InkyPen Privacy Policy

This privacy policy (the “Privacy Policy”) explains the collection, use, and sharing of information from or about you in connection with your use of our Service. The term “Service” refers to subscription-based service we offer, which allows users to access, download and view a wide selection of comic books, graphic novels, manga and comic strips (collectively, “Content”) through a software client (the “Client”) available to download on the Nintendo Switch™.

The company that provides the Service is InkyPen AS, a private limited company (Aksjeselskap) incorporated under the laws of Norway, having its registered office at Sandviksboder 13, 5035 Bergen, Norway and registered at the Norwegian Register of Business Enterprises under number 919503661 (“InkyPen”).

InkyPen is a data controller of personal information collected and processed through the Service as described in this Privacy Policy.

1 Personal Information We Collect:

InkyPen may collect the following information from or about you:

1.1 Information You Provide To Us:

We receive and store information you provide in relation to our Service. For example:

- When you purchase a subscription and create an account with us, you enter information about yourself such as username, email address, birthdate, and payment method information.

- When you contact us for customer support or other reasons, or configure your settings for the Service on your Account.

1.2 Automatic Information:

Your use of our Service generates information that InkyPen receives and collects automatically. For example:

- Hardware, Software and Network Data: We collect information about the type and version of the Nintendo Switch™ device you use to access our Service, your IP address, unique device identifiers, the location of your Nintendo Switch™ device, your network and connection information, Client usage, connectivity data, and errors or event failures.

- Content Selection and Interaction: We collect information about the Content you view, browse and download for offline access.

2 Purposes For Processing Your Personal Information:

2.1 We process your personal information to operate, provide, and improve the Service. These purposes include:

- Providing the Service to you.

- Processing your subscription payments.

- Communicating with you, including for promotional purposes;

- Recommending content that we think might interest you and to personalise your experience with the Service.

- Detecting and mitigating fraud or abuse in order to protect the security of our customers, the Service, InkyPen, and others.

- Providing functionality, analysing performance, fixing errors, and improving usability and effectiveness of the Service.

- Compiling aggregate data for internal and external business purposes.

- Complying with our legal obligations, such as complying with geographic restrictions on the distribution of Content, paying taxes, and displaying appropriate Content, policies and notices.

- Protecting your and our rights.

- Other uses in accordance with our Terms of Use.

- Any other purpose for which we seek your consent. When you consent to our processing your personal information for a specified purpose, you may withdraw your consent at any time and we will stop processing your information for that purpose.

2.2 Use of Payment Information:
We use payment information, such as bank account and credit card numbers, to provide the Service. For example, we use payment information to process payments from a subscriber (we use a third-party payment processor to do this), to retrieve account information for a subscriber, to determine whether a subscriber is eligible for promotions, and to detect fraud or abuse.

2.3 Use of Location Data:
In order to access the Service, you may be required to share your device’s location data with us in order for us to comply with geographic restrictions on the distribution of Content.

2.4 Use of Aggregate and Anonymised Information:
In addition to the individual data use described in this Privacy Policy, we may aggregate information about you and other individuals together and anonymise the information about you (which means that the information does not identify you personally). We will use information in these forms for our legitimate business purposes, including for research and analysis, calculating payment of our Content licensors, optimisation of the Service, and promotional purposes.

3 Your Rights and Choices

Subject to applicable law, you have the right to access the personal information we maintain about you, to request that your personal information be corrected, updated, or deleted, and to ask for data portability. Examples of information you can access through InkyPen include browsing history and personally identifiable information (including account name and email). You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information; if we have collected and process your personal information with your consent, then you can withdraw your consent at any time; withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent; you have the right to complain to a data protection authority about our collection and use of your personal information. When you consent to our processing of your personal information for a specified purpose, you may withdraw your consent at any time and we will stop any further processing of your information for that purpose. If you decide you no longer want us to process your personal information, you should uninstall the Client, and, if you have an account, at your request we will delete your account and make your user profile anonymous in the database. You will no longer be able to use our Service if you do this. You may exercise the rights mentioned in this section by contacting us at the following address: Sandviksboder 13, 5035 Bergen, Norway
or by emailing us at:

4 Sharing Personal Information with Third Parties

4.1 We may share information collected from or about you with third parties as described below:

- We may transfer personal information to our corporate affiliates.

- We may transfer personal information to third parties we have retained to perform services on our behalf, such as Content hosting and delivery, data analytics, marketing and advertising, and payment services. Such service providers may not use or disclose personal information except as necessary to perform services on our behalf or to comply with legal requirements.

- We may transfer personal information in aggregated or anonymised forms with our business partners, including publishers who provide Content for our Service in order to measure Content popularity, business metrics and calculating payments.

- In connection with a business transaction involving transfer of our Company or a business of ours, information relating to customers typically would be included in the assets transferred.

- We may transfer personal information with your consent.

- We may share personal information: (a) as required by any law to which we are subject; (b) in response to a valid legal request; (c) to protect our rights under our contracts, terms of service, or end user license agreements, or to otherwise protect our rights or the rights of others, including the owners of intellectual property in Content; (d) to assess or mitigate credit risk; or (e) to conduct any investigation relating to the foregoing.

4.2 Whenever in the course of sharing information we transfer personal information to countries outside of the European Economic Area and other regions with comprehensive data protection laws, we will ensure that the information is transferred in accordance with this Privacy Policy and as permitted by the applicable laws on data protection.

5 Data Retention

We retain personal information for as long as necessary to provide our Service, to fulfill any other purposes for which the information was initially collected, as may be required by law (such as for tax or accounting purposes), or as otherwise communicated to you. We take reasonable measures to destroy or anonymise personal information in a secure manner when it is no longer required.

6 Security

We use reasonable administrative, logical, physical and managerial measures to safeguard your personal information against loss, theft and unauthorised access, use and modification. These measures are designed to provide a level of security appropriate to the risks of processing your personal information. We will never ask you for your password in any unsolicited communication (including by telephone or e-mail) but we may occasionally request proof of identity. If you believe your username or password has been compromised, please contact us at You should understand that no system of data security is invulnerable. You should protect against unauthorised access to your password and to your computers, devices, and applications.

7 Links to Other Websites and Services

We may provide links to various third party websites and services. Those sites and services are not under our control. Those sites and services may have their own privacy policies or notices, which we strongly suggest you review if you visit them or use them. We are not responsible for those third party privacy policies or notices, the related data processing practices, or any other aspects of those sites and services.

8 Children

You must be 18 years of age or older to subscribe to the Service, and while individuals under the age of 18 may use the Service, they may do so only with the involvement, supervision, and approval of a parent or legal guardian.

9 Changes to This Privacy Policy

We will update this Privacy Policy from time to time in response to changing legal, regulatory or operational requirements. We will provide notice of any such changes (including when they will take effect) in accordance with applicable law. Your continued use of the Service after any such updates take effect will constitute acknowledgement and (as applicable) acceptance of those changes. If you do not wish to acknowledge or accept any updates to this Privacy Policy, you may cancel your use of the Service. To see when this Privacy Policy was last updated, please see below.