ANDiDREW Privacy Policy

This Privacy Policy was last updated on February, 12 2024.

Thank you for visiting ANDiDREW. We at ANDiDREW (“ANDiDREW ”, “we”, “us”) respect Your privacy and want You to understand how we collect, use, and share data about You. This Privacy Policy covers our data collection practices and describes Your rights regarding Your Personal Data.

This Privacy Policy applies to all Your activities on the ANDiDREW website, our APIs, our website domains, and other related Services. It also applies to all individuals that visit our websites, including the following website domains:  https://andidrew.com/, https://andidrew.com/book/, https://www.torahcomics.com/, and any other software platform used to provide Services.[Sc1] 

Consent

By using the Services and/or providing us with Your Personal Data, You hereby consent to our Privacy Policy and agree to its terms.

Defined Terms

Below are terms we use throughout this Privacy Policy that You should know:

• “Personal Data” refers to the data we collect from You that You provide to us or that we collect automatically, including: Account Data, Profile Data, Shared Collaborations, Learning Data, Payment Data, Communications and Support Data, System Data, Usage data, and Approximate Geographic Location.
• “Services” (as defined in ANDiDREW’s Terms of Service)[Sc2]  refers to the ANDiDREW website, our APIs, our website domains, and other related services.
• “Third Party” refers to ANDiDREW affiliates, our business partners, analytics and data enrichment providers, Your social media providers, and Payment Processors.
• “You” and/or “Your” refers to users of ANDiDREW’s Services and anyone who visits an ANDiDREW website.

Table of Contents

1. What Data We Collect
2. What We Use Your Data For
3. How We Share Your Personal Data
4. Cookies and Other Tracking Technolgies
5. Security
6. Your Rights
7. Jurisdiction-Specific Rules
8. Modification
9. Miscellaneous

1. What Data We Collect

We collect certain data from You directly that can be used to individually identify a person (“Personal Data”). Personal Data collected includes information You enter Yourself, data about Your consumption of the Content (as defined in the ANDiDREW Terms of Service), and data from Third Parties You connect with ANDiDREW. Some Personal Data is automatically collected when You use our Services, described below in Section 1.2.

All Personal Data listed in this section is subject to Processing Activities, which generally covers actions that can be performed in connection with Personal Data such as collection, use, storage, and disclosure.

1.1 Data You Provide to Us

We may collect different Personal Data from or about You depending on how You use the Services. Below are some examples to help You better understand the data we collect.

When You create an account and use the Services, we collect any data You provide to us directly, including through a Third Party, (defined above). Third Parties data collection may include collection through analytic tools like Google Analytics and the use of Amazon to purchase books. We may also share Your data as needed for security, legal compliance, or as part of a corporate restructuring. Lastly, we can share data in other ways if it is aggregated or de-identified or if we get Your consent.

The Personal Data we collect includes:

• Account Data: In order to use certain features (like accessing Content), You need to create a user account, which requires us to collect and store Personal Data directly from when You provide us with such Personal Data, including: first and last name, email address, and billing zip code and/or country of residence. We also collect and store Your account password and account settings. 
• Profile Data: You can also choose to provide profile information like a photo. Your Profile Data will be publicly viewable by others in the Torah Comics Community (https://www.torahcomics.com/community/public).
• Shared Collaborations: Parts of the Services let You interact with other users or share information/collaborate publicly, including posting reviews about Content, asking or answering questions, or posting photos. Such shared information/collaborations posted in the Torah Comics Community may be publicly viewable by others depending on where it is posted.
• Learning Data: When You access Content, we collect certain data including which drawing classes You’ve started and completed; content purchased; books and materials purchased; and content accessed.
• Payment Data: In order to collect and receive payments, the Company uses a Third Party Payment Processor (as defined in ANDiDREW’s Terms of Service) to collect payment information from customers. This information is used solely to collect and provide payments related to the Services, and is only stored by the Third Party Payment Processor. If You have any questions about our Payment Processor, You can contact us at art@andidrew.com.
• Communications and Support Data: If You contact us for support or to report a problem or concern (regardless of whether You have created an account), we collect and store Your Personal Data. We use this data to respond to You and research Your question or concern, in accordance with this Privacy Policy.

The data listed above is stored by us and associated with Your account.

1.2 Data We Collect Automatically

When You access the Services (including browsing content), we collect certain data automatically, including:

• System Data: Technical data about Your computer or device, like Your IP address, device type, operating system type and version, unique device identifiers, browser, browser language, domain and other systems data, and platform types.
• Usage Data: Usage statistics about Your interactions with the Services, including content accessed, time spent on pages or the Service, pages visited, features used, click data, date and time, referrer, and other data regarding Your use of the Services.
• Approximate Geographic Data: An approximate geographic location, including information like country, city, and geographic coordinates, calculated based on Your IP address. You can adjust Your settings at the device or browser level to disable the use of these geographic data collection technologies. 

The data listed above is collected through the use of server log files and tracking technologies, as detailed in the “Cookies” section below. It is stored by us and associated with Your account.

• What We Use Your Data For

We process Personal Data to operate, improve, understand and personalize our Services. For example, we use Personal Data to:

• Communicate with You about the Services, including to provide updates, sending You order confirmations and digital receipts, or communicate You about Your account or use of our Services;
• Protect against or deter fraudulent, illegal or harmful actions;
• Contact You about Service announcements, updates or offers;
• Personalize website content and communications based on Your preferences;
• Provide support and assistance for the Services;
• To identify trends and other statistical information that may be useful to our business;
• Comply with our legal, compliance, security-related, and contractual obligations,
• Resolve disputes; and
• Enforce our Terms of Service (including, for clarity, the Privacy Policy and, where applicable, the EU Data Processing Addendum).

• How We Share Your Personal Data

We share certain data about You with Third Party companies performing services for us, ANDiDREW affiliates, our business partners, analytics and data enrichment providers, Your social media providers, and advertising companies who help us promote our Services. We may also share Your data as needed for security, legal compliance, or as part of a corporate restructuring. Lastly, we can share data in other ways if it is aggregated or de-identified or if we get Your consent.

We may share Your data with Third Parties under the following circumstances or as otherwise described in this Privacy Policy:

• With Service Providers, Contractors, and Agents: We share Your data with Third Party companies who perform services on our behalf, like payment processing, fraud and abuse prevention, data analysis, marketing and advertising services (including retargeted advertising), email and hosting services, and customer services and support. These service providers may access Your personal data and are required to use it solely as we direct, to provide our requested service.
• With ANDiDREW  Affiliates: We may share Your data within our corporate family of companies that are related by common ownership or control to enable or support us in providing the Services.
• With Business Partners: We have agreements with other websites and platforms to distribute our Services and drive traffic to ANDiDREW. Depending on Your location, we may share Your data with these trusted partners.
• With Analytics and Data Enrichment Services: As part of our use of Third Party analytics tools, we share certain contact information or de-identified data. De-identified data means data where we’ve removed things like Your name and email address and replaced it with a token ID. This allows these providers to provide analytics services or match Your data with publicly-available database information (including contact and social information from other sources). We do this to communicate with You in a more effective and customized manner.
• For Security and Legal Compliance: We may disclose Your data (all data categories) to Third Parties if we (in our sole discretion) have a good faith belief that the disclosure is:
• Requested as part of a judicial, governmental, or legal inquiry, order, or proceeding;
• Reasonably necessary as part of a valid subpoena, warrant, or other legally-valid request;
• Reasonably necessary to enforce our Terms of Use, Privacy Policy, and other legal agreements;
• Required to detect, prevent, or address fraud, abuse, misuse, potential violations of law (or rule or regulation), or security or technical issues;
• Reasonably necessary in our discretion to protect against imminent harm to the rights, property, or safety of ANDiDREW , our users, employees, members of the public, or our Services;
• We may also disclose data about You to our auditors and legal advisors in order to assess our disclosure obligations and rights under this Privacy Policy; or
• Required or permitted by law.
• During a Change in Control: If ANDiDREW undergoes a business transaction like a merger, acquisition, corporate divestiture, or dissolution (including bankruptcy), or a sale of all or some of its assets, we may share, disclose, or transfer all of Your data to the successor organization during such transition or in contemplation of a transition (including during due diligence).
• After Aggregation/De-identification: We may disclose or use aggregated or de-identified data for any purpose.
• With Your Permission: With Your consent, we may share data with Third Parties outside the scope of this Privacy Policy.

• Cookies and Other Tracking Technologies

ANDiDREW uses cookies and/or device identifiers from Third Parties to track who visits our website and then retarget those users or similar audiences with advertisements online. Third Parties show these ads online.

A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. ANDiDREW uses cookies to help it identify and track visitors, their usage of its website, and their website access preferences. We may gather information about Your general internet use by using the cookie.  Such information will not identify You personally. It is statistical data. Visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using ANDiDREW websites. If a user rejects the cookie, they may still use our website, but the user will experience limited functionality in some areas of our website.

There are other tracking technologies, such as web beacons/GIFs, pixels, page tags, embedded scripts, that consist of small transparent image files or other web programming code that record how You interact with websites, mobile applications and services.  They are often used in conjunction with web browser cookies or other identifiers associated with Your device. 

Some Cookies are placed by a Third Party on Your device and may provide information to us and Third Parties about Your browsing habits (such as Your visits to one of our website domains or while accessing our Services, the pages You have visited and the links and advertisements You have clicked). These Cookies can be used to determine whether certain Third Party services are being used, to identify Your interests, to retarget advertisements to You and to serve advertisements to You that we or others believe are relevant to You. We do not control third party Cookies.

As part of using the Services, we use these technologies as well as similar technologies within our Services and across our Websites. Examples include:  

• to provide our Services;
• to uniquely identify You and/or Your device; 
• to store Your preferences as part of providing the Services; 
• for personalization and targeted advertising purposes (including across Your devices and applications); 
• for security and fraud-prevention purposes; 
• to analyze and monitor the performance of our Services;  
• to improve and develop new Services; and 
• to understand Your use of the Services over time. 

You can decide whether or not to accept Cookies. One way You can do this is through Your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent Your browser from accepting new Cookies, as well as (depending on the sophistication of Your browser software) allow You to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on Your computer.

To explore what Cookie settings are available to You, look in the “preferences” or “options” section of Your browser’s menu. To find our more information about Cookies, including information about how to manage and delete Cookies, please visit https://ico.org.uk/for-the-public/online/cookies/ or https://www.allaboutcookies.org/.

Please be aware that depending on the Services being used, restricting Cookies may prevent You from accessing all or part of our Services.

• Security

We use appropriate security based on the type and sensitivity of data being stored. We take precautions to protect Your information. In order to prevent unauthorized access or disclosure, we have put in place suitable procedures to safeguard and secure the information we collect online.  As with any internet-enabled system, there is always a risk of unauthorized access, so it’s important to protect Your password and to contact us if You suspect any unauthorized access to Your account.

The ANDiDREW domain pages contain links to other websites. Please be aware that we are not responsible for the content or privacy practices of such other websites.

• Your Rights

You have certain rights around the use of Your data, including the ability to opt out of promotional emails, cookies, and collection of Your data by certain Third Parties. You can update or terminate Your account from within our Services, and can also contact us for individual rights requests about Your personal data.

6.1 Your Choices About the Use of Your Data

You can choose not to provide certain data to us, but You may not be able to use certain features of the Services.

• To stop receiving promotional communications from us, You can opt out by using the unsubscribe mechanism in the promotional communication You receive or by changing the email preferences in Your account. Note that regardless of Your email preference settings, we will send You transactional and relationship messages regarding the Services, including administrative confirmations, order confirmations, important updates about the Services, and notices about our policies.
• If You’re located in the European Economic Area, You may opt out of certain Data Collection Tools by clicking the “Cookie settings“ link at the bottom of any page. See Section 7.4 for more information about Your rights as a user in the European Economic Area.
• The browser or device You use may allow You to control cookies and other types of local data storage. To learn more about managing cookies, visit https://cookiepedia.co.uk/how-to-manage-cookies. Your wireless device may also allow You to control whether location or other data is collected and shared.
• To get information and control cookies used for tailored advertising from participating companies, see the consumer opt-out pages for the Network Advertising Initiative and Digital Advertising Alliance, or if You’re located in the European Economic Area, visit the Your Online Choices site. If You’re located in Japan, visit the Digital Advertising Consortium. To opt out of Google’s display advertising or customize Google Display Network ads, visit the Google Ads Settings page. To opt out of Taboola’s targeted ads, see the Opt-out Link in their Cookie Policy.
• Apple iOS, Android OS, and Microsoft Windows each provide their own instructions on how to control in-app tailored advertising. For other devices and operating systems, You should review Your privacy settings on that platform.

If You have any questions about Your data, our use of it, or Your rights, contact us at art@andidrew.com.

6.2 Accessing, Updating, and Deleting Your Personal Data

You can access and update Your personal data that ANDiDREW collects and maintains as follows:

• To update data You provide directly, log into Your account and update Your account at any time.
• To terminate Your account:
  • Visit Your profile settings page and follow the steps to “Delete my account”.
  • If You have any issues terminating Your account, please contact art@andidrew.com.
• Personal Data Retention:
  • Please note that even after Your account is terminated, some or all of Your data may still be visible to others, including without limitation any data that has been (a) copied, stored, or disseminated by other users (including comments on content); (b) shared or disseminated by You or others (including in Your shared content); or (c) posted to a Third  Party platform. Even after Your account is terminated, we retain Your data for as long as we have a legitimate purpose to do so (and in accordance with applicable law), including to assist with legal obligations, resolve disputes, and enforce our agreements. We may retain and disclose such data pursuant to this Privacy Policy after Your account has been terminated.

6.3 Our Policy Concerning Children

We do not knowingly collect, use, share, or sell the Personal Data of individuals under the age of 18 and ANDiDREW websites are not directed to individuals under 18. We recognize the privacy interests of children and encourage parents and guardians to take an active role in their children’s online activities and interests. Individuals younger than 18 years of age, but of the required age for consent to use online services where they live (for example, 13 in the US or 16 in Ireland), may not set up an account. Individuals younger than the required age for consent to use online services may not use the Services. If we learn that we’ve collected personal data from a child under those ages, we will take reasonable steps to delete it.

If you believe we might have any information from or about a child under the required age for consent, please contact us at art@andidrew.com.

• Jurisdiction-Specific Rules

7.1 Users in California

Users who are California residents have certain rights under the California Consumer Privacy Act, (“CCPA”). If You are an eligible California user, included in these rights are:

• Right to know: You have the right to request to know more about the categories and specific pieces of personal information that we have collected about You and access a copy of Your personal information.
• Right to correction: You have the right to have inaccurate personal information about You corrected.
• Right to deletion: You have the right to request deletion of personal information that we have collected about You.
• Right to non-discrimination: You choose to exercise any of Your rights under CCPA, ANDiDREW  will treat You like all other users. In other words, there is no penalty for exercising Your rights under CCPA.
• Right to opt-out: You have the right to opt out of the sale of Your personal information.

To exercise any of these rights under CCPA, please email art@andidrew.com.

7.2 Users in Nevada

ANDiDREW does not sell its users’ personal information or personal data.Nonetheless, Nevada residents have the right to submit a request that we do not sell Your covered personal information, which You can do by emailing art@andidrew.com.

7.3 Users in Virginia

Users who are Virginia residents have certain rights under the Virginia Consumer Data Protection Act (“VCDPA”). If You are an eligible Virginia user, You have the following additional rights:

• Right of access: You have the right to confirm whether a controller is processing Your personal information and to access such information.
• Right of correction: You have the right to correct inaccuracies in Your personal information, taking into account the nature of the personal information and purposes of the processing. 
• Right of deletion: You have the right to delete Your personal data You have provided or that has been collected.
• Right of portability: You have the right to obtain a copy of Your personal information that was previously provided in a portable, and to the extent technically feasible, readily usable format that can be transmitted to another controller where the processing is carried out by automated means.
• Right to opt out: You have the right to opt out of (as defined by the VCDPA) (i) targeted advertising, (ii) the sale of personal information and (iii) profiling in furtherance of decisions that produce legal or similarly significant effects.

To exercise any of these rights under the VCPA, residents can submit an individual rights request or contact ANDiDREW directly at art@andidrew.com.

7.4 Users in the European Union and United Kingdom

By law, users in the European Union, United Kingdom, Lichtenstein, Norway, or Iceland have certain rights with respect to their Personal Data, including those set forth below.

• Right to be informed: You have the right to be informed about the collection and use of Your personal data.
• Right to access: You have the right to access a copy of Your personal data.
• Right to rectification: You have the right to request inaccurate or outdated personal information be updated or corrected.
• Right to erasure: Data subjects have the right to request their personal data be deleted. Note that this is not an absolute right and may be subject to exemptions based on certain laws.
• Right to data portability: You have the right to ask for their data to be transferred to another controller or provided to them. The data must be provided in a machine-readable electronic format.
• Right to restrict processing: You have the right to request the restriction or suppression of their personal data.
• Right to withdraw consent: You have the right to withdraw previously given consent to process their personal data.
• Right to object: You have the right to object to the processing of their personal data.
• Right to object to automated processing: You have the right to object to decisions being made with their data solely based on automated decision making or profiling.

You can exercise the above rights at any time by contacting us via email at art@andidrew.com.

7.5 Users Outside of the U.S.

In order to provide the Services to You, we must transfer Your data to the United States and process it there. If You are using the Services from outside the United States, You consent to Processing Activities related to Your data in and to the United States or other countries.

8. Modification

From time to time, we may update this Privacy Policy. If we make any material change to it, we will notify You via email, or as required by applicable law. We encourage visitors to frequently check this page for any changes to its Privacy Policy.  Unless stated otherwise, modifications will become effective on the day they are posted. The revised Privacy Policy supersedes all previous Privacy Policies.

9. Miscellaneous

9.1 Interpretation

Any capitalized terms not defined in this policy are defined as specified in ANDiDREW ‘s Terms of Use. Any version of this Privacy Policy in a language other than English is provided for convenience. If there is any conflict with a non-English version, You agree that the English language version will control.

9.2 Questions

If You have any questions or concerns regarding our Privacy Policy, our practices, or our compliance with applicable privacy laws, please feel free to contact us at art@andidrew.com.