Comics / Digital Comics

Is Marvel Entertainment‘s Digital Subscription Safe for Privacy?

By Hervé St-Louis
June 12, 2008 - 22:40

Marvel Digital Unlimited, a branch of Marvel Comics and Marvel Entertainment has been offering a digital subscription service to comic books from the publisher’s huge library for a few months now. Some recent titles are even available.  For one monthly fee comic book subscribers can have access to Marvel Digital Unlimited’s  entire library that was converted to digital format online. Readers read the Web comics through a branded Marvel Comics’ reader created with Adobe Flash. As attractive as the offer seems, the one question I have is how serious is Marvel Entertainment about protecting the privacy of its subscribers?


The question is a legitimate one concerning some recent announcements from Marvel Comics. The publisher announced a few months ago that its Digital Unlimited initiative would connect with the social networking Web site Facebook. Through Facebook, subscribers of Marvel Digital Unlimited could comment and exchange with other users about online comic books offered by the publishers. Recently, Facebook has come under a lot of scrutiny for the way it protects and manages its users’ privacy settings.

There was a fiasco around November 2007 about Facebook exchanging data about people shopping and using some third party Web sites without its users’ knowledge. Last week, the Canadian Privacy Commissioner launched an enquiry into Facebook’s privacy practices which, according to one Ottawa-based consumer rights group, runs afoul of Canada’s privacy laws. The most consistent annoyance about Facebook is that by default, it opts in its users in all its schemes instead of opting them out.  Privacy advocates and Canadian privacy laws ask the opposite. The burden of protecting and enabling subscribers’ privacy should always the providers’ responsibility.


That Marvel Digital Unlimited connects directly with Facebook is a major concern for me. Will Marvel Unlimited Digital let Facebook know that I have an account with them, even if I don’t use the Facebook widgets they provide when I use Facebook? Will Marvel Digital Unlimited share any of my subscription or personal data with third parties?

Although cross selling users information doesn’t seem frequent in the comic book industry, it has happened in the past. I remember in the early 1990s when I collected Valiant Comics. I was one of the readers who had purchased all the first six issues of Valiant Comic’s Harbinger’s series and mailed the coupon card in order to receive the free Harbinger #0 issue. A few months later, I received in my mail box, an offer for a comic book subscription service from a company I had never heard about. At the time, the only people in the comic book industry with whom I had ever shared my home address were Valiant Comics. The local comic book store had no such information and neither would it have been in their interests to share such information with a competing service! To this day I never had any proof that Valiant Comics had sold my personal data to third parties without my express approval and it is unlikely that I will ever find out.


Yet, the issue is compounded these days as the sharing of subscribers’ personal data is so much easier, and when there are genuine financial rewards for media groups that do.  I consider Marvel Entertainment a me-too kind of company. Marvel Entertainment is like that kid in high school who upon returning from the summer vacation one year, decided it was going to hang out with the cool kids, even though it used to be a real geek before. The cool kids here are the large media groups that make movies, video games and a lot of entertainment material for the masses. Marvel Entertainment wants to be up there with them.

Marvel Entertainment is sitting on a pile of intellectual property and information about a desirable target group. The temptation to monetize this data is strong. However, media groups and vendors like Facebook often forget one basic covenant. The information they hold in their database is not theirs. It belongs to their users. They cannot do with this information what they want with it.


Marvel Entertainment doesn’t even act like a comic book publisher. It acts like just another media group. Marvel Entertainment’s Web site is ridden with advertising. If I subscribe to Marvel Digital Unlimited, will they sell all my data to the first bidder?

Looking at the privacy statement from Marvel Entertainment’s Web site, I’m so far astounded with the answers. Marvel Entertainment places a high protection value for its users aged under 13-years. In other words, if the statement is to be believed, parents can trust Marvel Entertainment.  However, it is not clear if Marvel Entertainment would require parents to sign in and approve a subscription to Marvel Digital Unlimited.


As for adults and kids over 13-years of age, the situation is a bit different. They are both treated as the same, although kids from 13 to 18 years-old are still minor and thus, one would expect, should have the same protection as kids under 13. Why does Marvel Entertainment distinguish the two groups? Is there a commercial incentive to treat kids over 13 years as more desirable consumers?

Adults are told that they can opt out of several “offers” from Marvel Entertainment’s third party “partners.” That’s a fair deal. The one problem with this is that Marvel Digital Unlimited associates one’s general user account directly with the Marvel Digital Unlimited service. They would probably fail the Canadian privacy laws, even though they claim to follow the state of California’s legal framework. If Marvel Entertainment sells to Canadians, it should adhere to Canada’s privacy laws.


I intend to follow up on this story and continue to investigate Marvel Entertainment’s privacy provisions. I would really like to subscribe to their Digital Unlimited service, but if Marvel Entertainment cannot guarantee that my personal data will not be sold to third parties, I will continue to go to my local comic book store that is happy enough to see me and doesn’t require me to provide him more than my name.

Meanwhile, if you know of any potential privacy abuse or issues of contentions within the comic book industry, share it with The Comic Book Bin, and we’ll investigate.

Last Updated: January 24, 2022 - 11:00

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