1. INTRODUCTION

Toonsutra, Inc. (“Toonsutra,” “we,” “us,” or “our”) respects the privacy of its Users (“User,” “your,” or “you”). This Privacy Policy (the “Privacy Policy”) explains how we collect, use, disclose, and safeguard your information when you use Toonsutra Platform (the “Platform”) through Toonsutra’s website athttps://company.toonsutra.com/(the “Website”) or Toonsutra’s mobile application (the “App”).

Toonsutra is a mobile app (and mobile website) that allows users to read comics on their devices. It’s a freemium model where users can read a few comics for free, after which users will need to make a purchase. Toonsutra is committed to protecting the privacy of its Users whose information is collected and stored while using Toonsutra’s Platform through our Website or App. This Privacy Policy is applicable to our Website, Platform and all applications offered for sale to the public.

The capitalized terms have the same meaning as ascribed in our Terms of Service as applicable, unless otherwise noted here.

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR INFORMATION AND HOW WE WILL TREAT IT. BY ACCESSING OR USING OUR WEBSITE, APP, AND PLATFORM, YOU AGREE TO ACCEPT ALL THE TERMS CONTAINED IN THIS PRIVACY POLICY AND ACKNOWLEDGE AND AGREE WITH THE PRACTICES DESCRIBED HEREIN. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS AND USE OUR WEBSITE, APP, AND PLATFORM.

IF YOU HAVE ANY QUESTIONS REGARDING THIS PRIVACY POLICY, PLEASE SEND US AN EMAIL ATprivacy@toonsutra.com.

WE DO NOT SELL YOUR PERSONAL INFORMATION, NOR DO WE INTEND TO DO SO. WE DO NOT GIVE ACCESS TO YOUR PERSONAL INFORMATION TO THIRD PARTIES EXCEPT TO SUBPROCESSORS TO ASSIST US IN THE PROVISION OF OUR SERVICES TO YOU.

2. WHAT INFORMATION DO WE COLLECT?

When you register to use our Website, App, or Platform, we collect personal information (also referred to as personally identifiable information or “PII”) which may include your name, address, online contact information such as your email address or username, phone number, and other personal information. The information so collected will be stored on our servers. You are able to change your personal information via email by contacting us atprivacy@toonsutra.com or through your profile or account settings on our Website, App, or Platform.

1. Geolocation and Equipment Information. We may collect information that does not personally identify you such as (i) your geolocation, and (ii) information about your internet connection, the equipment you use to access our Website, App, or Platform, and usage details.
2. Financial Information. We currently do not collect or store any credit cards or bank information, as we are using a third-party payment processor. However, we will update this Privacy Policy when we start using and storing such information. We will also inform you via reasonable means if we start collecting such information from you.

3. HOW DO WE COLLECT INFORMATION?

We collect personal information from you in the following ways:

• At registration on our Website, App, or Platform;
• Through mobile and desktop applications your downloads from our Website, App, or Platform;

1. When you interact with our advertising and applications on third-party websites and services;
2. From you placing an order, which includes details of transactions you carry out on our Website, App, or Platform;
3. When you subscribe to a newsletter;
4. From your responses to a survey;
5. From forms filled out by you;
6. From records or copies of correspondences (including email addresses) if you contact us;
7. From search queries on our Website, App, or Platform;
8. When you post information to be displayed publicly.

We collect information automatically when you use our Platform:

1. Usage details;
2. IP addresses;
3. Browser cookies;
4. Flash cookies;
5. Web beacons on our Website;
6. Web beacons in our emails;
7. Other tracking technologies.

4. HOW DO WE USE YOUR INFORMATION?

We use the information you provide to:

1. Personalize your experience in using our Platform;
2. Provide you with information, products, or services requested from us;
3. Present our Website, App, and Platform and their contents to you;
4. Provide you with notices about account and/or subscription, including expiration and renewal notices;
5. Carry out obligations and enforce rights arising from contracts entered into between you and us, including billing and collection;
6. Notify you about changes to our Website, App, and Platform and any products or services;
7. Allow you to participate in interactive features on our Website, App, and Platform;
8. Improve the Website, App, and Platform;
9. Improve our customer service;
10. Administer contests, promotions, and surveys or other Website, App, and Platform features;
11. Process transactions;
12. Anonymize data and aggregate data for statistics;
13. Contact you for other purposes with your consent;
14. Contact you about our products and services that may be of interest;
15. Enable the display of advertisements to our advertisers’ target audiences.

5. OUR COOKIE POLICY

Cookies are small pieces of text used to store information on web browsers. Cookies are used to store and receive identifiers and other information on computers, phones, and other devices. Other technologies, including data we store on your web browser or device, identifiers associated with your device, and other software, are used for similar purposes. In this Privacy Policy, we refer to all of these technologies as “Cookies.”

We use Cookies on our Website and App to:

• Help remember and process items in the shopping cart;
• Understand and save your preferences for future visits;
• Keep track of advertisements;
• Compile aggregate data about site traffic and site interactions;
• Allow trusted third-party services to track information on our behalf.

You can set your browser to refuse all or some browser Cookies, but it may affect your user experience. We honor Do Not Track signals and, if one is in place, we will not track, plant cookies, or use advertising.

We allow third-party behavioral tracking and links to third-party web pages. These third-party sites have separate and independent privacy policies. We, therefore, have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our Website, App, or Platform and welcome any feedback atprivacy@toonsutra.com.

6. HOW DO WE PROTECT INFORMATION WE COLLECT?

Our Website and App receive regular security scans and penetration tests. Our Website and App also receive regular malware scans. In addition, our Website and App use an SSL certificate as an added security measure.

We require username and passwords for our employees who can access your personal information that we store and/or process on our Platform and servers. In addition, we actively prevent third parties from getting access to your personal information that we store and/or process on our Platform and servers. We accept payment by credit card through a third-party credit card processor on our behalf.

7. DATA SECURITY MEASURES

a. Security Measures. We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, App, or Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website, App, or Platform. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our Website, App, or Platform.

b. Fair Information Practice Principles. In the event of a personal data breach, we will notify you via (i) email and/or (ii) our Platform notification system on our Website and/or App. We agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.

8. DISCLOSURE OF PERSONAL INFORMATION

There are times when we may share Personal Information that you have shared with us with others to enable us to provide you our Services, including contractors, service providers, and third parties (“Partners”). This section discusses only how Toonsutra may share such information with Partners. We will ensure that our Partners protect your Personal Information. The following describes how and with whom we may share your Personal Information:

• a. We may disclose aggregated, de-personalized information about you that does not identify any individual to other parties without restriction, such as for marketing, advertising, or other uses.
• b. We may disclose personal information to our subsidiaries and affiliates.
• c. We may disclose personal information to contractors, service providers, and other third parties.
• d. We require all contractors, service providers, and other third parties to whom we disclose your personal information to be under contractual obligations to keep personal information confidential and to use it only for the purposes for which we disclose them.
• e. We may disclose personal information in the event of a merger, sale of business, etc.
• f. We may disclose to third parties to market their products and services to you if you have either consented or not opted out of these disclosures.
• g. We require all other Partners, to whom we disclose your personal information, to enter into contracts with us to keep personal information confidential and use it only for the purposes for which we disclose it to such Partners.
• h. We disclose personal information to fulfill the purpose for which you have provided it, for instance, if you gave us an email address to use the “email a friend” feature of the Platform.
• i. We may disclose personal information for any other purpose for which you have provided it.
• j. We may only disclose personal information as described in this Privacy Policy or with your consent.

Other Disclosure of Personal Information

• a. We will disclose personal information (i) to comply with any court order, law, or legal process, including to respond to any government or regulatory request, (ii) to enforce or apply our Terms of Service and other agreements, including for billing and collection purposes, (iii) if we believe it is necessary or appropriate to protect the rights, property, or safety of Toonsutra, our customers, or others, and/or (iv) if it is necessary or appropriate to protect the rights, property, or safety of Toonsutra, our customers, or others, and this includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Third Party Disclosure

• a. We do not sell, trade, rent, or otherwise transfer personal information to others, unless we provide you with advance notice. This does not include our hosting partners and other parties who assist us in operating our Website, App, or Platform, conducting our business, or servicing you, so long as those parties agree to keep this information confidential.
• b. We may provide non-personally identifiable visitor information for marketing purposes.

9. GOOGLE ADSENSE AND GOOGLE ANALYTICS

Google, as a third-party vendor, uses Cookies to serve advertisements to Users on our Website, App, and Platform. Google uses first-party Cookies, such as Google Analytics Cookies, to compile data regarding User interactions with ad impressions and other ad service functions as they relate to our Platform. We currently use Google Analytics to collect and process certain Website and App usage data. To learn more about Google Analytics and how to opt-out, please visit https://policies.google.com/privacy/google-partners.

10. FOR OUR EUROPEAN CUSTOMERS AND VISITORS

We are headquartered in the United States. Most of the operations are located in the United States. Your Personal Information, which you give to us during registration or use of our Website, App, or Platform, may be accessed by or transferred to us in the United States. If you are visiting our Website or registering for our Services from outside the United States, be aware that your Personal Information may be transferred to, stored, and processed in the United States. Our servers or our third-party hosting services partners are located in the United States. By using our site, you consent to any transfer of your Personal Information out of Europe, UK, or Switzerland for processing in the US or other countries.

a. EU Standard Contractual Clauses

On June 4, 2021, the EU promulgated a new set of SCCs (the “New SCCs”), which replaced the old SCCs that had been in place for over a decade. We now comply with the New SCCs with respect to the transfer of Personal Data from the EU to the US and other countries for processing. If there is any conflict between the terms and conditions in this Privacy Policy and your rights under the New SCCs, the terms and conditions in the new SCCs will govern.

b. The New SCCs

The New SCCs took effect on June 27, 2021. The Old SCCs may still be used for new data transfers in new contracts during a three-month transition period that ends on September 27, 2021. Existing data transfer contracts that rely on the Old SCCs can be used until December 27, 2022, by which time all data transfers relying on the Old SCCs must be transitioned to the New SCCs. As of now, we and our customers are using the New SCCs to transport Personal Data from the EU to other countries, including the US, for processing by us.

You are the Controller, as defined in the GDPR, and the Exporter, as defined in the New SCCs, of the Personal Data and we are a processor, as defined in the GDPR, and the Importer of such Personal Data. You agree to comply with the GDPR rules that apply to Controllers and the New SCCs rules that apply to Data Exporters. We agree to comply with the GDPR rules that apply to Processors and the New SCCs rules that apply to Data Importers.

11. YOUR CALIFORNIA PRIVACY RIGHTS

Toonsutra does not sell, trade, or otherwise transfer to outside third parties your “Personal Information” as defined under the California Civil Code Section § 1798.82(h). Additionally, California Civil Code Section § 1798.83 permits Users of our Website, App, or Platform that are California residents to request certain information regarding our disclosure of their Personal Information to third parties for their direct marketing purposes. To make a request for such disclosure, or identification and/or deletion of Personal Information in all our systems that we store on you, please send an email to privacy@toonsutra.com.

12. COPPA COMPLIANCE (FOR CHILDREN UNDER 13 USERS ONLY)

The Children’s Online Privacy Protection Act (“COPPA”) is a federal legislation that applies to entities that collect and store “Personal Information,” as the term is defined under COPPA, from children under the age of 13. We are committed to ensuring compliance with COPPA. Our Website, App, and Platform are not meant for use by children under the age of 13. Our Website, App, and Platform do not target children under the age of 13, but we do not age-screen or otherwise prevent the collection, use, and personal disclosure of persons identified as under 13. If you would like to know more about our practices and specifically our practices in relation to COPPA compliance, please email us at privacy@toonsutra.com.

IF YOU ARE UNDER 13, PLEASE DO NOT ACCESS OR USE OUR WEBSITE, APP, OR PLATFORM.

13. CAN-SPAM ACT OF 2003

The CAN-SPAM Act establishes requirements for commercial messages, gives recipients the right to have businesses stop emailing them, and spells out penalties for violations. Per the CAN-SPAM Act, we will:

• a. not use false or misleading subjects or email addresses;
• b. identify the email message as an advertisement in some reasonable way;
• c. monitor third-party email marketing services for compliance, if one is used;
• d. honor opt-out/unsubscribe requests quickly;
• e. give an “opt-out” or “unsubscribe” option.

If you wish to opt out of email marketing, follow the instructions at the bottom of each email or contact us at privacy@toonsutra.com and we will promptly remove you from all future marketing correspondences.

14. MODIFICATIONS TO OUR PRIVACY POLICY

We will post any changes to this Privacy Policy in a notice of the change at the bottom of our web page with a hyperlink thereto. We will also send you an email describing such changes. Please regularly review this Privacy Policy. Notwithstanding if you continue to use our services, you are bound by any changes that we make to this Privacy Policy.

15. LIST OF THIRD-PARTY SERVICE PROVIDERS

Toonsutra uses the following third-party service providers for the provision of services as detailed under Terms of Service:

Additionally, if you have any questions or concerns about our third-party service providers, please email us at privacy@toonsutra.com.

16. COPYRIGHT INFRINGEMENT/DMCA NOTICE

If you believe that any content on our Website, App, or Platform violates your copyright, and you wish to have the allegedly infringing material removed, the following information in the form of a written notification (pursuant to the Digital Millennium Copyright Act of 1998 (“DMCA Takedown Notice”)) must be provided to our designated Copyright Agent.

• a. Your physical or electronic signature;
• b. Identification of the copyrighted work(s) that you claim to have been infringed;
• c. Identification of the material on our Website, App, or Platform that you claim is infringing and that you request us to remove;
• d. Sufficient information to permit us to locate such material;
• e. Your address, telephone number, and email address;
• f. A statement that you have a good faith belief that use of the objectionable material is not authorized by the copyright owner, its agent, or under the law;
• g. A statement that the information in the notification is accurate, and under penalty of perjury, that you are either the owner of the copyright that has allegedly been infringed or that you are authorized to act on behalf of the copyright owner.

Toonsutra’s Copyright Agent to receive DMCA Takedown Notices is Vishal Anand, at privacy@toonsutra.com and at Toonsutra, Attn: DMCA Notice, Toonsutra, Inc. 355 Bryant Street, Suite # 403, San Francisco CA 94107.

You acknowledge that for us to be authorized to take down any content, your DMCA Takedown Notice must comply with all the requirements of this Section. Please note that, pursuant to 17 U.S.C. § 512(f), any misrepresentation of material fact (falsities) in a written notification automatically subjects the complaining party to liability for any damages, costs, and attorney’s fees incurred by Toonsutra in connection with the written notification and allegation of copyright infringement.

17. ANTI-BRIBERY COMPLIANCE

Toonsutra represents and warrants that it is fully aware of and will comply with, and in the performance of its obligations hereunder will not take any action or omit to take any action that would cause it or its customers to be in violation of:

• (i) U.S. Foreign Corrupt Practices Act,
• (ii) U.K. Anti-Bribery Act,
• (iii) India Prevention of Corruption Act of 1988,
• (iv) any other applicable anti-bribery statutes and regulations, and
• (v) any regulations promulgated under any such laws.

The Company represents and warrants that neither it nor any of its employees, officers, or directors is an official or employee of any government (or any department, agency, or instrumentality of any government), political party, state-owned enterprise or a public international organization such as the United Nations, or a representative of any such person (each, an “Official”).

The Company further represents and warrants that, to its knowledge, neither it nor any of the Supplier Personnel has offered, promised, made, or authorized to be made, or provided any contribution, thing of value or gift, or any other type of payment to, or for the private use of, directly or indirectly, any Official for the purpose of influencing or inducing any act or decision of the Official to secure an improper advantage in connection with, or in any way relating to:

• (A) any government authorization or approval involving Toonsutra, or
• (B) the obtaining or retention of business by Toonsutra.

Supplier further represents and warrants that it will not in the future offer, promise, make or otherwise allow to be made or provide any payment and that it will take all lawful and necessary actions to ensure that no payment is promised, made, or provided in the future by any of the Supplier Personnel.

18. CONTACT US

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at:

Email: privacy@toonsutra.com

PLEASE NOTE: IF YOU USE OUR WEBSITE, APP, OR PLATFORM, YOU HAVE AGREED TO AND ACCEPTED THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY AND THE TERMS AND CONDITIONS SET FORTH IN OUR TERMS OF SERVICE, AS APPLICABLE. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY OR OUR TERMS OF SERVICE, PLEASE DO NOT USE OUR WEBSITE, APP, OR PLATFORM.