TOONBO Privacy Policy

1. Collection and Use of Personal Information

Personal information is information that identifies a particular person or how to contact a particular person. You may be asked to provide your personal information anytime you are in contact with TOONBO or a TOONBO affiliated company. TOONBO and its affiliates may share this personal information with each other and use it consistent with this Privacy Policy. They may also combine it with other information to provide and improve our products, services, content, and advertising. You are not required to provide the personal information that we have requested but, if you chose not to do so, in many cases we will not be able to provide you with our products or services or respond to any queries you may have.

Personal information we collect

When you create a TOONBO account or purchase a TOONBO product or service, we may collect your name, mailing address, phone number, email address, device identifiers, IP address, location information, credit card information and profile information where the contact is via social media.
When you share your content with family and friends using TOONBO products, send gift certificates and products, or invite others to participate in TOONBO services or forums, TOONBO may collect the information you provide about those people such as name, mailing address, email address, and phone number. TOONBO will use such information to fulfill your requests, provide the relevant product or service, or for anti-fraud purposes.

How we use personal information

We may process your personal information: for the purposes described in this Privacy Policy, with your consent, for compliance with a legal obligation to which TOONBO is subject, for the performance of a contract to which you are party, in order to protect your vital interests, or when we have assessed it is necessary for the purposes of the legitimate interests pursued by TOONBO or a third party to whom it may be necessary to disclose information. If you have questions about this legal basis you can contact the Data Protection Officer.

The personal information we collect allows us to keep you posted on TOONBO’s latest product announcements, software updates, and upcoming events. If you don’t want to be on our mailing list, you can opt-out anytime by updating your preferences.

We also use personal information to help us create, develop, operate, deliver, and improve our products, services, content and advertising, and for loss prevention and anti-fraud purposes. We may also use your personal information for account and network security purposes, including in order to protect our services for the benefit of all our users, and pre-screening or scanning uploaded content for potentially illegal content, including child sexual exploitation material. Where we use your information for anti-fraud purposes it arises from the conduct of an online transaction with us. We limit our uses of data for anti-fraud purposes to those which are strictly necessary and within our assessed legitimate interests to protect our customers and our services. For certain online transactions we may also validate the information provided by you with publicly accessible sources.

We may use your personal information, including date of birth, to verify identity, assist with identification of users, and to determine appropriate services. For example, we may use date of birth to determine the age of TOONBO account holders.

From time to time, we may use your personal information to send important notices, such as communications about purchases and changes to our terms, conditions, and policies. Because this information is important to your interaction with TOONBO, you may not opt out of receiving these communications.

We may also use personal information for internal purposes such as auditing, data analysis, and research to improve TOONBO’s products, services, and customer communications.

If you enter into a sweepstake, contest, or similar promotion we may use the information you provide to administer those programs.

Source of your personal information where they are not collected from you

We may have received your personal information from other persons if that person has shared their content with you using TOONBO products, sent gift certificates and products, or invited you to participate in TOONBO services or forums. We may also validate the information provided by you when creating an TOONBO ID with a third party for security and fraud prevention purposes.

2. Collection and Use of Non-Personal Information

We also collect data in a form that does not, on its own, permit direct association with any specific individual. We may collect, use, transfer, and disclose non-personal information for any purpose. The following are some examples of non-personal information that we collect and how we may use it:
We may collect information such as occupation, language, zip code, area code, unique device identifier, referrer URL, location, and the time zone where an TOONBO product is used so that we can better understand customer behavior and improve our products, services, and advertising.

We may collect information regarding customer activities on our website and from our other products and services. This information is aggregated and used to help us provide more useful information to our customers and to understand which parts of our website, products, and services are of most interest. Aggregated data is considered non‑personal information for the purposes of this Privacy Policy.

We may collect and store details of how you use our services, including search queries. This information may be used to improve the relevancy of results provided by our services. Except in limited instances to ensure quality of our services over the Internet, such information will not be associated with your IP address.

With your explicit consent, we may collect data about how you use your device and applications in order to help app developers improve their apps.

If we do combine non-personal information with personal information the combined information will be treated as personal information for as long as it remains combined.

3. Cookies and Other Technologies

TOONBO’s websites, online services, interactive applications, email messages, and advertisements may use “cookies” and other technologies such as pixel tags and web beacons. These technologies help us better understand user behavior, tell us which parts of our websites people have visited, and facilitate and measure the effectiveness of advertisements and web searches. We treat information collected by cookies and other technologies as non‑personal information. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered personal information by local law, we also treat these identifiers as personal information. Similarly, to the extent that non-personal information is combined with personal information, we treat the combined information as personal information for the purposes of this Privacy Policy.

If you do not wish to receive ads targeted to your interests from TOONBO’s advertising platform, you can choose to enable Limit Ad Tracking, which will opt your TOONBO ID out of receiving such ads regardless of what device you are using. If you enable Limit Ad Tracking on your mobile device, third-party apps cannot use the Advertising Identifier, a non-personal device identifier, to serve you targeted ads. You may still see ads in the App Store or News based on context like your search query or the channel you are reading. In third-party apps, you may see ads based on other information.

TOONBO also uses cookies and other technologies to remember personal information when you use our website, online services, and applications. Our goal in these cases is to make your experience with TOONBO more convenient and personal. For example, knowing your first name lets us welcome you the next time you visit the TOONBO Online Store. Knowing your country and language − and if you are an educator, your school − helps us provide a customized and more useful shopping experience. Knowing someone using your computer or device has shopped for a certain product or used a particular service helps us make our advertising and email communications more relevant to your interests. Look at the settings in your browser to find out how to disable cookies. Please note that certain features of the TOONBO website will not be available once cookies are disabled

We gather some information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type and language, Internet service provider (ISP), referring and exit websites and applications, operating system, date/time stamp, and clickstream data. We use this information to understand and analyze trends, to administer the site, to learn about user behavior on the site, to improve our product and services, and to gather demographic information about our user base as a whole. TOONBO may use this information in our marketing and advertising services.

In some of our email messages, we use a “click-through URL” linked to content on the TOONBO website. When customers click one of these URLs, they pass through a separate web server before arriving at the destination page on our website. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages. Pixel tags enable us to send email messages in a format customers can read, and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to customers.

4. Disclosure to Third Parties

At times TOONBO may provide third parties with certain personal information to provide or improve our products and services, including to deliver products at your request, or to help TOONBO market to consumers. When we do, we require those third parties to handle it in accordance with relevant laws. TOONBO does not sell personal information, and personal information will never be shared with third parties for their marketing purposes. For example, when you purchase and activate your iPhone, you authorize TOONBO and your carrier to exchange the information you provide during the activation process to carry out service, including information about your device. If you are approved for service, your account will be governed by TOONBO and your carrier’s respective privacy policies.

Service Providers

TOONBO shares personal information with companies who provide services such as information processing, extending credit, fulfilling customer orders, delivering products to you, managing and enhancing customer data, providing customer service, assessing your interest in our products and services, and conducting customer research or satisfaction surveys. These companies are obligated to protect your information and may be located wherever TOONBO operates.

Others

Sometimes TOONBO may be required by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence to disclose your personal information. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you, but only where there is a lawful basis for doing so, if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users. This could include providing information to public or governmental authorities. Additionally, in the event of a reorganization, merger, or sale we may transfer any and all personal information we collect to the relevant third party.

5. Protection of Personal Information

TOONBO takes the security of your personal information very seriously. TOONBO protects your personal information during transit using encryption such as Transport Layer Security (TLS). When your personal data is stored by TOONBO, we use computer systems with limited access housed in facilities using physical security measures that store data in encrypted form.

When you use some TOONBO products, services, or applications or post on an TOONBO forum, chat room, or social networking service, the personal information and content you share is visible to other users and can be read, collected, or used by them. You are responsible for the personal information you choose to share or submit in these instances. For example, if you list your name and email address in a forum posting, that information is public. Please take care when using these features.

6. Integrity and Retention of Personal Information

TOONBO makes it easy for you to keep your personal information accurate, complete, and up to date. We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy and our service specific privacy summaries. When assessing these periods we carefully examine our need to collect personal information at all and if we establish a relevant need we only retain it for the shortest possible period to realize the purpose of collection unless a longer retention period is required by law.

7. Your Privacy Rights

You can help ensure that your contact information and preferences are accurate, complete, and up to date by signing in to your TOONBO ID account page. For other personal information we hold, we will provide you with access (including a copy) for any purpose including to request that we correct the data if it is inaccurate or delete the data if TOONBO is not required to retain it by law or for legitimate business purposes.

We may decline to process requests that are frivolous, jeopardize the privacy of others, are impractical, or for which access is not otherwise required by local law. We may also decline aspects of deletion or access requests if we believe doing so would undermine our legitimate use of data for anti-fraud and security purposes as described earlier. Online tools for the exercise of access, deactivation/restriction, correction, or deletion requests are available on a regional basis by signing in to privacy.TOONBO.com.

California

The California Consumer Privacy Act provides California consumers with the right to obtain from TOONBO information about the personal information about you that we collect, use, and disclose. You can exercise your rights through an authorized agent by providing relevant details to allow sign in to privacy.TOONBO.com. If you cannot access TOONBO’s online tools, you or your agent can make a request to info@toonbo.com or by calling 1-310-279-5288. If you choose to exercise your privacy rights, you have the right to not to receive discriminatory treatment or a lesser degree of service from TOONBO.

Nevada

You have the right to opt-out of the sale of your personal information. TOONBO does not sell your personal information. See our page on understanding and controlling your personal information for more information on exercising your rights. Where the online tool is not currently available for access requests in your region, a request may be made directly to TOONBO.com/legal/privacy/contact.

8. Children & Education

We understand the importance of taking extra precautions to protect the privacy and safety of children using TOONBO products and services. Children under the age of 13, or equivalent minimum age in the relevant jurisdiction, are not permitted to create their own TOONBO accounts. For example, a parent must review the TOONBO account and privacy disclosures and agree to the Consent to TOONBO’s Collection, Use and Disclosure of Your Child’s Information before they can begin the TOONBO account creation process for their child. If we learn that we have collected the personal information of a child under 13, or equivalent minimum age depending on jurisdiction, outside the above circumstances we will take steps to delete the information as soon as possible. If at any time a parent needs to access, correct, or delete data associated with their child’s TOONBO account, they may contact us at info@toonbo.com or1-310-279-5288.

9. Location-Based Services

To provide location-based services on TOONBO products, TOONBO and our partners and licensees, such as maps data providers, may collect, use, and share precise location data, including the real-time geographic location of your TOONBO computer or device. Where available, location-based services may use GPS, Bluetooth, and your IP Address, along with crowd-sourced Wi-Fi hotspot and cell tower locations, and other technologies to determine your devices’ approximate location. Unless you provide consent, this location data is collected anonymously in a form that does not personally identify you and is used by TOONBO and our partners and licensees to provide and improve location-based products and services. For example, your device may share its geographic location with application providers when you opt in to their location services.

10. Third‑Party Sites and Services

TOONBO websites, products, applications, and services may contain links to third-party websites, products, and services. Our products and services may also use or offer products or services from third parties. Information collected by third parties, which may include such things as location data or contact details, is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties.

11. Our Companywide Commitment to Your Privacy

To make sure your personal information is secure, we communicate our privacy and security guidelines to TOONBO employees and strictly enforce privacy safeguards within the company.

12. Privacy Questions

If you have any questions or concerns about TOONBO’s Privacy Policy or data processing, you would like to contact our Data Protection Officer, or if you would like to make a complaint about a possible breach of local privacy laws, please contact us. You can always contact us at info@toonbo.com or1-310-279-5288. When a privacy question or question about personal information received in response to an access/download request is received we have a dedicated team which triages your contact to address your issue. Where your issue may be more substantive in nature, we may request more information from you. All such substantive contacts receive a response within seven (7), days wherever possible – providing a response on the issue raised, requesting additional information where necessary or indicating that a response will require additional time. You may at any time refer your complaint to the relevant regulator in your jurisdiction if you are unsatisfied with a reply received from us. If you ask us, we will endeavor to provide you with information about relevant complaint avenues which may be applicable to your circumstances.

Where your complaint indicates an improvement could be made in our handling of privacy issues we will take steps to make such an update at the next reasonable opportunity. In the event that a privacy issue has resulted in a negative impact on you or another person we will take steps to address that with you or that other person.

TOONBO may update its Privacy Policy from time to time. When we change the policy in a material way, a notice will be posted on our website along with the updated Privacy Policy. We will also contact you via your contact information on file, for example by email, notification or some other equivalent method.

TOONBO – Privacy Policy
Rev. 1.0 May 31, 2020

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