Privacy Policy

KOMODO HAWAII LLC, a Hawaii limited liability company, and its affiliates (collectively, “we” or “Komodo”) have issued this Privacy Policy (the “Policy”). Komodo respects your privacy and is committed to protecting it.

1. Definitions

This Policy covers your “Personal Data”, which we define to mean any information that can be used to directly or indirectly identify you as an individual. “Anonymous Data”, which may or may not be aggregated, is data that cannot readily be used to identify the user who generated the data. This Policy does not apply to Anonymous Data, and Komodo reserves the right to share Anonymous Data with third parties in accordance with applicable laws and regulations. Aggregated Personal Data that cannot be used to identify you shall be considered Anonymous Data for the purposes of this Policy.

2. Scope

This Policy shall apply to all products and services provided by Komodo, including but not limited to, access to its website and use of the NIUHI platform (“NIUHI”).

3. Consent

Agreeing to the terms of this Policy and consenting to Komodo’s collection of your Personal Data is required to access any service or program operated or developed by Komodo. By agreeing to this Policy, you hereby accept and acknowledge that the ongoing collection of Personal Data is necessary for Komodo’s provision of certain products and services to you, and that Komodo shall not require any additional consent or authorization to collect or process your Personal Data through your use of Komodo’s products or services. Further, by agreeing to this Policy, you hereby consent to Komodo’s use of your Personal Data for the purposes detailed in Section 6 below. You may withdraw your consent to this Policy at any time by written request, but if you withdraw your consent to this Policy then you will be unable to access any of Komodo’s products or services.

4. Collection of Information

The Personal Data we collect may include, without limitation, your full name, birth date, age, gender, address, telephone number, e-mail address, payment information, IP address, application usage data, location data, device information, and other data collected through automated electronic interactions. We may collect Personal Data directly from applications, forms, or communications we receive from you, or from other sources on your behalf, in connection with our provision of products or services to you. For example, when registering for NIUHI, we will ask you for your Personal Data. We may also collect application user information from your Internet browser, computer, mobile device, or similar equipment.

5. Cookies

Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology to help us provide functionality that is useful to you. You can set your browser not to accept cookies. However, by disabling cookies, some of our website features may not properly function. Information gathered from cookies may be provided to third party services such as Google Analytics to help us better engage with our site’s users.

6. Purpose of Use

We may use your Personal Data for the following uses: to facilitate the teaching and learning of languages, to provide products and services to you (or to someone else on your behalf), to improve our products and services, to process payments you make to us, and to communicate with you about our products and services. We will not sell nor otherwise handle Personal Data in our possession beyond the extent necessary for fulfilling its intended purpose of usage, except in the following cases:

1. In instances where you have granted your permission;
2. In instances where we are required to do so by a legal order;
3. If such information is required for the protection of a person’s life, body, or property, and the permission of the customer cannot readily be obtained; or
4. If it becomes necessary by legal ordinance to cooperate with a government agency, public authorities, or parties authorized by them, and, as determined by Komodo in good faith, there is concern that seeking permission of the customer may hinder the execution of the relevant duties.

Before using Personal Data for any purpose other than those listed above, we will notify you to request your consent, and will not use your Personal Data for such other purpose unless you give your consent.

7. NIUHI

NIUHI allows users to submit their own translations and other comments in order to facilitate the teaching and learning of languages as well as spread the enjoyment of comics to more people. Komodo also uses this data to improve our services and teaching features. Other NIUHI users may view these translations and other comments. By agreeing to this Policy, you hereby agree and accept that it is your responsibility to not upload any confidential personal information that you do not want viewed by other users. If you recognize any confidential personal information in a translation or comment that is publicly viewable on NIUHI, please contact Komodo using the contact information provided in Section 13 of the Policy to request its removal.

8. Security and Retention of Information

We take measures to prevent leakage, loss or damage and other necessary and appropriate measures to safely manage Personal Data. We use a combination of security technologies, procedures, and safeguards to protect against unauthorized access, use, and/or disclosure of Personal Data. We train our employees on privacy practices and on Komodo’s privacy and information security policies. We work hard to retain information related to you only as long as reasonably necessary for business and/or legal purposes. We are not responsible for the privacy practices of third parties, even if our website links to those third parties’ websites.

We will retain your Personal Data as long as reasonably necessary to fulfill the purposes stated in this Policy, and in accordance with applicable law. However, we do not represent or warrant that your Personal Data will be protected from loss, damage, or deletion without notice.

9. Waiver of Liability

By agreeing to this Policy, you agree to not hold Komodo liable in tort or contract for any direct or indirect damages you may experience because of a data leak of your Personal Data by third parties, unless the data leak was caused by the gross negligence or intentional misconduct of Komodo.

10. Providing Information to Third Parties

By agreeing to this Policy, you hereby consent to Komodo sharing your Personal Data with certain third parties (including other companies affiliated with Komodo) as permitted by law. Komodo’s provision of your Personal Data is solely for those purposes identified in Section 6 above. For example, we may use third party services such as Google Analytics to help us understand user engagement and better interact with our users.

11. Access and Correction

You have the right to withdraw your consent to this Policy. You have the right to request copies of your Personal Data. We may charge you a reasonable fee for this service. You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete information you believe is incomplete. You have the right to request that we erase your Personal Data, under certain conditions. You have the right to request that we restrict the processing of your Personal Data, under certain conditions. You have the right to object to our processing of your Personal Data, under certain conditions. You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions. To access your Personal Data in our possession, to correct any inaccuracies, or to make any of the other requests described above, please submit your request to us in writing using the mailing address specified in Section 13. Please note that the erasure of your Personal Data, or a withdrawal of your consent to this Policy, may prevent you from further accessing our products and services.

12. Policy Updates

This Privacy Policy was last updated on December 10, 2024.

We reserve the right to revise this Policy from time to time and will keep an updated copy on our website at all times. Please review this Policy regularly to be aware of any recent changes we may have made. If you have an account with Komodo, we will contact you using the email address associated with your account to inform you of any changes in our use of your Personal Data or other modifications to this Policy.

13. Contact

Komodo is the data controller of your data for the purposes of the General Data Protection Regulation (also known as “GDPR”) and any relevant local laws and regulations. Mr. Nicolas Dufer is the Personal Information Protection Manager for Komodo. If you wish to contact us regarding our use of your Personal Data, or if you wish to exercise the rights provided to you under this Policy, you may write to us at:

Or, you may email us at: [email protected]

14. Business Transfers

In the event that we are involved in a merger, acquisition, reorganization, bankruptcy proceeding, or sale of assets, your Personal Data may be transferred to a new entity. The privacy protections provided under this Policy will continue even after the transition to a new entity.

15. Supplemental Terms

For users in some jurisdictions, local laws and regulations may supplement the terms of this Policy. For users in those jurisdictions, local laws and regulations will take precedence over this Policy to the extent that a conflict may exist.

For Users in Japan

This Policy shall be interpreted in accordance with the terms and provisions of the Act on the Protection of Personal Information (“APPI”). For purposes of the APPI, “Personal Data” as defined in Section 1 of this Policy may include Pseudonymized Data. “Pseudonymized Data” is Personal Data that has been processed so as to make the individual user indirectly identifiable only through the use of other information. Under this Policy, your Pseudonymized Data benefits from the same protections as your Personal Data, except that your right to Access and Correction of data under Section 11 may be more limited with regard to Pseudonymized Data.

Komodo has offices in the U.S. state of Hawaii, and may transfer your Personal Data to its servers outside of Japan. In addition, Komodo may transfer your Personal Data to third parties outside of Japan, including third parties in the United States. The United States has different privacy laws than Japan. Under federal law, companies in the United States do not have to ask for your consent prior to providing your Personal Data to third parties. However, regardless of where your data is stored, we will take steps in accordance with the terms and conditions of this Policy to protect your privacy rights. By agreeing to this Policy, you hereby knowingly acknowledge and consent to the potential provision of your Personal Data to third parties outside Japan.

16. Complaints

You have a right to report a complaint to us using the mailing address provided in Section 13. If you feel that our response to your complaint was inadequate, you may contact the Hawaii Department of Commerce and Consumer Affairs, Office of Consumer Protection, at 235 South Beretania Street, 8th Floor, Honolulu, Hawaii 96813, or by calling +1 (808) 586-2630.