Privacy Policy
Last updated: September 27, 2026
This Privacy Policy explains how LewdPanels ("we", "us") collects and uses personal data when you visit lewdpanels.com (the "Site"), join our early access list, or contact us. LewdPanels is an 18+ marketplace for adult comics that is currently in pre-launch.
1. Who is responsible for your data
The data controller is [Company legal name], [registered address, country]. You can reach us about privacy at [privacy@lewdpanels.com].
2. Adults only
The Site is intended only for people aged 18 or older (or the age of majority where they live). We do not knowingly collect data from minors. If you believe a minor has given us personal data, contact us and we will delete it.
3. What data we collect and why
| Data | Purpose | Legal basis (GDPR) |
|---|---|---|
| Email address and whether you are a reader or a creator, when you join the early access list | To tell you when LewdPanels launches and, for creators, to discuss founding-creator terms | Consent (Art. 6(1)(a)), which you can withdraw at any time |
| Anything you send us by email | To answer your request | Legitimate interest (Art. 6(1)(f)) or steps before a contract (Art. 6(1)(b)) |
| Usage and device data collected by analytics (pages viewed, clicks, scrolling, approximate location from IP, browser and device type, referrer) | To understand how the Site is used and improve it | Consent (Art. 6(1)(a)); collected only if you click "Accept" |
| Technical server logs (IP address, time, requested URL) | Security, preventing abuse, keeping the Site running | Legitimate interest (Art. 6(1)(f)) |
We do not sell your personal data, and we do not use it for targeted advertising.
4. Analytics and cookies
When you first visit, we ask whether you accept analytics cookies. If you click "Reject" or ignore the banner, no analytics scripts are loaded and no analytics cookies are set. You can change your choice at any time via Cookie settings, also linked in the footer of every page.
If you accept, we use:
- Matomo, a web analytics tool that we run on our own server (analytics.gazolin-production.com). Data collected by Matomo is not shared with third parties.
- Microsoft Clarity, provided by Microsoft Corporation, which records how visitors interact with pages (clicks, scrolling, mouse movement) as heatmaps and session replays. Clarity masks text you type in form fields. Microsoft processes this data as described in the Microsoft Privacy Statement.
| Name | Provider | Purpose | Duration |
|---|---|---|---|
| _pk_id.* | Matomo | Recognises returning visitors | 13 months |
| _pk_ses.* | Matomo | Groups page views into a visit | 30 minutes |
| _pk_ref.* | Matomo | Remembers which site referred you | 6 months |
| _clck | Microsoft Clarity | Keeps the same Clarity user ID across visits | 1 year |
| _clsk | Microsoft Clarity | Groups page views into one session recording | 1 day |
| CLID, MUID, ANONCHK, SM, MR | Microsoft Clarity / Microsoft | Identify the browser across Clarity sessions and sites that use Clarity | Session up to 1 year |
We also store two small values in your browser's local storage that are never sent to us and are strictly necessary for the Site to work:
- lp_age_ok: remembers that you confirmed you are 18 or older, so we don't ask on every page.
- lp_consent: remembers whether you accepted or rejected analytics cookies.
5. Who we share data with
We share personal data only with service providers that help us run the Site, under contracts that require them to protect it:
- our hosting provider, which stores the Site and its server logs;
- the email service we use to store the early access list and send the launch email;
- Microsoft, for Clarity analytics (only if you accept analytics cookies).
We may also disclose data if required by law or to protect our rights, users or the public.
6. International transfers
Some providers, including Microsoft, may process data outside the European Economic Area or the UK, including in the United States. Where this happens, we rely on appropriate safeguards such as the EU–US Data Privacy Framework or the European Commission's Standard Contractual Clauses.
7. How long we keep data
- Early access list: until LewdPanels launches and we have sent the launch email, or until you unsubscribe or ask us to delete it, whichever is earlier, and in any case no longer than 24 months.
- Analytics data: up to 13 months in Matomo; Clarity data is kept according to Microsoft's retention periods.
- Emails you send us: as long as needed to handle your request.
- Server logs: up to 30 days, unless needed to investigate abuse.
8. Your rights
Depending on where you live, including under the GDPR, the UK GDPR and US state laws such as the California Consumer Privacy Act (CCPA/CPRA), you have the right to:
- access the personal data we hold about you and get a copy of it;
- correct inaccurate data;
- have your data deleted;
- restrict or object to certain processing;
- receive your data in a portable format;
- withdraw consent at any time, without affecting processing before the withdrawal;
- not be discriminated against for exercising your rights.
To exercise any of these rights, email [privacy@lewdpanels.com]. We will reply within 30 days. You also have the right to complain to your local data protection authority.
9. Security
We use reasonable technical and organisational measures to protect personal data, including encrypted connections (HTTPS) and limited access to data. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.
10. Changes to this policy
We may update this Privacy Policy, for example when LewdPanels launches accounts and payments. We will change the "Last updated" date above and, for significant changes, tell people on the early access list by email.
11. Contact
[Company legal name], [registered address]. Email: [privacy@lewdpanels.com].