Privacy Policy and Notice of Privacy Practices

Last Updated: January 2023

Shion Studio LLC and its affiliates and assigns (“Company” or “We”) respects your privacy and is committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit the website www.shionstudio.com (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to all products and services offered by the Company but excludes any products or services that have separate privacy notices which do not incorporate this policy.

This policy applies to information we collect:

• On this Website.
• In e-mail, text and other electronic messages between you and this Website.
• Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website.
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

• us offline or through any other means, including on any other website operated by Company or any third party; or
• any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to our Privacy Policy. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information:

• by which you may be personally identified, such as name, postal address, e-mail address, telephone number, birth date, or any other identifier by which you may be contacted online or offline (“personal information”);
• that is about you but individually does not identify you, such as geographic location; and/or
• about your internet connection, the equipment you use to access our Website and usage details.

We collect this information:

• Directly from you when you provide it to us.
• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses and information collected through cookies, web beacons, and other tracking technologies.
• From third parties, for example, our business partners.

Information You Provide to Us

The information we collect on or through our Website may include:

• Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use certain features of our Website, posting reviews, or receiving additional information from us. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.
• Records and copies of your correspondence (including e-mail addresses), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.
• Your search queries on the Website.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Transfers Outside of the European Economic Area

Personal information in the European Union is protected by data protection laws but other countries do not necessarily protect your personal information in the same way.

The Website, some of the applications or services or parts of them may also be hosted in the United States or otherwise outside of the EEA (which means all the EU countries plus Norway, Iceland and Liechtenstein) (“EEA”) and this means that we may transfer any information which is submitted by you through the website or the application or service outside the EEA to the United States or to other territories outside of the EEA. When you send an email to us, this will also be stored on email servers which are hosted with Google and therefore may be outside of the EEA.

We may use service providers based outside of the EEA to help us provide our website and services to you and this means that we may transfer your information to service providers outside the EEA for the purpose of providing our advertising and services to you.

We take steps to ensure that where your information is transferred outside of the EEA by our service providers and hosting providers, appropriate measures and controls are in place to protect that information in accordance with applicable data protection laws and regulations. In each case, such transfers are made in accordance with the requirements of Regulations (EU) 2016/679 (the General Data Protection Regulations or “GDPR”) and may be based on the use of the European Commission’s Standard Model Clauses for transfers of personal data outside the EEA.

By using our website, products or services or by interacting with us in the ways described in this Privacy Notice, you consent to the transfer of your information outside the EEA in the circumstances set out in this Privacy Notice. If you do not want your information to be transferred outside the EEA you should not use our website, applications or services.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:

• Details of your visits to our Website, including traffic data, location data, logs and other communication data and the resources that you access and use on the Website.
• Information about your computer and internet connection, including your IP address, operating system and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). For information on how you can opt out of behavioral tracking and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking, please email us at hello@shionstudio.com.

The information we collect automatically is statistical data and may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies).A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
• Flash Cookies.Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see this.
• Web Beacons.Pages of the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.

Third-party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, retailers, content providers and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Website and its contents to you.
• To provide you with information, products or services that you request from us.
• To fulfill any other purpose for which you provide it.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to our Website or any products or services we offer or provide though it.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile. For more information, see Choices About How We Use and Disclose Your Information.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect, or you provide, as described in this privacy policy:

• To our subsidiaries and affiliates.
• To contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of The Company’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by The Company about our Website users is among the assets transferred.
• To third parties to market their products or services to you if you have not opted out of these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them. For more information, see Choices About How We Use and Disclose Your Information.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law or legal process, including to respond to any government or regulatory request.
• To enforce or apply our Terms of Use or Terms of Sale and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of The Company, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising.You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
• Disclosure of Your Information for Third-Party Advertising.If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by checking the relevant box located on the form on which we collect your data. You can also always opt-out by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an e-mail stating your request to hello@shionstudio.com.
• Promotional Offers from the Company.If you do not wish to have your e-mail address or contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by checking the relevant box located on the form on which we collect your data or at any other time by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an e-mail stating your request to hello@shionstudio.com. If we have sent you a promotional e-mail, you may send us a return e-mail asking to be omitted from future e-mail distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

Accessing and Correcting Your Information

You can review and change your personal information by logging into the Website and visiting your account profile page.

You may also send us an e-mail at hello@shionstudio.com to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our Terms of Use.

Your California Privacy Rights

California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to hello@shionstudio.com.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions are handled by third-party providers who use appropriate security measures and we do not collect any payment information from you.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like comment posts. The information you share in public areas may be viewed by any user of the Website.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you by e-mail to the e-mail address you have provided and/or through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at: hello@shionstudio.com.

COPYRIGHT POLICY

Last modified: January 2023

Reporting Claims of Copyright Infringement

We take claims of copyright infringement seriously. We will respond to notices of alleged copyright infringement that comply with applicable law. If you believe any materials accessible on or from this site (the “Website”) infringe your copyright, you may request removal of those materials (or access to them) from the Website by submitting written notification to our Copyright Agent (designated below). In accordance with the Online Copyright Infringement Liability Limitation Act of the Digital Millennium Copyright Act (17 U.S.C. § 512) (“DMCA’), the written notice (the “DMCA Notice”) must include substantially the following:

Your physical or electronic signature.

• Identification of the copyrighted work you believe to have been infringed or, if the claim involves multiple works on the Website, a representative list of such works.
• Identification of the material you believe to be infringing in a sufficiently precise manner to allow us to locate that material.
• Adequate information by which we can contact you (including your name, postal address, telephone number and, if available, e-mail address).
• A statement that you have a good faith belief that use of the copyrighted material is not authorized by the copyright owner, its agent or the law.
• A statement that the information in the written notice is accurate.
• A statement, under penalty of perjury, that you are authorized to act on behalf of the copyright owner.

Our designated Copyright Agent to receive DMCA Notices is: Legal/DMCA. hello@shionstudio.com (subject line: DMCA Notice).

If you fail to comply with all of the requirements of Section 512(c)(3) of the DMCA, your DMCA Notice may not be effective.

Please be aware that if you knowingly materially misrepresent that material or activity on the Website is infringing your copyright, you may be held liable for damages (including costs and attorneys’ fees) under Section 512(f) of the DMCA.

Repeat Infringers

It is our policy in appropriate circumstances to disable and/or terminate the accounts of users who are repeat infringers.

COPPA Compliance

Privacy Policy for Children under the Age of 13

Last modified: January 2023

The Children’s Online Privacy Protection Act of 1998 and its rules (collectively, “COPPA”) require us to inform parents and legal guardians (as used in this policy, “parents”) about our practices for collecting, using and disclosing personal information from children under the age of 13 (“children”). It also requires us to obtain consent from a child’s parent for certain collection, use and disclosure of the child’s personal information.

This policy notifies parents of:

• The types of information we may collect from children.
• How we use the information we collect.
• Our practices for disclosing that information.
• Our practices for notifying and obtaining parents’ consent when we collect personal information from children, including how a parent may revoke consent.
• All operators that collect or maintain information from children through this Website.

This policy only applies to children under the age of 13 and supplements the provisions of our general Privacy Policy. The general Privacy Policy still applies to children and the terms that are defined in it have the same meaning in this policy; but, the additional provisions of this policy only apply to children under the age of 13 and only our general Privacy Policy applies to teens and adults.

Information We Collect from Children

Children can access many parts of the Website and its content and use many of its features without providing us with personal information. However, some content and features may be available only to registered users or require us to collect certain information, including personal information, from them. In addition, we use certain technologies, such as cookies, to automatically collect information from our users (including children) when they visit or use the Website.

We only collect as much information about a child as is reasonably necessary for the child to participate in an activity, and we do not condition his or her participation on the disclosure of more personal information than is reasonably necessary.

Information We Collect Directly

To register with this website, a child must provide us with the following information: the child’s name, birth date, and a parent’s e-mail address. We also require the child to create a member name and password. We may request additional information from your child, but this information is optional. We specify whether information is required or optional where we request it.

Automatic Information Collection and Tracking

We use technology to automatically collect information from our users, including children, when they access and navigate through the Website and use certain of its features. The information we collect through these technologies may include:

• One or more persistent identifiers that can be used to recognize a user over time and across different websites and online services.
• Information that identifies a device’s location (geolocation information).

We also may combine non-personal information we collect through these technologies with personal information about you or your child that we collect online.

For information about our automatic information collection practices, including how you can opt out of certain information collection, see the “Automatic Information Collection and Tracking” and “Choices About How We Use and Disclose Your Information” sections of our general Privacy Policy.

How We Use Your Child’s Information

We use the personal information we collect from your child to:

• register him or her with the Website; and
• communicate with him or her about activities or features of the Website and Company events that may be of interest.

We use the information we collect automatically through technology (see Automatic Information Collection and Tracking and other non-personal information we collect to improve our Website and to deliver a better and more personalized experience by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about the child’s preferences, allowing us to customize the content according to individual interests.
• Speed up your searches.

We use geolocation information we collect to identify convention locations that might better serve our fans.

Our Practices for Disclosing Children’s Information

We do not share, sell, rent or transfer children’s personal information other than as described in this policy.

We may disclose aggregated information about many of our users, and information that does not identify any individual or device. In addition, we may disclose children’s personal information:

• To third parties we use to support the internal operations of our Website and who are bound by contractual or other obligations to use the information only for such purpose and to keep the information confidential.
• If we are required to do so by law or legal process, such as to comply with any court order or subpoena or to respond to any government or regulatory request.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers or others, including to:
• protect the safety of a child;
• protect the safety and security of the Website; or
• enable us to take precautions against liability.
• To law enforcement agencies or for an investigation related to public safety.

In addition, if the Company is involved in a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of its assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding or event, we may transfer the personal information we have collected or maintain to the buyer or other successor.

Social Features

The Website offers limited social features, including posting reviews or comments to public areas of the Website (“Social Features”). This enables users, including children, to publicly communicate with others on or through this Website. The nature of these features allows children to disclose personal information about themselves. We do not monitor or review this content for privacy concerns before it is posted, we do not control the types of information your child can send or post through them, and we do not control the actions of third parties with whom your child shares his or her information. We encourage parents to educate their children about safe internet use and to monitor their children’s use of social features to ensure they do not disclose their personal information through them.

Accessing and Correcting Your Child’s Personal Information

At any time, parents may review their child’s personal information maintained by us, require us to correct or delete the personal information and/or refuse to permit us from further collecting or using the child’s information.

You can review, change or delete your child’s personal information by:

• Logging into your child’s account, if he or she has created one, and visiting his or her account profile page.
• Sending us an e-mail at hello@shionstudio.com. To protect your privacy and security, we may require you to take certain steps or provide additional information to verify your identity before we provide any information or make corrections.

TRACKING TECHNOLOGIES

Last modified: January 2023

You have a number of options with respect to the tracking technologies:

You can prevent the use of certain tracking technologies (other than Flash cookies) by using the controls in your Web browser. To do so, you must complete both of the steps following your browser type below:

Internet Explorer

• Delete existing tracking technologies through the “Internet Options” sub-option of the “Tools” menu option of your browser or otherwise as directed by your browser’s support feature; and
• Disable future tracking technologies by using the same browser controls. Additional information on disabling most tracking technologies may be available through your browser’s support feature. (See the “help” section of your browser for more information.)

Google Chrome

• Delete existing tracking technologies through the “Clear Browsing Data…” sub-option of the “Tools” menu option of your browser or otherwise as directed by your browser’s support feature; and
• Disable future tracking technologies by using the same browser controls. Additional information on disabling most tracking technologies may be available through your browser’s support feature. (See the “help” section of your browser for more information.)

Mozilla Firefox

• Delete existing tracking technologies through the “Clear Recent History…” sub-option of the “History” menu option of your browser or otherwise as directed by your browser’s support feature; and
• Disable future tracking technologies by using the same browser controls. Additional information on disabling most tracking technologies may be available through your browser’s support feature. (See the “help” section of your browser for more information.)

You may be able to have the device you use to access the Website warn you each time a cookie or most other tracking technologies is being set (other than Flash cookies), or you can choose to turn off such warnings. This is done through your browser on the device you use to access the Website. Additional information on warnings and removal of warnings may be available through your browser’s support feature.

Please note that deleting, rejecting, disabling or turning off tracking technologies through the above options will not remove Flash cookies. For more information about Flash cookies and how to remove them from your computer, please visit here.

Please be aware that certain areas and features of the Website can only be accessed in conjunction with tracking technologies, and that disabling tracking technologies might prevent you from accessing such content.