PRIVACY POLICY: COMICSMITH L.L.C.

ComicSmith L.L.C., and any of its affiliates (collectively "ComicSmith," "we," or "us") operates an online website, located at [ ] or at any affiliated web location, and/or web or mobile application (collectively, the "Website"), used to promote and provide information about the various services offered by ComicSmith, as further described in the Terms (the "Services").

You (a "User," "Users," "you" or "your") may obtain information from our Website in connection with our Services as further described in the Terms of Service (located elsewhere) (collectively, the "Terms").

All Users of our Website and Services must agree to this Privacy Policy (the "Policy"), and the Terms prior to use:

1. Acceptance

Please read this Policy carefully. It contains important legal rights, and constitutes a binding legal agreement between you and us. In order to use our Website and Services, we may collect personally identifiable information from you, or request that you provide us with personally identifiable information (the “Personal Information”). Even information that is not immediately personally identifiable, or that cannot be currently traced back to you directly, may later, through technologies known or unknown, enable your usage of our Website and Services to be traced back to you, your computer, or a similar device. Examples of Personal Information include your IP address or MAC Address, your name, e-mail address, place of residence, and similar (for example, but not limited to, if provided to us via a registration form or similar), and any other Personal Information which you affirmatively make available to us, such as by your usage of a contact form, e-mail, or similar means. In connection with certain features of the Services, we may also collect device identifiers, GPS location data, timestamps, and cryptographic image hashes associated with images captured through the application (collectively, “Capture Metadata”), as further described in Section 10 of this Policy.

"Anonymous Information" is information that is not reasonably identifiable to you. However, in certain circumstances, such information may be combined with other data in ways that could potentially identify individuals. Such data may include technical information regarding your anonymous usage of our website, aggregated data, an anonymous User's path through our Website or Services, and similar.

We may use the data we collect from you, whether Personal Information or Anonymous Information, in various ways as detailed throughout this Policy. We may also use third party service providers that may provide data collection services. You can learn more about this manner of data collection and advertising at http://www.aboutads.info or http://www.networkadvertising.org/choices. These links may also enable you to opt out of this manner of data collection and advertising.

We are committed to protecting your personal information as detailed in this Policy.

2. Changes to Our Policy

From time to time, we may make changes to our Policy. This Policy was last modified on April 4, 2026. Changes to our Policy may occur without notice to you, and at any time. However, material changes to this Policy, particularly those that affect how we use Personal Information or Uploaded Content, will be communicated to you via e-mail or prominent Website notice, and where required by applicable law, we will seek your renewed consent. If you do not agree with any alteration in our Policy, you must discontinue your usage of our Site and our Services. You may also request that your user account, if any, be deleted or permanently disabled, and that we remove any Personal Information, to the extent technologically possible.

3. Cookies

Cookies are one example of data that we collect from Users. Cookies may include Personal Information, or may be compiled from or along with Anonymous Information. A cookie is a piece of data stored on your computer that is tied to information about you and your usage of our Website or Services. We may use both session ID cookies (which are cookies that are specific to your usage of our Website or Services during one given browsing session), or persistent cookies (which are cookies that remain on your device beyond a single browsing session).

Session ID cookies are usually deleted when you close your browser, log out, or do a similar action on your device. Your browser’s help file may contain information on affirmatively deleting such cookies.

Persistent cookies are not deleted when you close your browser, but may be deleted manually, or may expire in time. Your browser’s help file may contain information on manually deleting such cookies.

We may also use other means of tracking your usage beyond the use of cookies, such as by using web beacons, or other forms of technology. This technology may change over time, and you may not be notified of changes in our methods of data collection.

You may also be able to prohibit our Website from placing cookies or similar web beacons on your device, and to limit our collection of your data in general, however this may limit your ability to use our Website and Services, or certain features. Your browser’s help file may contain information on disabling such access.

Cookies and similar data are used for various purposes, which include minimizing load times to our Website and Services, tracking and saving your preferences and those of other uses when you or they log in to or access our Website or Services, tracking your usage for technological or statistical purposes, tracking your usage in an attempt to improve or alter our Website or Services, or for various other purposes.

Certain third party service providers and websites with whom we may partner, such as, but not limited to, Google Analytics, may also utilize cookies or other, similar web beacons that are loaded onto your device during the navigation of our Website or use of our Services. These third party services providers may not be disclosed to you prior to your usage of our Website or Services. We may not have control over these cookies. These third party websites may use these cookies to help provide insight into which areas of our Website and Services are frequently visited by you and other Users. These cookies may also be used to provide targeted advertisement to you and other Users. You may review the applicable privacy policies of these service providers to learn more about how they may use information they collect from cookies and other similar means.

4. Storage

We may store your Personal Information for as long as you are an active User of our Services and Website, for, by example, maintaining a user account with us, and for a reasonable amount of time after. We may also continue to store Personal Information to comply with legal, financial reporting, or other compliance obligations, such as to enforce this Policy, or the Terms. In the event you wish to affirmatively ensure that your Personal Information has been deleted or removed, you may send an e-mail request to us, and we will make reasonable efforts to comply with your request, consistent with any applicable privacy laws, and other requirements as set out in this paragraph.

We do not store, nor do we have direct access to, credit card or other financial information that may be transmitted to a payment provider via our Website or Services.

Anonymous Information may be stored indefinitely, even after Personal Information is deleted.

Both Personal Information and Anonymous Information is stored using various data storage technologies, which may include but is not limited to storage using cloud storage providers such as Amazon Web Services, or other similar services. We may alter how we store data at any time, without prior notice, at our discretion. All passwords, if any, are stored using industry standard encryption. Where appropriate, we may utilize technologies such as SSL (Secure Socket Layer) to further encrypt data, such as when sensitive data such as credit card information is transferred.

5. Use of Personal Information and Anonymous Information

We may use the Personal Information collected from you in various ways. For example, this data may be used to minimize load times for various pages on our Website, for tracking and saving your preferences and those of other uses when you or they log in to or access our Website or Services, for tracking your usage for technological or statistical purposes, for tracking your usage in an attempt to improve or alter our Website or Services, to allow third parties to offer you additional services, tools, or relevant opportunities related to your usage of our Website and Services, to allow us to contact you with personalized information regarding upcoming events, products, services, or offerings relevant to your usage of our Website and Services, and to enable payment processing through a payment processor. We may also use Personal Information, including Capture Metadata and device identifiers, for fraud prevention, device fingerprinting, authenticity verification, platform integrity, and dispute resolution. Device fingerprinting may involve collecting and analyzing device-level attributes (such as your device model, operating system, and unique device identifiers) to detect fraudulent or unauthorized activity. Such analysis may occur automatically and without additional notice at the time of collection.

As noted, we may share your personal information with third parties or obtain personal information from you via third parties. One such example if the use of social media accounts that you may choose to affirmatively link with a user profile, or any Services on our website that requires or advises making such a connection.

We may also share Personal Information with other parties, without your prior consent or knowledge, when we are required to by any law, regulation, legal process, subpoena, discovery request, or governmental request; to enforce the Terms or this Policy; to resolve technical issues which may require the assistance of third parties; to prevent, resolve, or investigate suspected fraudulent activity in violation of the Terms or this Policy including through the use of Capture Metadata and device fingerprinting data; to protect the rights of ComicSmith, or any other User, or the general public; when ComicSmith undergoes a change of control, including a merger, acquisition, or the purchase of substantially all of the assets of ComicSmith, or a bankruptcy or similar legal proceeding; to enable payment processors to process payment; to third parties, such as consultants, who may help to enhance your experience or the Services we offer; to third parties, such as advertising affiliates, to let these partners and affiliates serve you with relevant advertisement at our discretion; and pursuant to your explicit approval of our disclosure of Personal Information.

ComicSmith may share Anonymous Information with any party at any time, at its sole discretion, and with no prior notice to any User.

We process Personal Information based on one or more of the following legal grounds: your consent; the necessity to perform our contract with you; our legitimate business interests; and compliance with legal obligations.

We do not sell your Personal Information as that term is commonly understood. However, we may share information with service providers and partners as described in this Policy.

6. Payment Provisions

We may accept various forms of payment through various means. These payments are processed through third party payment processors, who are responsible for, among other things, processing credit cards, debit cards, or bank accounts, and for transmitting money to our account. We may alter these payment processors at any time, at our discretion, and without your consent or prior knowledge.

We are not directly affiliated with any of these payment processors, beyond our use of them to process payments. Each is an independent contractor, and no payment providers is an agent or employee of us, or vice versa, and neither is responsible for the actions of either party, including for performance or lack of performance of any task, or the provisioning or lacking of provisioning of any service.

It is your responsibility to follow any terms, conditions, or policies specified by these payment providers. Such terms may include restrictions on age, location, type of payment method, and similar restrictions. You assume all risks of conducting any transactions via these payment processors.

7. Removal or Modification of Personal Information

You may contact us to remove or modify any Personal Information on you that we may have. Please note that the removal of such information may permanently alter your usage of your Services, and we are unlikely to be able to provide any Services to you without your Personal Information.

We will use commercially and technologically reasonable methods to remove your Personal Information. However, we may retain this Personal Information consistent with these Policies and as specified elsewhere, or if it is not commercially or technologically feasible to remove or modify this information.

To the extent legally permissible, we may not disclose all Personal Information we have collected to you, subject to commercial and technological limitations.

Depending on your jurisdiction, you may have rights to request access to your Personal Information; request deletion of your Personal Information; or request correction of inaccurate information.

You may exercise these rights by contacting us at [ ].

8. Third Party Service Providers and Websites

We may use third parties unaffiliated with us to collect, host, store, process, analyze, or distribute Personal Information and Anonymous Information. We attempt to ensure that our third party providers store and use data consistently with our own practices, however we do not control such service providers. We disclaim any responsibility arising from your use of these services where Personal Information is subsequently accessed, modified, or altered in a manner that causes harm.

In addition, we may link to third party websites. These websites may have no affiliation with us or our Services. They may not be under our control, and their content may change at any time, without our knowledge. Your access to, and usage of these websites, is subject to your acquiescence to the relevant terms of usage, or privacy policy, if any, of these websites. Your usage of these websites and these linked services as solely at your own risk and expense. We advise you to read any documents relevant to your usage of these websites. We cannot provide any advice, legal or otherwise, regarding your use of these websites.

We may use third-party service providers including cloud hosting providers, artificial intelligence and machine learning providers, payment processors, and analytics providers to process data on our behalf. We may also obtain or display data from third-party marketplaces such as completed sales data, which is subject to the terms of those third parties.

We may obtain or display data from third-party marketplaces (such as completed sales data). Such data is subject to the terms and policies of those third parties and may be limited in scope, accuracy, or availability.

9. Marketing

We may contact you regarding your use of the Services, account-related matters, and, where permitted by law, promotional communications. You may opt out of marketing communications at any time. To opt out, click the unsubscribe link in any marketing e-mail or contact us at [ ]. Opting out of marketing communications will not affect transactional or account-related communications. This contact may also be from third parties with which we have a relationship, or third parties may facilitate our contact with you. You may remove yourself from any mailing list or equivalent by contacting us, or by following the relevant unsubscribe instructions, if any, on any form of contact you receive.

10. Collection and Use of Uploaded Content

. As part of the Services, you may capture images through the application’s live camera functionality and submit related information (such as photographs of comic books) (“Uploaded Content”). Uploaded Content, as used in this Policy, corresponds to User Submitted Content as defined in the Terms of Service. Images for listing purposes must be captured live through the application’s camera. Uploading from a device’s photo library is not permitted for creating listings. We may collect, process, analyze, and store Uploaded Content, together with associated Capture Metadata (including device identifiers, timestamps, GPS coordinates, and cryptographic image hashes), in order to identify items and extract features; detect defects or condition characteristics; generate estimated values; verify the authenticity and provenance of listings; and/or to improve and train our machine learning and artificial intelligence systems. Uploaded Content may be processed using automated systems and may be retained for as long as necessary to provide and improve the Services. Uploaded Content is not made publicly available except where such display is a feature of the Services or otherwise disclosed to you, or as otherwise described in the Terms. Capture Metadata associated with listing evidence records will be retained following the date of capture for as long as reasonably necessary to support fraud prevention, dispute resolution, and legal compliance, whichever is longer. This retention period applies even after account closure. We may retain Uploaded Content for a period of time necessary to operate and improve the Services, after which it may be deleted, anonymized, or aggregated. Derived data may be retained indefinitely as further described in this Policy. You should not submit confidential or proprietary information through the Services, as such information may be processed as described in this Policy.

We collect and store data related to your participation in the Founding Member Program and Collector Program described in the Terms, including defect correction submission history, validation outcomes, accumulated points, badge status, and associated discount eligibility (collectively, “Contribution Data”). Contribution Data is retained as part of your account data for as long as your account remains active. If your account is closed or terminated, Contribution Data may be retained in anonymized or aggregated form for analytical purposes, but badge status and accumulated points will not survive account closure, as further described in the Terms.

The Services may store estimated values and related pricing data associated with your collection at the time of evaluation (“Value Snapshots”). Value Snapshots are derived from third-party data sources and are retained as part of your account data. If your account is closed, Value Snapshots may be deleted, anonymized, or retained in aggregated form at our discretion. If a third-party data source used to generate Value Snapshots becomes unavailable or is terminated, previously generated Value Snapshots will be retained as historical records but may not be updated, and ComicSmith makes no representation regarding the continued accuracy of such data.

11. Marketplace Data

When you use the marketplace feature described in the Terms, we collect, process, and store data related to your transactions, including listing details, item descriptions, photographs and associated Capture Metadata, sale price, transaction status, and communications between buyers and sellers conducted through the platform (collectively, “Marketplace Transaction Data”). We may also collect shipping information, delivery confirmation data, and payment records to the extent processed through or facilitated by the Services.

Marketplace Transaction Data is used to facilitate and complete transactions between Users; support dispute resolution, including condition mismatch claims; enforce the Terms, including prohibited listing rules; detect and prevent fraud, including through cross-referencing Capture Metadata and device fingerprinting data; and improve the Services, including marketplace functionality and trust features.

In connection with a dispute between a buyer and seller, ComicSmith may disclose relevant Marketplace Transaction Data to the counterparty, including Capture Metadata, listing photographs, item descriptions, and transaction history, to the extent ComicSmith determines in its sole discretion is reasonably necessary to resolve the dispute. By using the marketplace, you consent to such disclosure in connection with dispute resolution.

Marketplace Transaction Data is retained for as long as your account remains active and for a minimum of three (3) years following the date of the transaction, or longer where required for legal compliance, fraud prevention, or dispute resolution. If your account is closed, completed transaction records may be retained in accordance with this retention period even after closure. Communications between Users conducted through the platform may be retained separately for the same purposes.

ComicSmith does not sell Marketplace Transaction Data. We may share Marketplace Transaction Data with third-party service providers (such as payment processors and shipping providers) solely to facilitate transactions, and with law enforcement or legal authorities where required by law or legal process.

12. AI Training and Derived Data

We may use Uploaded Content and related data to train, improve, and evaluate our artificial intelligence systems. In doing so, we may generate derived data, including metadata, features, embeddings, or aggregated insights that are not reasonably identifiable to you. Such derived data may be retained and used for analytics, product improvement, and commercial purposes.

13. Security

We take reasonable measures to maintain the security of our Website and Services, which includes User Information. We generally use industry standard technologies and methodologies to achieve such security, however these technologies and methodologies may change over time at our sole discretion as technology evolves.

No transmission of information over the internet, or storage of data, can be entirely secure. We cannot guarantee that disclosure of your Personal Information and financial information will never occur. We advise the use of caution when you transmit personal information via our Website or our Services.

Under no circumstances shall we be responsible or liable for unauthorized access to our servers, Website, Services, storage systems, or any affiliated system or service, from the failure to store or secure any data, from the deletion, corruption, destruction, alteration, damage, or loss of any data or information, even if such access results in harm to you or any other User, or any third party, and even if such damage was foreseeable. Such unauthorized access may include security intrusions, “hacking,” the engineering of access to our data or private services, or any similar unauthorized means of accessing our data in any form.

14. Minors

To the extent technologically possible, we will not collect personally identifiable information from any individual under the age of 18. Our Services and Website are not intended for the use of, nor designed to attract the attention of, individuals under the age of 18. With respect to children under the age of 13, we do not knowingly collect, use, or disclose personal information without verifiable parental consent, consistent with the Children's Online Privacy Protection Act (“COPPA”). If we learn that we have collected personal information from a child under 13 without such consent, we will promptly delete it. Parents or legal guardians may contact us at [ ] to review, request deletion of, or refuse further collection of their child's personal information. The full details of our COPPA compliance practices are set forth in Section 23 of the Terms of Service.

15. Disclaimer

As noted throughout this Policy, we reserve the right to disclose your Personal Information as required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process served on our website.

We will use commercially reasonable efforts to preserve all data provided, but we are not responsible for lost or purged data. You are responsible for archiving your own data and backing it up on a regular basis, which includes any data you may have shared with us. Under no circumstances will we be responsible for the expense of lost data or consequential damages, whether foreseeable or not, due to data loss, corruption, damage, or alteration, or any form of unauthorized data access.