Privacy policy

1. General provisions

1.1. This Privacy Policy (the Policy) sets out how personal data of users of the MANGAEZ platform at https://manga.valsky.org/ (the Platform) is collected, used, stored, protected and otherwise processed.

1.2. The Policy is drawn up under the laws of Ukraine, in particular the Law of Ukraine “On Personal Data Protection”.

1.3. The controller of personal data is the Mangaez platform administration, which determines the purpose and procedure of processing the personal data of Platform users in accordance with the laws of Ukraine (the Administration).

1.4. The Policy applies to personal data the Administration receives when users visit the Platform, create an account, use its features, post content, contact the Administration and, once the relevant features are launched, take out a paid subscription.

1.5. Users should read the Policy before providing personal data. Where the law requires the user's consent for a particular kind of processing, that consent is obtained separately or in another lawful way.

1.6. A user who does not agree with the Policy should refrain from providing personal data that requires their consent and from using the corresponding Platform features.

2. What personal data may be processed

2.1. Account data. When an account is created and used, the Administration may process:

• login and/or nickname;
• email address;
• password as a cryptographic hash, never in plain text;
• gender, if the user chooses to state it in their profile;
• profile description;
• age;
• profile avatar and banner;
• details of linking the account to Google and/or Telegram, if the user connected that service.

2.2. Platform usage data. To run Platform features the Administration may process:

• the user's bookmarks;
• reading history and progress;
• ratings and reviews;
• forum posts and comments;
• account settings;
• level, experience and other activity indicators, where the Platform provides them;
• records of rule violations, restrictions applied and appeals against the Administration's decisions.

2.3. Technical data. When the Platform is visited and used, the following may be recorded automatically:

• IP address;
• browser type and technical characteristics available to the server;
• date and time of requests to the server;
• Platform pages the user requested;
• other technical details that end up in server logs during operation.

2.4. Payment data. When paid features are used, the Platform may process the plan, subscription status, payment amount and date, transaction status and other data needed to account for payments and provide paid features.

If payments are handled by a third-party payment provider, card details and other payment data may be passed directly to that provider and processed under its own documents and rules.

2.5. Third-party service data. If a user links the account to Google and/or Telegram, the Platform may receive and process the data that service transmits within the sign-in or linking method the user chose.

2.6. Public data. Nickname, profile description, avatar, banner, ratings, reviews, forum posts and comments may be visible to other users if placed in the open part of the Platform.

The password hash, IP addresses and internal records of violations, restrictions and appeals are not intended for public display.

2.7. Users decide for themselves what to put in their open profile or public content and should keep in mind that third parties may view, copy and further share it.

3. Purposes and legal grounds for processing

3.1. The Administration processes personal data in order to:

• create, identify and maintain accounts;
• provide access to Platform features;
• store bookmarks, reading history and progress, ratings, settings and other user data;
• ensure the operation, stability and information security of the Platform;
• record user activity within Platform features;
• handle complaints, requests and appeals;
• detect, review and record violations of Platform rules;
• prevent fraud, abuse and unauthorised access;
• communicate with users;
• send marketing materials;
• comply with obligations under the laws of Ukraine;
• protect the rights and legitimate interests of the Administration, users and third parties to the extent permitted by law.

3.2. The legal grounds for processing are the data subject's consent, the need to conclude or perform a contract with the user, compliance with legal obligations and other grounds established by the laws of Ukraine.

3.3. Personal data is processed for the stated purpose, to the extent necessary and for as long as needed to achieve that purpose or meet legal requirements.

4. Retention periods

4.1. Personal data is kept for as long as needed for the purposes of processing, unless the laws of Ukraine set another period.

4.2. Account data may be kept while the account exists and for the time needed to complete its deletion, meet legal obligations or protect rights and legitimate interests to the extent permitted by law.

4.3. Raw server logs containing IP addresses are kept for up to 14 calendar days. After that they are deleted or turned into aggregated data without IP addresses.

4.4. Records of rule violations, restrictions and appeals may be kept for as long as needed to enforce Platform rules, handle repeat violations and protect rights and legitimate interests to the extent permitted by law.

4.5. Once the purpose is achieved or the retention period ends, personal data is deleted or anonymised unless there is a proper legal basis for keeping it.

5. Protection of personal data

5.1. The Administration takes organisational and technical measures to protect personal data against accidental loss, unlawful destruction, alteration, unauthorised access, disclosure and other unlawful processing.

5.2. These measures may include restricting access to personal data, account protection, secure communication channels, backups, software updates and access control to administrative functions.

5.3. The Administration ensures the confidentiality of personal data and that only authorised persons access it, to the extent needed for their duties.

5.4. If a security incident is detected, the Administration acts to contain it and remedy its consequences and meets any legal requirements to notify the relevant persons or authorities.

6. User rights

6.1. Users have the rights regarding their personal data provided by the laws of Ukraine, in particular the right to:

• know the sources of collection and location of their personal data, the purpose of processing and the location of the controller;
• receive information on the conditions of access to personal data;
• access their personal data in the manner prescribed by law;
• demand correction of inaccurate or outdated personal data;
• demand deletion or destruction of personal data in cases provided by law;
• object to processing in cases established by law;
• withdraw consent where processing is based on consent;
• complain to the Ukrainian Parliament Commissioner for Human Rights or to a court;
• exercise other rights provided by the laws of Ukraine.

6.2. Users may opt out of marketing emails at any time using the subscription management link in the emails and/or their email service. If that is not possible, write to the email given in this section.

6.3. To exercise their rights, users may contact the Administration at [email protected].

6.4. Requests are handled within the time limits and in the manner set by the laws of Ukraine.

6.5. Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal and does not rule out further processing on another lawful ground.

7. Cookies

7.1. The Platform uses cookies necessary for it to work properly: keeping the user signed in, storing the session state and settings, and security. Disabling necessary cookies may make the Platform or some of its features work incorrectly or become unavailable.

7.2. With the user's separate consent, the Platform may use analytics cookies to collect statistics on how the Platform is used — page visits, interaction with features and performance indicators. This data is used to analyse and improve the Platform's features, usability and performance.

7.3. Analytics cookies are used only after the user consents. The user may refuse them or withdraw consent through the available cookie settings.

7.4. Users can also manage cookies in their browser settings. Blocking necessary cookies may affect the availability and correct operation of the Platform.

7.5. How long cookies are kept depends on their purpose and settings. Session cookies are deleted when the browser session ends; persistent cookies are kept for their set period or until the user deletes them.

8. Changes to the Policy

8.1. The Administration may amend this Policy following changes in law, Platform features or the way personal data is processed.

8.2. The current version is published at https://manga.valsky.org/legal/privacy. The effective date is shown at the top of the document.

8.3. If changes significantly affect the processing of personal data or user rights, the Administration takes steps to inform users properly and, where necessary, obtains consent to further processing in accordance with the laws of Ukraine.

9. Contact information

9.1. For questions about the processing and protection of personal data, users may contact the controller — the Administration.

Email: [email protected]