Privacy Policy

1. Introduction

This privacy policy outlines the data collection, usage, and sharing practices of Winter Comics, Inc. (“Winter Comics”) when you visit wintercomics.com (the “Site”) or interact with our services, applications, or platform via the Site or affiliated channels (collectively referred to as the “Services”). Winter Comics is a creative platform designed to generate custom characters and visuals based on user-provided prompts, fueling creativity and storytelling.

Applicability

This Policy governs personal data collected by Winter Comics through: (i) our Services, (ii) processes involved in refining and training our character and image generation models, (iii) interactions on the Winter Comics website, and (iv) third-party sources, such as public records, commercial data vendors, and publicly available information.

Exclusions

This Policy does not apply to information related to Winter Comics employees, job applicants, or contractors performing similar functions.

Changes

We may update this Policy from time-to-time to reflect changes in legal, regulatory, operational requirements, our practices, and other factors. Please check this Policy periodically for updates. If any of the changes are unacceptable to you, you should cease interacting with us. When required under applicable law, we will notify you of any changes to this Policy.

Definitions

Throughout this Policy, “you” or “your” refers to the individual accessing or using our Services, or the organization or legal entity on whose behalf the Services are utilized. The term “Company” (also referred to as "we," "us," or "our") refers to Winter Comics, Inc. “Usage Data” pertains to information collected automatically, such as site usage metrics, interaction times, or engagement with generated content.

2. Collecting and Using Your Personal Data

2.1 Types of Data Collected

While interacting with the Services, you may provide certain personally identifiable information that could be used to contact or identify you. Personally identifiable information may include, but is not limited to:

  • Your username for the Services
  • Text or image prompts and other content such as photos, videos, documents, and messages that you input into the Services
  • Your IP address
  • Usage Data
  • Tracking Technologies and Cookies
  • Contact Information
  • Organizational Information like your company title
  • Your Email
  • Cookies
  • Other data that you elect to send to Winter Comics, such as your survey responses or information you include in communications to us

2.2 Use of Your Personal Data

Winter Comics may use your Personal Data for the following purposes:

  • To provide, maintain, and enhance our Service, including monitoring how you use our platform.
  • To manage your account: to facilitate your registration as a user of the Service. The Personal Data you provide allows you to access various features of the Service available to registered users.
  • For the performance of a contract: to process and fulfill the purchase agreements for the products, services, or items you have bought, or any other agreement with us through the Service.
  • To contact you: by email, phone, SMS, or other forms of electronic communication, such as push notifications in the mobile app, to provide updates, security notices, or other relevant communications related to our Service, products, or services.
  • To send you news, special offers, and general information about other products, services, or events offered by Winter Comics that are similar to those you have already shown interest in, unless you have opted out of receiving such updates.
  • To manage your requests: to handle and respond to any inquiries or requests you make to Winter Comics.
  • For business transfers: we may use your data to evaluate or carry out mergers, acquisitions, restructuring, or other transactions involving our business, where your Personal Data may be part of the assets transferred.
  • For other purposes: we may also use your data for purposes such as analyzing trends, assessing the effectiveness of our promotional activities, and improving our services, products, and overall user experience.

2.3 Sharing of Your Personal Data

We may share your personal information in the following situations:

  • With Service Providers, Third Party Vendors, Consultants, and Business Partners: We may share your personal information with these parties to provide services on our behalf, analyze the usage of our services, contact you, and for reasons outlined in our agreement. Service Providers may also help monitor and analyze the usage of our Service or reach out to you.
  • For business transfers: We may share or transfer your personal information in connection with, or during the negotiation of, any merger, acquisition, sale of company assets, or financing to another company.
  • With your consent: We may disclose your personal information for any other purpose with your explicit consent.
  • With Law Enforcement: Under certain circumstances, Winter Comics may be required to disclose your personal data if required by law or in response to valid requests from public authorities (e.g. a court or government agency). If such a request is made, we will promptly notify you and provide a copy of the request, unless legally prohibited.
  • With other parties in order to:

2.4 Retention of Your Personal Data

  • Winter Comics will retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy. We will retain and use your personal data as necessary to comply with legal obligations (such as retaining data to comply with applicable laws), resolve disputes, and enforce our agreements and policies.
  • We will also retain Usage Data for internal analysis purposes. Usage Data is generally kept for a shorter period unless it is used to strengthen security or improve functionality, or if we are legally required to retain it for longer periods.

2.5 Transfer of Your Personal Data

Your information, including personal data, is processed at Winter Comics’ operating offices and in any other locations where the parties involved in processing are situated. This means your data may be transferred to and stored on computers located outside your state, country, or jurisdiction, where data protection laws may differ from those in your jurisdiction.

  • By consenting to this Privacy Policy and submitting your information, you agree to the transfer of your data.
  • Winter Comics will take all reasonable steps to ensure that your data is securely processed in accordance with this Privacy Policy. No transfer of your personal data will occur to an organization or country unless there are adequate controls in place to protect your data and personal information.

2.6 Security of Your Personal Data

The security of your personal data is important to Winter Comics, but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.

3. Age Restrictions

Our Service is intended for users aged 18 and older. We do not knowingly collect personally identifiable information from anyone under the age of 18.

Parental Consent

If we ever need to process personal data for users under the age of 18, we will seek explicit parental consent in accordance with applicable laws.

4. External Links

Our Service may contain links to external websites that are not controlled or operated by Winter Comics. If you click on a third-party link, you will be directed to that site. We strongly recommend that you review the privacy policy of every site you visit.

We are not responsible for the privacy practices or the content of any third-party websites, including services like Discord, that you may interact with through links on our platform. These external sites have their own privacy policies, and we cannot control or be held liable for how they handle your personal data.

5. Changes to this Privacy Policy

We may update this Privacy Policy periodically. Any changes will be communicated to you by posting the updated Privacy Policy on this page.

Before the changes take effect, we will notify you through email or a prominent notice on our Service. Additionally, we will update the "Last updated" date at the top of this Privacy Policy.

We encourage you to review this Privacy Policy regularly for any updates. Changes are effective when posted on this page.

© 2025 Winter Comics. All rights reserved.

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