Personal Data Protection Policy BANG!

Preamble

Welcome to the Personal Data Protection Policy of the application “BANG! Vertical Comics”  (the “ Policy ”).

The application “BANG! Vertical Comics”  (the “ Application ”) is operated by ARCTOON SAS , a simplified joint‑stock company with share capital of €1,000, registered in the Paris Trade and Companies Register under number 930 845 367, whose registered office is located at 229 rue Saint‑Honoré, 75001 Paris (“ ARCTOON ”).

We take great care of all personal data of our Users that we collect and process when they access or use the Application. We therefore invite you to read this Policy carefully. Its purpose is to explain how Users’ personal data are processed, how they can exercise their rights, and the commitments and measures we have adopted to ensure respect for Personal Data.

This Policy has been drawn up in accordance with the applicable legislation and regulations on personal data, in particular French Act No. 78‑17 of 6 January 1978 on Information Technology, Data Files and Civil Liberties (the “Loi Informatique et  Libertés”) and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data (the “ GDPR ”).

ARCTOON, in its capacity as Data Controller, reserves the right to amend this Policy at any time in order to comply with applicable legal obligations. Any change to the personal data protection policy will be communicated to Users in order to obtain their consent to the new policy.

By browsing the Application, each User acknowledges that they have read, understood and accepted this Policy. Any related question may be sent to: support@arctoon.xyz

Article 1 – Definitions

• Subscription  means the User’s subscription.
  
• Bang! Content  means all the elements that make up the information present on the Application (text, images, videos, algorithms, software, etc.) and that enable its operation, inform the User and present the services.
  
• Personal Data  means any data that directly or indirectly identifies a User, such as last name, first name, e‑mail address or profile picture.
  
• Data Controller  means ARCTOON, which determines the purposes and means of the Processing.
  
• Processor  means any natural person or legal entity who processes Personal Data on behalf of the Data Controller.
  
• Processing  means any operation or set of operations carried out, with or without the aid of automated processes, and applied to data or sets of Personal Data, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
  
• User  means any identified or identifiable natural person.
  
• Personal Data Breach  means a breach of security leading, whether accidentally or unlawfully, to the destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transferred, stored or otherwise processed.
  

Article 2 – What Personal Data are collected?

We collect only the minimum Personal Data necessary about the User to enable the use of all the Application’s features.

When the Application is downloaded, the User may create an account by using the Apple or Google Sign Up functionality and thereby gives Apple or Google the right to share with ARCTOON the related information such as the Apple or Google identifier, a username and an e‑mail address. The User may choose to hide the e‑mail address linked to their Apple account, in which case Apple will create and use a random e‑mail address so that the personal e‑mail address remains private.

When the account is created, the User may complete their profile by adding a profile picture.

After registration, the User retains the right, via their profile, to modify the username, profile picture and personal e‑mail address (if it has been provided). It is the User’s responsibility to make the necessary updates.

ARCTOON will use the Personal Data received from Apple or Google to create the account on the Application and, if the Apple or Google identifiers are deleted, ARCTOON will no longer have up‑to‑date access to this Personal Data.

When using the Application, the User may interact with other users by leaving public comments in a specific section dedicated to Bang! Content.

Use of the Application also involves the collection of information about the User’s device (this may include the unique identifier, model, device operating system, country of connection, installation IDs, etc.) and data on use of the Application (search history, usage time, location, language, font size, etc.) for the purposes described in this Policy. Collecting this information makes it possible to link the User’s device to their usage and experience preferences on the Application. They may also be used to generate audience statistics for the Application and to offer services based on the information each User selected during previous use.

If the ARCTOON help service is contacted via the e‑mail address support@arctoon.xyz , or via the secure third‑party messaging system available in the User’s account, ARCTOON will receive the User’s e‑mail address and the information shared in order to help resolve the User’s request.

Article 3 – On what basis does ARCTOON process Personal Data?

The Processing operations implemented are essentially based on the contractual relationship between the User and ARCTOON following the User’s acceptance of the Application’s Terms of Use when creating an account for the first time. In some cases, the basis may also be ARCTOON’s legitimate interest.

By using the Application and providing Personal Data, the User therefore consents to the collection and Processing of Personal Data by ARCTOON, in its capacity as Data Controller, exclusively for the purposes detailed below.

ARCTOON collects and processes only the Personal Data strictly necessary for the purposes for which they are processed and undertakes not to process Personal Data for different purposes. Should we wish to offer a new feature or service on the Application requiring the collection and processing of Personal Data, we undertake to obtain Users’ consent once again before offering the new feature or service in question.

Article 4 – What are the purposes of the Processing?

To offer an optimal experience, we collect Users’ Personal Data only for the following Processing purposes:

• To provide the User with the services and features of the Application (legal basis: contractual necessity and ARCTOON’s legitimate interests in offering the Application’s features and account management);
  
• To contact the User with information about the Application, such as updates and new features (legal basis: contractual necessity);
  
• To enable Users to create their account, manage their Subscription, handle unsubscribe and account‑deletion requests (legal basis: contractual necessity and ARCTOON’s legitimate interests in protecting against fraud, protecting Users and protecting Bang! Content offered on the Application);
  
• To improve the User experience (legal basis: ARCTOON’s legitimate interests in improving its Users’ experience and personalizing use of the Application);
  
• To carry out research and analysis on how Users use the Application (legal basis: ARCTOON’s legitimate interests in analysing how Users access and use the Application);
  
• To test new technologies and processes to improve the Application (legal basis: ARCTOON’s legitimate interests in developing the Application, implementing security measures and improving the Application);
  
• To handle various requests, questions or complaints submitted to customer service (legal basis: ARCTOON’s legitimate interests in responding to requests, ensuring good service and resolving issues);
  
• To investigate fraud and protect our rights and content (legal basis: ARCTOON’s legitimate interests in preventing unauthorised behaviour, maintaining security, protecting Users, Bang! Content and the integrity of the Application);
  
• To produce statistics (legal basis: ARCTOON’s legitimate interests in obtaining information on Application traffic and use and in improving it).
  

Article 5 – Moderation practices

We pay great attention to the security and protection of our Bang! Content, to each User’s Personal Data and to everyone’s peaceful use. We therefore take measures to ensure each User complies with the Terms of Use when using the Application. Profile pictures, messages or comments posted in the Application are monitored and, if a message or comment meets criteria indicating a breach of the Terms of Use, we may issue a warning and may also restrict or block access to the User concerned. That User can contact ARCTOON to appeal the decision at support@arctoon.xyz , or via the secure third‑party messaging available in the User’s account.

Article 6 – How long are data kept?

We do not exceed the legal data‑retention periods and Users’ data are kept only for the time necessary to process the purposes for which they were collected.

Users’ Personal Data are retained for the entire time the User is registered on their account, plus five (5) years corresponding to legal prescription periods, and connection data are retained for a maximum of thirteen (13) months.

Information provided when contacting the help service via support@arctoon.xyz,  or via the secure third‑party messaging available in the User’s account, will be recorded and retained by ARCTOON for five (5) years after the deletion of the User’s account, including in the event of a complaint by the User regarding use of the Application.

If an account is blocked, ARCTOON may have to keep certain account information and a record of the behaviour that led to the blocking as evidence for possible legal claims, and if the blocking results from dangerous behaviour or security incidents, ARCTOON may need to retain information to prevent the creation of a new account.

Article 7 – Are the data shared?

Users’ Personal Data are not sold to third parties. The only persons authorized to use the Personal Data collected are ARCTOON employees and certain service providers who process certain Personal Data to provide certain features or services and are bound by a confidentiality obligations.

The latter have limited access to Users’ data in the context of performing these services and are contractually obliged to use them in compliance with the provisions of the applicable personal‑data‑protection regulations.

Users’ Personal Data are used to improve the user experience and enable optimization of the Application’s features and services.

In addition, Personal Data may also be transferred by ARCTOON to third parties and competent authorities to comply with legal, judicial, tax or regulatory obligations. ARCTOON guarantees Users that no transfer of Personal Data will be made to an unauthorised third party without the prior, voluntary, informed, explicit and written consent of the User.

Users are informed that some Personal Data may be processed, hosted or transferred to a country outside the European Union by one of the Data Controller’s Processors, as detailed above. These Processors undertake to comply with data‑protection laws for all such transfers and to implement adequate safeguards. The Data Controller undertakes not to process, host or transfer the Personal Data collected on its Users to a country outside the European Union or recognized as “non‑adequate” by the European Commission without first informing the data owner and obtaining their consent.

Article 8 – How do we protect the data?

ARCTOON has taken all useful, necessary, state-of-the-art precautions to protect your information in a secure environment in order to prevent any destruction, loss, alteration, disclosure or unauthorised access. Whatever efforts are made, no method of transmission or electronic storage is completely secure and we therefore cannot guarantee absolute security. If we become aware of a Personal Data Breach or security breach, we will notify the Users concerned so that they can take appropriate measures. Our incident‑notification procedures take account of our legal obligations, whether at national or European level.

If the integrity and confidentiality of your data are compromised, we undertake to comply with the procedures established under the applicable legislation and regulations.

Article 9 – What are the Users’ rights?

Under the applicable legislative and regulatory provisions, Users of the Application have the following rights:

• Right to information, access, rectification and erasure : the User may view, update, modify or request the deletion of data related to them;
  
• Right to portability : the User has the right to request the portability of their Personal Data, held by ARCTOON, to another site, by requesting the portability of their Personal Data from ARCTOON;
  
• Right to restriction and objection to Processing : the User has the right to request restriction of, or to object to, the Processing of their Personal Data by ARCTOON, which may not refuse except to demonstrate compelling legitimate grounds overriding the interests, rights and freedoms of the User;
  
• Right not to be subject to a decision based solely on automated Processing : in accordance with the GDPR, the User has the right not to be subject to a decision based solely on automated Processing where the decision produces legal effects related to them or similarly significantly affects them;
  
• Right to determine the fate of the data : the User may decide what is to happen to the data collected and processed if they die.
  

To exercise any of these rights, the User simply needs to write to support@arctoon.xyz

Requests will be processed within one (1) month, unless there is an overriding reason put forward and justified by the Data Controller that warrants an extension of the period.

If the Data Controller does not satisfy the User’s request, the User is entitled to lodge a complaint with the CNIL (Commission Nationale de l’Informatique et des Libertés,   https://www.cnil.fr ) in order to assert their rights.

Article 10 – How to contact us?

The ARCTOON support service can be contacted by e‑mail at support@arctoon.xyz for any questions, concerns, if a User wishes to exercise their rights, in the event of a problem or to make a complaint.

Effective date: 1 July 2025