YONDER PRIVACY POLICY HIGHLIGHTS

WEBTOON ENTERTAINMENT Inc. (including its subsidiary, NAVER WEBTOON Ltd., hereinafter together referred to as “we”, “our” or “us”) respect your concerns about privacy. This Privacy Policy applies to the personal information we collect through the services provided through the YONDER application and/or website (the “Services”).

For users in California, please review our additional Regional Privacy Disclosures.

OVERVIEW OF PRIVACY POLICY

In this Privacy Policy, we describe the types of personal information we process through the Services, how we may use the information, with whom we may share it and the choices available to you regarding use of the information and exercising your rights. We also describe the measures we take to safeguard the information and tell you how to contact us about our privacy practices. Below you will find a summary of the key topics contained in our Privacy Policy. For more detailed information on how we process your information, please click on the headings or continue to read below.

  1. 1. Information We Collect
  2. 2. How We Use the Information We Collect
  3. 3. Information Sharing
  4. 4. Retention of Personal Information
  5. 5. Your Rights and Choices
  6. 6. How We Protect Personal Information
  7. 7. International Transfer of Information
  8. 8. Links to Third-Party Websites, Devices, Apps and Features
  9. 9. Children’s Personal Information
  10. 10. Updates to Our Privacy Policy
  11. 11. Contact Us
  12. 12. Regional Privacy Disclosures

1. Information We Collect

The following personal information is collected in connection with the Services:

Information You Provide Directly

When you use our Services, you may provide us with your personal information after being informed of the privacy information at the time of collection. For example:

  • - When you login through a third-party account (e.g., Google, Facebook, or Apple) to your profile with us, we receive information from such third-parties such as your nickname (alias) or profile picture, in accordance with the authorization procedures determined by such third-party platforms.
  • - When you participate in our events or promotions, we may ask for your name, phone number, address, email address, and any other information required to deliver prizes and to respond to inquiries.
  • - When you participate in our surveys or opinion polls, we may ask for your name, phone number, gender, and any other information that can be reasonably required to conduct surveys or opinions and provide rewards.
  • - To provide responses when you contact our Customer Care, we may collect verification information and any information you choose to provide, such as your requests or inquiries. When you communicate with our Customer Service staff or others, your communications will be transmitted through our systems through your email address.

Information About Your Use of Services

In addition to the information you provide, we will collect information about your use of our Services through software on your devices and by other means. We will collect:

  • - Service usage information: your interactions with the Services, dates and times of use of the Services, and any Service usage information such as reading genre preferences, comments or reviews, Coin and Free Passes balances, commercial information including purchase and transaction history, recent views, subscription history, download history, and event, promotion and/or contest participation.
  • - Information relating to the organization of contests and/or any promotional operations: date of participation, responses to the contests and nature of the prizes offered;
  • - Device and Log Information: Device and log information such as device identification key number, device model, OS version, IP address, setting of devices, nation based on IP address, URL and network type; and
  • - Transaction Data: We process technical information (e.g. transaction number) to validate the transactions.

Information collected through cookies and similar technologies

- We and third parties may use cookies, web beacons, pixels, tags, and other tracking technologies (which we will refer to collectively as "cookies") to help us gather statistical information in order to improve your experience with the Services, save your preferences, and to provide you offers. These Tracking Technologies may be used to track you across devices and websites over time. Most web browsers automatically accept cookies and session IDs, but you may be able to disable cookies by making the appropriate selection from your browser options. Note that by doing so, the functionality of our Services may be limited.

To find out more on how we use the cookies collected, please refer to our Cookie Policy. To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org or www.allaboutcookies.org.

2. How We Use the Information We Collect

We may use the information collected above for the following purposes:

  • - Identify and authenticate you and administer your account;
  • - Provide the Services or feature you request, respond to your request, questions and instructions made through the Services;
  • - Conduct surveys and analyses necessary for improving the Service;
  • - Personalize your experience with us;
  • - Send you information and prizes for campaigns and events;
  • - Communicate with you about our products, services, and events and provide news and information that we think will interest you (See section 5 “Your Rights and Choices” below for information about how to opt out of these communications at any time);
  • - Monitor and analyze trends, usage, and activities in connection with our products and services;
  • - Create de-identified, anonymized or aggregated information;
  • - Deliver and protect Digital Content;
  • - Ensure the information security of our Services;
  • - Protect against, identify and prevent fraud and other criminal activity, claims and other liabilities;
  • - Validate transaction and prevent fraud and abuse;
  • - Generate statistical data pertaining to usage of the Services;
  • - Ensure and monitor the effectiveness and availability of the services to improve performance of the website and the application;
  • - Comply with and enforce applicable law requirements, relevant industry standards and our policies, including this Privacy Policy; and
  • - Carry out any other purpose described to you at the time the information was collected

3. Information Sharing

WEBTOON Entertainment Inc. and NAVER WEBTOON Ltd. share information as joint controllers of your personal information whenever necessary to provide Services efficiently and in accordance with applicable law. We disclose personal information about you through or from the Services as described in the following:

  • - Service Providers. We may disclose your information to companies that provide Services on behalf of us, such as companies that help us develop and operate systems for the Service with customer contact centers, as well as customer care activities, conducting customer satisfaction surveys, billing or that send emails on our behalf. These entities are limited by contractual provisions in their ability to use your information for purposes other than providing Services for us. Acting as service providers in accordance with legal regulations, such suppliers may have access to your personal data in order to provide the services and/or comply with the obligations arising from the legal relationships maintained between the aforementioned third parties and us. In any case, we have signed the corresponding confidentiality and data protection agreements with those service providers, in full compliance with the provisions of current legislation on data protection.
  • - Affiliates. We may disclose your information to our affiliates and subsidiaries as needed to provide the Services.
  • - Public. Information that you have voluntarily registered to be shared with the public can be seen by anyone, including those who do not have an account. This may include your nickname, comments or review and any information or content you share with a public audience.
  • - Advisors. We may share personal information with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
  • - Government entities, including law enforcement as required by law. There may be instances when we disclose your information to comply with the law or respond to compulsory legal process (such as a search warrant or other court order);
  • - When Required to Protect Our App or Others. We may share personal information to persons (e.g., law enforcement, IT forensics) as necessary if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect our rights, property, and safety or the rights of our users, the public, or others. There may be instances when we disclose your information to other parties:
    • • to comply with the law or respond to compulsory legal process (such as a search warrant or other court order);
    • • to verify or enforce compliance with the policies governing our Services; and
    • • to protect our rights, property, or safety, or, in compliance with data protection laws, any of our respective affiliates, business partners, or customers.
  • - Other Parties in Connection with Transactions. We may disclose your information to a third party as part of an actual or planned merger or transfer, acquisition or sale, or corporate reorganization.
  • - Other Parties with Your Consent or on Your Request. In addition to the disclosures described in this Privacy Policy, we may share information about you with third parties when you separately consent to or request such sharing.

4. Retention of Personal Information

We take appropriate steps to ensure that we process and retain information about you based on the following logic:

  • - at least the duration for which the information is used to provide you with a service;
  • - as required under law, a contract, or with regard to our statutory obligations (e.g., tax laws); or
  • - only for as long as is necessary for the purpose for which it was collected, is processed, or longer if required under any contract, by applicable law, or, in anonymized form, for statistical purposes, subject to appropriate safeguards.

Thus, we will only keep your personal data for as long as we need it for the purposes for which we collect them and to comply with legal, financial, business or reporting requirements. When we no longer need the personal data, we will securely delete or destroy it.
We will storage the collected data even thereafter, until the expiration of any legal liability arising therefrom.

5. Your Rights and Choices

collected, and you can ask us to correct any inaccuracies. If permitted by law, we may charge you a small fee for providing you with this ability. We may decline to process requests that are unreasonably repetitive, require disproportionate technical effort, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. To make a request concerning your rights or to make an inquiry, contact us. See the Contact Us section.

You may ask us to delete your personal information by deleting your account at any time.

We offer you certain choices in connection with the personal information we obtain about you. If you would like to change your preference regarding our communications (including marketing communications), you can change your communication preferences from “Settings” page.

6. How We Protect Personal Information

The transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information as it is transmitted to us. To the extent permitted under applicable law, we assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized access by third-parties, or other causes beyond our control.

You play an important role in keeping your information secure. You should not share your username or password for your account with anyone. If you have reason to believe that your account is no longer secure, please contact us immediately as detailed below.

7. International Transfer of Information

Your use of our Service will involve the transfer, storage, and processing of your personal information within and outside of your country of residence, consistent with this policy. In particular, your personal information will be transferred to the United States, Japan, the Philippines, and Republic of Korea. Please note that the data protection and other laws of countries to which your information may be transferred might not be as comprehensive as those in your country.

8. Links to Third-Party Websites, Devices, Apps and Features

The Services may provide the ability to connect to third-party websites, devices, apps and other features, which may operate independently from us and may have their own privacy notices or policies, which we strongly suggest you review. To the extent any linked website, device, app or other feature is not owned or controlled by us, we are not responsible for its content, use or privacy practices.

9. Children’s Personal Information

Our Services have a minimum “User’s Age Limit” as defined in our Terms of Use. Our Services are not directed to individuals under the applicable “User’s Age Limit” and we do not knowingly collect personal information from individuals under the applicable “User’s Age Limit”. If you believe that we have personal information about an individual the “User’s Age Limit”, please notify us or that we may take reasonable steps to delete the information.

10. Updates to Our Privacy Policy

This Privacy Policy may be updated to reflect changes in our personal information practices with respect to the Service, or changes in the applicable law. We will post a notice on our Service to notify you in advance of material changes to our Privacy Policy and indicate at the top of the notice when it was most recently updated.

11. Contact Us

For more information about our privacy practices, or to exercise any rights you may have pursuant to applicable law, please contact our personal information management department at Customer Care.

You can also contact us in writing at the following addresses:
WEBTOON Entertainment Inc.
5700 Wilshire Blvd Suite 220,
Los Angeles, CA 90036
United States

As WEBTOON Entertainment Inc. and NAVER WEBTOON Ltd. will take joint action whenever necessary to comply with your rights, requests or complaints, you can also contact us at NAVER WEBTOON Ltd.: NAVER WEBTOON Ltd.:
11-12F Techone Tower, 131, Bundangnaegok-ro, Bundang-gu,
Seongnam-si, Gyeonggi-do,
Republic of Korea.

12. Regional Privacy Disclosures

12.1 For California Consumers

This California section supplements the YONDER Privacy Policy and applies solely to California consumers.

California

The California Consumer Privacy Act or “CCPA” (Cal. Civ. Code § 1798.100 et seq.) affords consumers residing in California certain rights with respect to their personal information. If you are a California resident, this section applies to you.

To understand what personal information we may have collected about you in the past 12 months, and from where we collected it, please see the section, Information We Collect. We collect personal information for the business and commercial purposes described in the How We Use the Information We Collect section above.

We may share such personal information with the third parties listed in the above section entitled, Information Sharing. California law requires that we provide you with additional information about certain disclosures to such third-parties within the past 12 months, particularly, where the disclosure involves monetary or other consideration. California treats these disclosures as sales of information, even where no money is exchanged. We do not sell personal information, and we do not sell, or have actual knowledge of any sale of, the personal information of minors under 16 years of age.

We may, however, have disclosed, in the past 12 months, the following categories of personal information to the following third-parties for our operational “business purposes” as defined by California law:

  • - LINE Plus Corporation: user ID, Nickname, IP address, email address, service usage information, and information required to respond to respond to your inquiries and requests for the management of your relationship with us and for the management of your inquiries and requests;
  • - NAVER Corporation Inc.: user ID, IP address, email address, and information collected through social networks such as nickname and profile picture for operational and analysis purposes;
  • - NAVER Cloud Corp.: user ID, IP address, email address, service usage information, device and log information, transaction data for infrastructural operations and the prevention of misuse of the services;
  • - LINE Corporation: user ID, purchase history, device identification key number and unique value given to you as subscriber of services for payment processing purposes, in particular in order to enable the validation of transactions made through Apple Store and Google Play Store platforms;
  • - INKA Entworks Inc.: Hashed user ID and device identification key number of your device for digital rights management.
  • - Data Analytics Providers: Identifiers such as a unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements

Under California law, you have certain rights, including:

  • • The right to know the categories of personal information we’ve collected and the categories of sources from which we received the information;
  • • The right to know the business purposes for collecting, using, or selling personal information;
  • • The right to know the categories of third parties with whom we’ve disclosed personal information;
  • • The right to access the specific pieces of personal information we’ve collected, used, disclosed, and/or sold;
  • • The right to opt-out of the sale of your personal information;
  • • The right to delete/anonymize your information, with limited exceptions; and
  • • California residents also have the right to not be discriminated against if they choose to exercise their privacy rights.

As noted above, we do not sell your information, however, if you wish to exercise any of these rights or have any questions or concerns regarding the processing of your personal information, please contact us as specified in the Contact Us section of this Privacy Policy. We will not discriminate against you if you exercise your rights under the CCPA.

Please note, however, before we will be able to process your request for access or deletion of personal information, we will need to properly verify your identity for security purposes. If we possess appropriate information about you on file (e.g., name, phone number, email), we will attempt to verify your identity using that information. If it is not reasonably possible to identify you adequately, we may not be able to respond to your request.

To use an authorized agent to make a request on your behalf, you will need to directly confirm with us that you provided the authorized agent permission to submit the request and provide us with signed permission for the authorized agent to act on your behalf. You will also need to verify your identity, directly with us. If you are an authorized agent seeking to make a request, please contact us as specified in the Contact Us section of this Privacy Policy.

This Privacy Policy is effective from October 5, 2022 (effective immediately for new users).