DAMN DONKEY COMICS PRIVACY POLICY

Last updated: November 01, 2026

1. Scope and contact on information

Damn Donkey Comics Inc. (the “Company,” “Damn Donkey,” “we,” “us” or “our”) respects your privacy. This Privacy Policy explains how we collect, use, disclose, retain and otherwise process personal data in connection with our website, and our personalized comic books, figures, related products and services (collectively, the “Services”).

This Privacy Policy applies to individuals who visit or interact with our Services, create an account, place an order, communicate with us, participate in promotions, or otherwise provide information to us. It also applies to personal data concerning individuals featured in materials submitted to us, and individuals acting on behalf of our suppliers, partners or other business contacts.

For purposes of applicable data protection laws, Damn Donkey is the controller or business responsible for personal data processed under this Privacy Policy, unless we tell you otherwise or the circumstances indicate that another party determines the purposes and means of processing.

You may contact us at:

Damn Donkey Comics Inc.

169 Madison Av. STE 38346

New York, NY 10016 USA

Privacy enquiries: privacy@damndonkeycomics.com

Customer service: support@damndonkeycomics.com

Telephone: +1 240-949-6747

Our Terms and Conditions govern use of the Services and your purchases. This Privacy Policy describes our privacy practices and does not itself create a contract or require you to consent to processing for which applicable law requires separate consent. Where a conflict arises, we will apply mandatory law and any applicable contractual commitment.

2. Personal data we collect

In this Privacy Policy, “personal data” means information that identifies, relates to, describes or can reasonably be linked to an identified or identifiable individual or household, as defined by applicable law. It includes “personal information” where that term is used under applicable U.S. privacy laws. It does not include information that has been lawfully anonymized or de-identified and is maintained in that form.

Depending on how you interact with us, we may collect the following categories of personal data.

2.1. Account and contact information

This may include your name, email address, telephone number, postal address, account credentials, account preferences and other information you provide when registering, placing an order or communicating with us.

2.2. Order, payment and transaction information

This may include billing and delivery details, items purchased, order specifications, prices, payment status, transaction identifiers, payment method, discounts, returns, refunds, delivery records and order history. Payment processors may collect payment-card or other payment credentials directly. We may receive payment confirmations, limited payment details or tokens from those providers.

2.3. Customer materials and generated content

The Services allow customers to submit names, personal details, descriptions, stories, prompts, photographs, images, messages, instructions and other materials concerning themselves or other individuals, including children. We may also process previews, illustrations, text, layouts, personalized figures and other content generated or prepared using those materials.

Photographs and generated content may identify or depict individuals. Depending on their content, the technology used and applicable law, such information may constitute sensitive personal data or biometric information. A photograph is not necessarily biometric data under every applicable law.

2.4. Communications and support information

This may include inquiries, complaints, feedback, reviews, correspondence, information submitted through forms, and records of communications with our personnel or systems. Where legally permitted and disclosed or consented to as required, communications may include call or chat records.

2.5. Device usage and technical information

We may collect IP address, approximate location derived from IP address, device and browser characteristics, operating system, language, identifiers, referral information, access times, pages viewed, interactions with the Services, error reports, security logs, cookie identifiers and similar technical information.

2.6. Marketing and preference information

This may include communication preferences, marketing consents or objections, promotional code use, responses to campaigns, and information about interactions with our communications, advertisements or Services.

2.7. Business contact information

For representatives of suppliers, advisers, partners and other organizations, we may collect business contact details, professional role, correspondence and information relevant to our business relationship.

2.8. Information relating to rights, safety and compliance

Where reasonably necessary, we may collect information relating to identity verification, consent or permission to use materials, fraud prevention, complaints, disputes, suspected misuse, legal requests and compliance. We seek to limit such requests to information appropriate to the circumstances.

3. Sources of personal data

We may obtain personal data:

Directly from you when you register, place an order, submit materials, communicate with us or exercise a right.
From another customer or person who submits materials, places an order or communicates with us on your behalf or in connection with a product featuring you.
Automatically from your device or browser when you use the Services, including through cookies and similar technologies.
From service providers, such as payment processors, fraud-prevention providers, hosting providers, analytics providers, printers, fulfilment providers and carriers.
From business partners, social media services or other third-party services when you interact with us through them or direct them to share information.
From public sources, professional advisers, authorities or other third parties where lawful and relevant to a legitimate business, safety, legal or compliance purpose.
From our processing of information, including order records, service interactions and inferences reasonably derived from such information.

You are generally not legally required to provide personal data to us. However, certain information is necessary to create an account, fulfil an order, process payment, deliver a product, respond to a request or comply with law. If you do not provide it, we may be unable to provide the relevant Services or respond fully to your request.

4. How we use personal data

We may process personal data for the following purposes, to the extent appropriate and permitted by applicable law:

1. Providing the Services: operate the Platform; create and administer accounts; generate previews, illustrations and other content; personalize, produce, print, fulfil and deliver products; and provide requested features.

2. Orders and payments: process orders, payments, taxes, refunds, returns, cancellations and related financial records.

3. Communications and support: respond to inquiries and complaints; provide customer assistance; verify information; and send account, security, approval, payment, delivery and other service-related communications.

4. Quality, development and operations: maintain, troubleshoot, assess and improve the Services, customer support, security, accessibility and user experience; conduct analytics and technical diagnostics; and understand demand and performance.

5. Safety and fraud prevention: detect, investigate and prevent fraud, security incidents, prohibited content, unlawful conduct and misuse; conduct proportionate identity, payment and rights-verification checks; and protect individuals, the Company and the Services.

6. Marketing and promotions: send promotional communications, administer promotions, measure campaigns and advertise our Services, subject to applicable consent, objection and opt-out requirements.

7. Legal compliance and enforcement: comply with applicable law, legal process and regulatory obligations; maintain records; enforce our Terms and Conditions and other policies; investigate claims; and establish, exercise or defend legal rights.

8. Business administration and transactions: manage relationships with suppliers, advisers, partners and affiliates; conduct audits and financial operations; and evaluate or complete business transactions.

9. Other disclosed purposes: carry out a purpose you request or authorize, or another purpose disclosed when information is collected, where permitted by law.

We may create and use aggregated, anonymized or de-identified information for lawful business purposes. We will not treat information as anonymous or de-identified unless it satisfies applicable legal requirements.

5. Legal bases for processing

Where the EU General Data Protection Regulation (“EU GDPR”), the UK GDPR or substantially similar law applies, we rely on one or more of the following legal bases, as appropriate to the particular processing:

Contract: processing necessary to enter into or perform a contract with you, including processing orders, payments, production, delivery and support.
Legal obligation: processing necessary to comply with a legal obligation applicable to us.
Legitimate interests: processing necessary for our legitimate interests or those of a third party, except where those interests are overridden by your interests or fundamental rights and freedoms. These interests may include operating and improving the Services, preventing fraud, securing systems, communicating with business contacts, administering our business and establishing or defending legal claims.
Consent: processing based on your consent where required or otherwise appropriate, including for certain marketing, optional cookies or other processing. You may withdraw consent at any time as described below.
Other applicable bases: another lawful basis permitted by applicable law, such as protection of vital interests, where relevant.

Where processing involves special categories of personal data under the GDPR, we will identify both a lawful basis and an applicable condition for processing that data, such as explicit consent where required. We do not rely on acceptance of our Terms and Conditions or continued use of the Services as a substitute for consent where a specific form of consent is legally required.

Withdrawal of consent does not affect the lawfulness of processing before withdrawal or processing based on another applicable legal basis.

6. Photographs, AI and Personalized Content

6.1. Creation and fulfillment

We use photographs and other customer materials to create personalized content and products, including stylized or fictionalized portrayals, and to provide associated previews, production, printing, support and fulfilment services. The creation process may use generative artificial intelligence and associated design tools. Generated content is a creative interpretation and may not be an exact likeness or factual record.

Photographs and personalized content may be processed by authorized personnel and providers involved in the Services, subject to appropriate restrictions. Access is limited to legitimate operational, support, safety and legal needs.

6.2. Model training and promotional use

We will not use, or authorize our AI providers to use, identifiable customer materials or personalized generated content to train general-purpose AI models without a separate opt-in and a lawful basis. Optional training use will be explained before consent is sought and will not be a condition of purchasing a product. We may also use your Customer Materials and Generated Content to create personalised products and offers sent only to you. You can opt out at any time, and we will stop.

We will not use identifiable customer materials or personalized generated content in advertising, public examples or promotional campaigns without separate, specific authorization and any legally required consent. Placing an order, posting a review or tagging us does not by itself grant that authorization. Where we request permission to feature content, the applicable terms will be presented with the request.

6.3. Information about other people

If you submit another person’s information, photograph or story, you are responsible for obtaining the consents, releases and permissions legally required for the intended disclosure and use, including AI-assisted processing, production and sharing of the product. Where required, this includes permission from an authorized parent or guardian and any permission required from a child.

You should provide only information reasonably necessary for the intended product. Do not submit identity documents, passwords, payment credentials, precise location information or unnecessary sensitive information in customer materials. Do not submit health, sexual, religious or other specially protected information as customer materials.

If you learn that a necessary permission was not obtained, has been withdrawn or is disputed, contact us promptly. We may assess the circumstances and take appropriate action, including pausing production or restricting access. These customer obligations do not transfer our own legal responsibilities to you.

7. How We Disclose Personal Data

We may disclose personal data to the following categories of recipients, as reasonably necessary for the purposes described in this Privacy Policy and subject to applicable law:

Service providers and vendors: AI and technology providers, hosting and cloud providers, printers, manufacturers, fulfilment and delivery providers, payment processors, customer-support providers, communications providers, security and fraud-prevention providers, analytics providers, and other suppliers.
Affiliates: our subsidiaries and affiliated entities, where relevant to operations, support, security, administration or other disclosed purposes.
Professional advisers: lawyers, accountants, auditors, insurers, financial advisers and other advisers.
Business transaction participants: prospective or actual purchasers, investors, lenders, counterparties and their advisers in connection with a proposed or completed financing, investment, merger, acquisition, restructuring, insolvency, asset transfer or similar transaction.
Authorities and other parties: courts, regulators, law enforcement, government bodies, rights holders or other persons where disclosure is required by law or reasonably necessary and lawful to comply with legal process, protect rights or safety, prevent or investigate fraud or wrongdoing, enforce our agreements, or establish, exercise or defend legal claims.
Persons you direct or authorize: recipients of products, users of an available sharing feature, or other parties where you request or authorize disclosure.

We select the information disclosed according to the recipient’s role and the relevant purpose. For example, carriers receive information necessary for delivery rather than unrestricted access to product content. Where required, we use agreements or other safeguards governing recipients’ processing of personal data.

A disclosure to a service provider is not a public posting. Customer materials and personalized generated content are private by default and are not publicly displayed or made available to other customers unless you deliberately use an available sharing feature or separately authorize publication.

8. International data transfers

We and our service providers may process personal data in the United States and Israel and other countries where we or they operate. Those countries may have privacy laws different from those in your jurisdiction.

Where applicable law restricts international transfers, we will use an appropriate lawful transfer mechanism, such as an applicable adequacy decision, approved standard contractual clauses, the UK International Data Transfer Agreement or Addendum, or another legally recognized mechanism. Where required, we will assess the circumstances of the transfer and implement supplementary safeguards.

You may contact us to request information about applicable transfer safeguards or a copy of relevant safeguards, subject to lawful redactions and restrictions.

9. Retention and deletion

We retain personal data for as long as reasonably necessary for the purposes for which it was collected or otherwise processed, including providing the Services, fulfilling orders, supporting reprints and requests, maintaining appropriate business records, complying with legal, tax and accounting obligations, resolving disputes and enforcing agreements.

Retention periods depend on factors such as the nature and sensitivity of the information, the purposes of processing, the risks associated with retention, whether the purpose can be achieved by other means, applicable legal requirements and relevant limitation periods.

How long do we keep data: Photos you upload, your characters and your comics: 2 years after your last order, or 2 years after you created them if you did not order or retention is otherwise required or permitted by applicable law. We keep them so you can reorder and so we can make personalised offers for you. You can ask us in writing to delete them at any time, and you can opt out of offers in every email. Other customer materials, generated content, account information, transaction records and communications may be retained for different periods consistent with their purposes and applicable requirements. drawn comics and characters, 24 months after the last order or until opt-out; order and invoice records: 7 years for tax and accounting law. Other data is kept only for as long as needed for the purposes in this Policy.

You may request deletion as described in Section 12. A request does not necessarily require deletion of information that we must or are permitted to retain, including for legal compliance, security, fraud prevention, disputes or other applicable exceptions. Deletion of an account or digital file cannot retrieve physical products already delivered or copies independently retained by recipients.

10. Cookies and similar technologies

We and relevant providers may use cookies, pixels, tags, local storage and similar technologies to operate and secure the Services, remember preferences, understand usage, measure performance and, where applicable, support marketing.

Some technologies are strictly necessary for a requested service or essential functions. Others may support functionality, analytics or advertising. Depending on your location and applicable law, we will request consent before using non-essential technologies or provide an applicable opt-out. You may use available consent or privacy controls, browser settings or device settings to manage certain technologies. Blocking some technologies may affect functionality.

Where required by applicable law, we honor recognized opt-out preference signals, including Global Privacy Control, as applicable to the relevant browser or device and processing activity. If you use another browser or device or clear stored preferences, you may need to set your preferences again, subject to applicable law.

The EU GDPR, the UK GDPR and applicable national rules implementing the EU ePrivacy Directive, as well as comparable laws, may impose requirements concerning cookies, similar technologies and electronic communications. We apply those requirements where relevant.

11. Communications and Marketing

We may send non-marketing communications concerning your account, security, orders, approvals, payments, delivery, support or changes affecting the Services. You may not be able to opt out of communications necessary to administer an existing transaction or account.

We may send marketing communications only where permitted by applicable law and subject to any required consent. Marketing consent is not a condition of purchase. You may unsubscribe using the instructions in a message or by contacting us. Where text messaging is offered, you may reply STOP or use another legally recognized reasonable method. We will honor requests as required by law.

Opting out of marketing does not prevent necessary non-marketing communications.

12. Your privacy rights

Depending on your location and applicable law, you may have rights to:

Request confirmation of whether we process your personal data and access to it.
Request information about the categories, sources, purposes and recipients of personal data.
Request correction of inaccurate personal data.
Request deletion of personal data.
Request restriction of processing or object to certain processing, including direct marketing where applicable.
Receive certain personal data in a portable format or request its transfer where legally available.
Withdraw consent where processing is based on consent.
Opt out of certain sales, sharing, targeted advertising or profiling, as applicable.
Limit certain uses or disclosures of sensitive personal data where the law provides that right.
Appeal a decision concerning a privacy request where applicable.
Lodge a complaint with a competent supervisory or data protection authority.
Be free from unlawful discrimination for exercising privacy rights.

To exercise a right, contact us at privacy@damndonkeycomics.com. Please describe your request with sufficient detail for us to understand and respond. Where applicable, an authorized agent may submit a request on your behalf.

We may verify your identity and, where applicable, an agent’s authority using information proportionate to the request and the sensitivity of the information. We may request clarification where reasonably necessary. We will not require more information than reasonably necessary for verification or impose a fee unless permitted by law.

Rights are not absolute. We may deny, limit or defer a request where permitted or required by law, including where we cannot verify identity or authority, where a request is manifestly unfounded, excessive or repetitive under the applicable legal standard, or where compliance would adversely affect another person’s rights, interfere with legal obligations, compromise security, or affect the establishment, exercise or defense of legal claims. We will respond within the period required by applicable law and explain a refusal or extension and any available appeal process where required.

To appeal an eligible decision, reply to our response or email privacy@damndonkeycomics.com with the subject line “Privacy Request Appeal.” We will consider and respond to the appeal as required by applicable law.

If you are in the European Economic Area, the United Kingdom or Switzerland, you may also complain to the competent supervisory authority. We encourage you to contact us first, but doing so is not a condition of making a complaint to an authority.

13. U.S. State Privacy Disclosures

Depending on your state of residence and the applicability of its law, you may have the rights described in Section 12 under laws such as the California Consumer Privacy Act, as amended by the California Privacy Rights Act, and other applicable state consumer privacy laws. Applicability, rights and exceptions differ by jurisdiction.

13.1. Categories, sources and purposes

The categories of personal data we may collect include identifiers and contact information; customer and account records; commercial and transaction information; internet or other electronic network activity; approximate location information; visual information and other customer materials; communications; and inferences. Depending on what is submitted or processed and applicable law, some information may be classified as sensitive personal information.

Sections 3 and 4 describe the sources and purposes of collection. Section 7 describes the categories of recipients to whom information may be disclosed for business or legal purposes. Retention criteria are described in Section 9.

13.2. Sale, sharing and targeted advertising

We do not rent or sell personal information for money. Certain disclosures to advertising or analytics providers, including through cookies or similar technologies, may nevertheless constitute a “sale,” “sharing” or processing for “targeted advertising” under applicable state law, depending on the technology and arrangements used.

Where such processing occurs and an applicable law gives you an opt-out right, you may exercise it through any available privacy choices control on the Services, by sending a recognized opt-out preference signal where applicable, or by contacting privacy@damndonkeycomics.com. We will apply the request to the extent required by law. We do not condition ordinary privacy rights on accepting optional advertising or marketing.

13.3. Sensitive personal information

We use or disclose sensitive personal information only for disclosed purposes and as permitted by applicable law. Where a law gives you a right to limit a particular use or disclosure, you may submit a request using the methods in this Privacy Policy. We may continue processing for purposes exempt from or otherwise permitted under the applicable limitation.

13.4. Additional rights and authorized agents

California residents and other eligible individuals may have rights to know, access, correct, delete, obtain portable copies, opt out of certain processing, and avoid unlawful discrimination or retaliation. Some states also provide a right to appeal a refusal. Authorized agents may submit requests where permitted by law, subject to appropriate verification.

We will provide any additional notices, disclosures or methods of exercising rights required by applicable law.

14. Children's privacy

Our Services are intended to be used and orders managed by adults who are at least 18 years old. They are not intended for direct use by children.

An eligible adult may order a personalized product featuring or intended for a child. In that case, the adult must provide the information and obtain any legally required permissions, including permission from an authorized parent or legal guardian and any permission required from the child.

We do not knowingly collect personal data directly from a child in circumstances that require parental consent without obtaining that consent. If we learn that we have collected such data without the required consent, we will take appropriate action, which may include deletion, subject to applicable law and any legitimate need to retain limited records.

If you believe a child has provided personal data to us inappropriately, contact privacy@damndonkeycomics.com. Where applicable, we will comply with the U.S. Children’s Online Privacy Protection Act and other relevant children’s privacy laws.

15. Security

We use technical, organizational and contractual measures designed to protect personal data against unauthorized access, loss, misuse, alteration or disclosure, taking into account the nature of the information and applicable requirements.

No system, transmission or storage method is completely secure. We cannot guarantee absolute security or prevent every unauthorized act, interruption or incident. This statement does not limit any duty to implement appropriate safeguards, provide legally required notifications or accept responsibility for security failures attributable to us where liability cannot lawfully be excluded or limited.

You should protect your account credentials, use appropriate device security and notify us promptly if you suspect unauthorized access.

16. Third-party Services

The Services may contain links to, or integrations with, third-party websites, applications or services. Their operators may process information under their own privacy notices and terms. We encourage you to review those notices before providing information.

This section does not remove our responsibility for our own selection, integration or use of suppliers, or for obligations imposed on us by applicable law.

17. Automated Processing and Decisions

We may use automated tools, including AI-assisted tools, to provide the Services, generate content, conduct analytics, detect fraud, support safety checks and manage operations. Authorized personnel may also review materials where reasonably necessary for fulfilment, quality assurance, safety, complaints or legal compliance.

Where applicable law provides rights concerning a decision based solely on automated processing that produces legal or similarly significant effects, or concerning certain profiling, we will provide the information, safeguards and methods of exercising those rights required by that law.

18. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, Services, legal requirements, technology or business operations. We will post the updated version and revise the “Last updated” date. Where required by law or appropriate in light of the change, we will provide additional notice and obtain consent.

An update does not retroactively replace a legally required consent or diminish rights that cannot lawfully be waived. Your continued use of the Services is not treated as consent where applicable law requires a separate or specific form of consent.

19. Questions and complaints

For privacy questions, requests or complaints, contact:

Damn Donkey Comics Inc.

169 Madison Av. STE 38346

New York, NY 10016 USA

Email: privacy@damndonkeycomics.com

Telephone: +1 240-949-6747

We will review communications and respond as required by applicable law. You may also contact the relevant data protection authority or other competent regulator where you have the right to do so.