Privacy Policy

KODANSHA USA PUBLISHING, LLC
Privacy Policy

Last Updated: July 18, 2024

INTRODUCTION

As used in this Privacy Policy, “KUP”, “Company”, “we”, “us”, or “our” refer to Kodansha USA Publishing, LLC. Except as specifically provided herein, this Privacy Policy does not apply to our parent company, Kodansha Ltd., or any of the other companies in the Kodansha corporate group.

Your privacy is important to KUP, and we are committed to protecting it through this Privacy Policy, which is part of the Terms of Use (“TOU”) located at /terms-of-use/. Initially capitalized terms not otherwise defined in this Privacy Policy have the meaning set forth in the TOU.

We may receive information about you through your use of our web domains or app, including kodansha.us and subdomains (collectively, the “Site”).

This Privacy Policy describes: (i) the types of information we collect from you or that you may provide when you visit and/or use the Site or purchase our digital products (“Products”) on the Site; and (ii) our practices for collecting, using, maintaining, protecting, sharing, and disclosing that information. Please familiarize yourself with our privacy practices and contact us as described below under “Contacting KUP” if you have any questions.

Unless it specifically states otherwise, this Privacy Policy applies to the collection, use, and disclosure of information that we collect in various ways, including:

Through the Site;
When you purchase our Products;
In email, text, and other electronic messages between you and us and/or the Site; and
When you interact with our advertising and applications, if any, on third-party websites and services, if those applications or advertising include links to this Privacy Policy.

It does not apply to information collected by:

Us offline or through any other means, including on any other website or application operated by us or any third party (including but not limited to our affiliates and subsidiaries); and/or
Any third party, including without limitation: (i) any application or content (including without limitation advertising) that may link to or be accessible from or located on the Site; and/or (ii) third-party websites or services that display KUP content, which may include Apple Books, Comixology, and Google Play Books.

If you view or use any of these other websites or online services, please note that any information you may provide will be subject to the privacy policy and other terms and conditions of those websites or services and not this Privacy Policy.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will handle your information. If you do not agree with our policies and practices, you agree not to use any part of the Site. To the fullest extent allowed by law (excluding if you are data subject in receipt of our services from the European Economic Area (EEA), the United Kingdom, or Switzerland): (i) by accessing or using any part of the Site, you agree to this Privacy Policy; and (ii) your continued use of the Site after we make changes to this Privacy Policy constitutes acceptance of those changes. If you are a data subject in receipt of our services from the EEA, the United Kingdom or Switzerland, please refer to the Privacy section for users from the EEA, UK, and Switzerland.

Please check this Privacy Policy regularly and periodically for updates.

Changes to Our Privacy Policy

This Privacy Policy may change from time to time. It is our policy to post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you directly if we have your email address and post a separate notice on the Site. The date this Privacy Policy was last updated is identified at the top of the first page of this Privacy Policy. You are responsible for ensuring we have an up-to-date and valid email address for you and for regularly and periodically visiting this Privacy Policy to check for any changes. As noted above, subject to applicable law, your continued use of the Site following the posting of changes constitutes your acceptance of such changes.

When we refer to the term “GDPR” in this Privacy Policy we mean the European Union General Data Protection Regulation or the UK GDPR.

Information We Collect
How We Collect Your Information and How Long We Keep It
How We Share Your Information
Children’s Privacy
How We Protect Your Information
How You May Change, Remove, or Export Your Information
Links To Third-Party Websites and Services
Non-US Users
Privacy Section for Users from the UK, EEA, and Switzerland
Your California Privacy Rights
Your Virginia Privacy Rights
Do Not Track Disclosure
Disputes; Binding Arbitration
Contacting KUP

I. INFORMATION WE COLLECT

A. We collect several types of information from and about users of the Site. In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months including:

Contact Data/Identifiers – Information by which you may be personally identified, such as name, date of birth, postal address, billing address, email address, or telephone number, social media handle;
Financial Data/Personal information categories listed in the California Customer Records statute – credit card number, debit card number, bank account details, or any other financial information;
Profile data – Account username; password; the content of any inquiries you submit to us; records and copies of your correspondence (including email addresses), if you contact us or responses to surveys we may ask you to complete; or your search queries on the Site;
Sales data/Commercial information – records of transactions, Products purchased, obtained, or considered, or other purchasing history or tendencies;
Technical data/Network Activity: Technical information, including but not limited to the IP address through which you access the Site and the unique mobile device ID or unique virtual device identifier for any mobile device used to access your account. Information about your internet connection, the equipment you use to access the Site; browser type and operating system, internet Service Provider (“ISP”), and country of registration (collectively, “Device Information”), and aggregated Site use information; and metadata and other information associated with files stored on your device;
Behavioral data – data related to your usage details, including data relating to your browsing activity or interaction with our emails, obtained through the use of cookies, pixel tags and other similar technologies; information about when your current or previous sessions started; and details about any Products you viewed or purchased through the Site;
Marketing and communications data – marketing preferences and service communications preferences.

B. Use of Personal Information.

The information we collect includes personal information, and we maintain it or associate it with personal information we collect in other ways or receive from third parties. This helps us improve the Site and deliver a better and more personalized service, including by enabling us to:

Create, maintain, customize, and secure your account with us;
Process requests, purchases, transactions, and payments and prevent transactional fraud;
Provide you with support and respond to your inquiries;
To process your responses to our surveys or your feedback on our Sites and Products;
To administer sweepstakes or contests (individually a “Promotion” and collectively “Promotions”). Please see our Promotions section below for more information;
Estimate our audience size and usage patterns;
Store information about your preferences, allowing us to customize the Site according to your individual interests;
Maintain the safety, security, and integrity of our Site and Products;
Speed up your searches;
Recognize you when you return to the Site;
Promote our Site and Products on social media sites and when you interact with our social media pages. Please see our Marketing and Advertising section below for more information; In connection with a business transition such as a merger, reorganization, acquisition by another company, or sale of any of our assets; and
To comply with our legal obligations, to enforce our legal rights, to protect rights of third parties, to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

Promotions

We may offer you the opportunity to receive special offers from us and/or our partner companies, such as a Promotion. If you choose to participate in a Promotion, we may request that you provide us with personal information such as your email address or mailing address as part of the registration process. We may require you to enter a region and language in order to provide relevant information in your language. We may also request or receive personal information during other interactions you have with us in relation to your Promotion entry. Our Promotions are subject to separate terms and conditions, which you may be required to accept as a condition of entry.

Marketing and Advertising

If we send you marketing communications by physical mail and/or email:

We will use your name, email address and postal address and marketing and communications data to send you marketing communications by physical mail and/or email. Our marketing will include press releases and information about us, our Site, our Products, and the offers and Promotions we offer from time to time.

Our marketing communications will include non-personalized marketing. Non-personalized marketing is marketing that is not tailored to you.

II. HOW WE COLLECT YOUR INFORMATION AND HOW LONG WE KEEP IT

We collect information:

Directly from you when you provide it to us, including without limitation by (a) entering your Contact details (name and/or email address) in order to receive our email newsletter, (b) providing personal information where necessary in order to obtain support for the Site, (c) providing us with your email address so that we may provide you with special offers, (d) using your email address as your username for your account, if any, (e) entering your email address, postal address, credit card, or other Financial Data to complete a purchase, (f) creating an account with us, (g) getting in contact or making an inquiry with us via the Site or email, and/or (h) using your email address and/or mailing address for Promotions.
Automatically and indirectly from you as you navigate through the Site. Information collected automatically may include Technical data and Behavioral data (including usage details, IP addresses, geolocation, and other information collected through cookies, web beacons, and other tracking technologies). KUP does not use your IP address or Device Information to determine your exact location.
From third parties, for example, our business partners or third party data brokers, who may share personal information they collect.

Cookies:

We may use technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). The technologies we or our service providers, such as Google Analytics or other analytics services use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may have the option to refuse to accept browser cookies by activating the appropriate setting on your browser or responding to a prompt from a page you visit. Additionally, you may disable or delete similar data used by browser add-ons by changing the add-on’s settings or visiting the website of its manufacturer. If you do not accept cookies, however, you may not be able to use all or part of the Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Site. Cookies in the Site (“Site Cookies”) are only used to obtain browser or device-specific information. Site Cookies do not collect information from your computer or mobile device unrelated to the Site.
Third-Party Use of Cookies and Other Tracking Technologies. Some content, including advertisements and website security, on the Site may be served by third-parties, including advertisers, ad networks and servers, content providers, security providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use the Site. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties’ tracking technologies or how they may be used. Their placement and use of cookies and other technologies will be subject to their own privacy policies and terms and conditions. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

Retention of Your Personal Information

We will only store your information as long as necessary to fulfill the purposes for which the information is collected and processed or, where applicable law provides for longer storage and retention periods, for the storage and retention period required by law.

In respect of personal data that we process in connection with the supply of our Products, we may retain your personal data for up to six years from the date of supply of the relevant Products and in compliance with our data protection obligations. We may then destroy such files without further notice or liability.

Where we process personal data in connection with the registration and use of an account on our Site, we may retain your personal data for up to six years from the date that the relevant account is terminated (and in compliance with our data protection obligations). We may then destroy such files without further notice or liability.

Where we process any other personal data, we will retain relevant personal data for up to three years from the date of our last interaction with you (and in compliance with our data protection obligations). We may then destroy such files without further notice or liability.

If any personal data is only useful for a short period (e.g. for a specific activity, promotion or marketing campaign), we will not retain it for longer than the period for which it is used by us.

If you have opted out of receiving marketing communications from us, we will need to retain certain personal data on a suppression list indefinitely so that we know not to send you further marketing communications in the future. However, we will not use this personal data to send you further marketing unless you subsequently opt back in to receive such marketing.

III. HOW WE SHARE YOUR INFORMATION

We may share your personal information with other companies within our corporate group, including without limitation Kodansha, Ltd. and Kodansha USA, Inc. In that case, those companies will be subject to the terms of this Privacy Policy and applicable law with regard to that information.

We will not share your personal information with third-party advertisers, advertising networks and advertising platforms for their direct marketing purposes unless you provide your prior consent.

We may disclose personal information that we collect or you provide as described in this Privacy Policy:

To our affiliated companies;
To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them;
To third party physical mail/email marketing and CRM specialists who assist us in managing our marketing database and sending out our physical mail and email marketing communications and account related communications
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about the Site’s users is among the assets transferred;
To payment providers and banks who assist us with the processing of payments and refunds;
To third parties to market their products or services to you if you have consented to these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them;
To auditors, lawyers, accountants and other professional advisers;
To law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of KUP or a third party, to protect the safety of any person or to prevent or stop activity we consider to be illegal or unethical;
In connection with any Promotion you may enter, to third parties as necessary to administer, market, sponsor, or provide fulfillment under the Promotion or as required by applicable law;
From time to time, to other third parties for any other purpose disclosed by us when you provide the information; and where applicable, with your consent.

We may also disclose your personal information:

To comply with any court order, law, or legal process, including responding to any government or regulatory request;
To enforce or apply our TOU and other agreements; and
If we believe disclosure is necessary or appropriate to protect the rights, property, security, or safety of the Company, our customers, or others, or to address technical issues. This includes without limitation exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information

Please note the following mechanisms that allow you to exercise control over your information:

Tracking Technologies and Advertising. Please use our website pop-up to configure your cookie settings with KUP. You can also set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of the Site may then be inaccessible or not function properly.
Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote our own products or services, you can opt-out by sending us an email stating your request to [email protected]. If we have sent you a promotional email, you may opt out by using the “unsubscribe” link in the email. This opt-out does not apply to information provided to the Company as a result of a user service experience or other transactions.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. For example, you may opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website: https://www.networkadvertising.org.

California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.

IV. CHILDREN’S PRIVACY

To any parent of a child under thirteen (13) years of age, please speak with your child about communicating with strangers and disclosing personal information online. Please also familiarize yourself with the procedures in this Section V regarding consent to disclosure, and use of your child’s personal information. We will not collect more information from children under the age of thirteen (13) than is reasonably necessary to provide the Site. By written notice to us, parents may elect to restrict our collection and use of their child’s information to our internal purposes only and prohibit disclosure to third parties, unless disclosure is integral to the Site.

If you are under thirteen (13) years of age, please do not use or provide any information on the Site or through any of its features. Please do not register on the Site, make any purchases through the Site, or use any of the interactive or other features of the Site. Please do not provide any information about yourself to us, including but not limited to your name, address, telephone number, email address, or any screen or username you may use, without having your parent or legal guardian provide us prior written consent.

If we learn we have collected or received personal information from a child under thirteen (13) without verification of prior parental consent, we will delete that information. If you believe we may possess or have received any information from or about a child under thirteen (13) without such prior parental consent, please immediately contact us at [email protected].

Under GDPR, the applicable age for the requirements above in this section is sixteen (16) years of age, and in one or more countries outside the United States, the applicable age is fourteen (14) years of age, rather than thirteen (13) years of age.

V. HOW WE PROTECT YOUR INFORMATION

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, theft, use, alteration, and disclosure. All information you provide to us is stored on secure servers.

We do not and will not, at any time, request your credit card information, or other identification in a non-secure or unsolicited communication (such as email).

Unfortunately, the transmission of information via the internet is not completely secure. Although we attempt to protect your personal information, we cannot guarantee the security of your personal information transmitted to or on the Site. Any transmission of personal information is at your own risk. You assume this risk by using any part of the Site. We are not responsible for circumvention of any of our privacy settings or security measures, and/or any damages resulting from such circumvention.

If any breach of data system security occurs, we will make any legally required disclosure to you by email or posting on the Site as soon as reasonably possible. Any such disclosure will be subject to law enforcement requests and measures necessary to determine the breach’s scope and restore the reasonable integrity of the data system.

VI. HOW YOU MAY CHANGE OR REMOVE INFORMATION

Accessing and Correcting Your Information

You may send us an email at [email protected] to request access to, object to, rectify, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

You may email us at [email protected] to request that we delete your personal information from our database. For such requests, please write “delete my personal information” in the subject line, and include your first and last name and email address in the body of the message. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for administrative purposes.

Please note that we will store communications you may send through the Site, and they may not be subject to modification or deletion.

Please note, similar rights will apply in the UK, EEA and Switzerland. Please see the Privacy section for users from the EEA, UK, and Switzerland for further information.

VII. LINKS TO THIRD-PARTY WEBSITES AND SERVICES

The Site may contain links to other websites and online services, including to websites from which you may purchase KUP publications (such as Amazon, Apple Books, Google Play Books and others) and to third-party advertisements. If you choose to click through to one of these other websites or online services, please note that any information you may provide will be subject to the privacy policy and other terms and conditions of that websites or service, and not to this Privacy Policy. We do not control third-party websites or services, and the fact that a link to such a website or service appears on the Site does not mean that we endorse them or have approved their policies or practices relating to user information.

Before providing any information to any third-party website or service, we encourage you to review the privacy policy and other terms and conditions of that website or service. You agree that KUP will have no liability for any matters related to a third-party website or service that you provide information to, including without limitation their collection and/or handling of that information.

VIII. NON-US USERS

Information that you provide may be transferred or accessed by entities around the world as described in this Privacy Policy. If you are located outside the United States, you understand that we may transfer personal information to and process it in the United States. If you are located in the UK, EEA or Switzerland please note that your personal information may be transferred outside of the UK, EEA or Switzerland. Privacy and data protection laws of the United States may not be as comprehensive as those of your country. Please see the Privacy section for users from the EEA, UK, and Switzerland for further information.

IX. PRIVACY SECTION FOR USERS FROM THE UK, EEA AND SWITZERLAND

By continuing to use our Site you acknowledge that your data will be processed in accordance with this Privacy Policy.

A. Data Controller

For the purposes of this Privacy Policy, Kodansha USA Publishing, LLC is the Data Controller of your personal information.

B. Legal Grounds for Processing Your Personal Data

Under data protection law, there are various grounds on which we can rely when processing your personal data. In some contexts more than one ground applies. We have summarised these grounds as Contract, Legal obligation, Legitimate Interests and Consent below:

Contract: Processing necessary for performance of a contract with you or to take steps at your request to enter a contract, for example:
- Create, maintain, customize, and secure your account with us;
- Process requests, purchases, transactions, and payments and prevent transactional fraud;
Legal obligation: Processing necessary to comply with our legal obligations, for example:
- To comply with our legal obligations, to enforce our legal rights, to protect rights of third parties, to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
Legitimate Interests: Processing necessary for our or a third party’s legitimate interests, for example:
- Provide you with support and respond to your inquiries;
- To process your responses to our surveys or your feedback on our Sites and Products;
- To administer Promotions;
- Estimate our audience size and usage patterns;
- Store information about your preferences, allowing us to customize the Site according to your individual interests;
- Maintain the safety, security, and integrity of our Site and Products;
- Speed up your searches;
- Recognize you when you return to the Site;
- Promote our Site and Products on social media sites and when you interact with our social media pages;
- In connection with a business transition such as a merger, reorganization, acquisition by another company, or sale of any of our assets
Consent: You have given specific consent to processing your data, for example:
- To send marketing communications via physical mail or email;
- To collect data using cookies;

C. International Transfers of Personal Data

Non-UK/EEA countries may not provide the same degree of protection for your personal data, may not give you the same rights in relation to your personal data and may not have a data protection supervisory authority to help you if you have any concerns about the processing of your personal data. However, when transferring your personal data outside the UK, EEA, or Switzerland, we will comply with our legal and regulatory obligations in relation to your personal data, including having a lawful basis for transferring personal data and putting appropriate safeguards in place to ensure an adequate level of protection for the personal data. We will take reasonable steps to ensure the security of your personal data in accordance with applicable data protection laws.

When transferring your personal data outside the UK, EEA, or Switzerland, we will, where required by applicable law, implement at least one of the safeguards set out below. Please contact us if you would like further information on the specific mechanisms used by us when transferring your personal data outside the UK, EEA, or Switzerland.

Adequacy decisions: We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission and/or the UK/Swiss Government (as applicable).
Model clauses: Where we use certain service providers, we may use specific standard contractual clauses approved by the European Commission and/or the UK/Swiss Government which give personal data the same protection it has in Europe, Switzerland and/or the UK.

D. Rights of EEA Residents

If you are accessing or using the Site from within the UK, EEA or Switzerland, you may have the following rights under the GDPR (as well as other rights). If you wish to exercise any of these rights, you may do so by contacting us as provided (i) in Section XVI below, or (ii) otherwise in this Privacy Policy.

Right of Access: You have the right to obtain confirmation from us as to whether or not we process personal information from you and you also have the right to at any time obtain access to your personal information stored by us.
Right to Correction of your Personal Information: If we process your personal information, we use reasonable measures to ensure that your personal information is accurate and up-to-date for the purposes for which your personal information was collected. If your personal information is inaccurate or incomplete, you have the right to require us to correct it.
Right to Deletion of your Personal Information or Right to Restriction of Processing: You may have the right to require us to delete your personal information or to restrict of processing of your personal information.
Right to Withdraw your Consent: If you have given your consent to the processing of your personal information, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on the consent before the withdrawal.
Right to Data Portability: You may have the right to receive the personal information concerning you and which you have provided to us, in a structured, commonly used, and machine-readable format or to transmit this data to another controller.
Right to Object: You may have the right to object to the processing of your personal information as further specified in this Privacy Policy.
Right not to be subject to automated decision making and profiling: You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for the entering into, or the performance of, a contract between you and us.
Right to Lodge a Complaint with Supervisory Authority: You have the right to lodge a complaint with your relevant data protection supervisory authority. If you are located in the EEA further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. If you are located in the UK the regulatory authority is the Information Commissioner’s Office (“ICO”). Contact details for the ICO can be found on its website at https://ico.org.uk.

E. If You Fail to Provide Your Personal Data

Where we are required by law to collect your personal data, or we need to collect your personal data under the terms of a contract we have with you, and you fail to provide that personal data when we request it, we may not be able to perform the contract we have or are trying to enter into with you. This may apply where you do not provide the personal data we need in order to provide the Products you have requested from us or to process an application to register an account. In these circumstances, we may have to cancel your application or the provision of the relevant Products to you, in which case we will notify you.

X. YOUR CALIFORNIA PRIVACY RIGHTS

A. Shine the Light

If you are a resident of California, USA and a Site user, you have specific rights regarding our handling of your “personal information” as specifically defined in California’s “Shine the Light” law (See Cal. Civil Code Section § 1798.83). This law permits users of the Site who are California residents to request certain information regarding our disclosure of personal information to third parties. To make such a request, please (a) send an email to: [email protected] and include “California Privacy Rights” in the subject line of the email; or (b) write us at: 25 East 22nd Street, New York, NY 10010.

Within thirty (30) days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for such third parties’ direct marketing purposes during the immediately preceding calendar year, along with the categories of third parties receiving that personal information. A request may be made no more than twice per calendar year and we are not required to respond to requests made by means other than through the email address and mailing address above.

B. Your Rights Concerning California Personal Information

You have certain rights in connection with the collection of your personal information as a resident of California. You may exercise the following rights regarding your personal information, subject to certain exceptions and limitations:

The right to know the categories and specific pieces of personal data we collect, use, and disclose about you; the categories of sources from which we collected personal data about you; our purposes for collecting or selling personal data about you; the categories of personal data about you that we have either sold or disclosed for a business purpose; and the categories of third parties with which we have shared personal data.
The right to request deletion of your personal information we have collected and retained about you. We may deny your request for deletion if retaining the information is necessary for us or our affiliates to:
1. Complete the transaction for which we collected the personal information and provide the Service that you requested;
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity or prosecute those responsible for such activities;
3. Comply with legal obligations; or
4. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
The right to opt-out of the sale of your personal information. As the terms are defined under the CPRA, KUP does not sell your personal data.
The right to limit how your sensitive personal data is disclosed or shared.

To exercise any of the above rights, please contact us and submit the required verification information as described at [email protected] and include “California Privacy Rights” in the subject line of the email; or (b) write us at: Kodansha USA Publishing, LLC, 25 East 22nd Street, New York, NY 10010. We may request that you provide additional information to verify your identity or to correctly understand, evaluate and respond to your request, but you are not required to create an account with us in order to have it fulfilled. We ask you to provide specific personal information for our records and reference. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request.

You may designate an authorized agent to submit requests on your behalf by designating such an agent in writing. We may require the agent to provide us with proof that you have authorized the agent to make requests on your behalf prior to accepting requests from the agent.

We will not discriminate against you for exercising any of these rights under the CPRA above.

XI. YOUR VIRGINIA PRIVACY RIGHTS

If you are a Virginia resident, you have certain rights under the Virginia Consumer Data Protection Act (VCDPA). These include the right to (i) confirm whether or not a controller is processing the personal data and to access such personal data; (ii) correct inaccuracies in the personal data, taking into account the nature of the personal data and the purposes of the processing of the personal data; (iii) deletion of personal data; (iv) obtain a copy of the personal data that previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another controller without hindrance, where the processing is carried out by automated means; and (v) opt out of the processing of the personal data for purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.

If you wish to exercise your rights under the VCDPA please contact us by email at the email address provided in the “Contacting KUP” Section XIV below. If we refuse to take action on the request, you may appeal by sending an email to us at the email address above. You may submit a complaint to the Attorney General at https://www.oag.state.va.us/consumercomplaintform.

We will not discriminate against you for exercising any of these rights under VCDPA above.

XII. DO NOT TRACK DISCLOSURE

KUP does not respond to “Do Not Track” browser signals or other mechanisms. Third parties may collect personal information about your online activities over time and across sites when you use the Site.

XIII. DISPUTES; BINDING ARBITRATION

Any disputes related to or arising from this Privacy Policy, our obligations and/or performance under this Privacy Policy will be subject to binding arbitration as provided in our TOU. PLEASE SEE THE TOU FOR IMPORTANT INFORMATION ABOUT THIS PROCESS AND HOW IT AFFECTS YOUR RIGHTS.

XIV. CONTACTING KUP

If you have any questions, inquiries, requests, comments or complaints concerning this Privacy Policy or our information practices, please contact us at [email protected] or by physical mail at the following address: Privacy Officer, Kodansha USA Publishing, LLC, 25 East 22nd Street, New York, NY 10010.