YONDER PRIVACY POLICY HIGHLIGHTS

Last Updated: September 5, 2023.

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 U.S residents, 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. U.S residents

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 create your own account and log in to your account once created, we may need nickname, email address and password.
  • - 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);
  • - Deliver targeted advertisements and measure their performance
  • - 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.
  • - Ad networks and social media. We may disclose your personal information to ad networks and social media to deliver advertisements and measure their performance to be able to display advertisements tailored to your activity and usage of the mobile application.
  • - 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

Your personal information belongs to you. You can ask us to provide details about what we’ve 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, Vietnam, 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. For U.S. Residents

This section supplements the YONDER Privacy Policy and applies solely to U.S. residents.

Information we process

- We may request date of birth, to verify your ability to access certain features of the Services and to tailor content and advertisements to you.

Children’s Personal Information

Users under the age of 13 are not audience for our service as it relates to the COPPA compliance. 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.

For Consumers Residing in U.S.

This section supplements the YONDER Privacy Policy and applies to consumers residing in U.S

A. Collection and Disclosure of Personal Information

(1) Categories of Personal Information We Collect: We may have collected the following categories of personal information about you:

  • - Identifiers such as a unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, Internet Protocol address, email address, account name, and other similar identifiers;
  • - Commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies;
  • - 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;
  • - Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, behavior, attitudes, intelligence, abilities, and aptitudes.

(2) Sensitive Personal Information : We do not collect personal information from users under the age of 13. We do not disclose sensitive personal information to third parties.

(3) Categories of Sources of Personal Information: We may have collected personal information about you from the following categories of sources:

  • - From you or your devices, for example, through your use of the Services;
  • - Our affiliated companies which provide services on our behalf, such as customer support and payment processing;
  • - Social media networks.
  • - Ad networks; and
  • - Analytics providers;

(4) Business and Commercial Purposes for Collecting Personal Information: We may have collected personal information about you for the following business or commercial purposes (in addition to the purposes listed above in the YONDER Privacy Policy):

  • - Performing Services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, providing targeted marketing services , providing analytics services, or providing similar services;
  • - Auditing, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;
  • - Helping to ensure the security and integrity of the Service;
  • - Debugging to identify and repair errors that impair existing intended functionality;
  • - Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction;
  • - Undertaking internal research for technological development and demonstration; and
  • - Undertaking activities to verify or maintain the quality or safety of a Service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the Service or device that is owned, manufactured, manufactured for, or controlled by us.

(5) Categories of Third Parties with Whom Personal Information is Disclosed: In the preceding 12 months, we have disclosed your personal information with the following categories of third parties:

  • - Our affiliates, subsidiaries and business partners;
  • - Vendors who provide services on our behalf;
  • - Social networks;
  • - ad networks and analytics providers;
  • - Professional services organizations, such as auditors and law firms; and
  • - Other third parties when you separately consent to or request such sharing.

We may also disclose your personal information with the following categories of third parties:

  • - A third party as part of an actual or planned merger or transfer, acquisition or sale, or in the event of a bankruptcy;
  • - Government entities, including law enforcement as required by law.

(6) Categories of Personal Information Disclosed for a Business and Commercial Purpose: In the preceding 12 months, we may have disclosed the following categories of personal information about you for a business purpose: Identifiers, other identifying information, Email address, commercial information, internet and other electronic network activity information, sensory information, and inferences.

(7) Categories of Personal Information Sold & Third Parties: We have sold the following categories of personal information about you to the following categories of third parties:

  • - Advertising/marketing cookies and similar information to advertising partners in order to show you targeted advertisement based on your interactions with our Services.
  • - 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, and internet protocol address, which we share with our service providers, advertising partners, and other vendors to provide the Services.
  • - 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, which we share with our service providers, advertising partners, and other vendors to provide the Services.
  • - Inferences, which we share with our service providers, advertising partners, and other vendors to provide the Services.

We do not have actual knowledge that we have sold personal information of minors under 16 years of age.

(8) Categories of Personal Information Shared for Targeted Advertising & Third Parties: We have shared the following categories of personal information about you to the following categories of third parties:

  • - Advertising/marketing cookies and similar information to advertising partners in order to show you targeted advertisement based on your interactions with our Services.
  • - 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, and internet protocol address, which we share with our service providers, advertising partners, and other vendors to provide the Services.
  • - 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, which we share with our service providers, advertising partners, and other vendors to provide the Services.
  • - Inferences, which we share with our service providers, advertising partners, and other vendors to provide the Services.

We do not have actual knowledge that we have shared personal information of minors under 16 years of age.

B. Consumer Rights

- Right to Know: You may have the right to request that we disclose personal information that we have collected, sold, or shared about you in the past 12 months, including:

  • • the categories and specific pieces of personal information we have collected about you;
  • • the categories of sources from which we collected the personal information;
  • • the categories of personal information about you that we sold or disclosed for a business purpose, and the categories of third parties to whom we sold or disclosed that information for a business purpose.
  • • the business or commercial purpose for which we collected or sold the personal information;
  • • You also may have the right to request that we provide you with (1) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (2) the identity of those third parties.
  • - Right to Data Portability: You have the right to request that personal information that has been collected and maintained about you be transferred to you via a secure method in a commonly used electronic format that enables you to have complete access to and full enjoyment of your data, including, but not limited to, the capacity to save, edit, and transfer the personal information to any other person or platform at your discretion.
  • - Right to Correct: You have the right to correct or modify inaccurate personal information that we may have collected about you.
  • - Right to Delete: You have the right to request that we delete the personal information we have collected from you. You also have the right to opt-out of the sale of your personal information. We will not deny, charge different prices for, or provide a different level or quality of goods or services because you choose to exercise these rights

- Sale or Sahre of Personal Information & Targeted Advertising: Certain data collection and processing on our applications for purposes of interest-based advertising and social media tools may be deemed by applicable state laws as “targeting advertising”, “selling”, or “sharing” of personal information. You can opt-out of targeted advertising, sale or sharing of your personal information by clicking “Do Not Sell or Share My Personal Information” link in our mobile application settings

  • - Non-Discrimination: We will not discriminate against you for exercising your rights and choices, although some of the functionality and features available on the Service may change or no longer be available to you.

- Other Consumers' Rights:

• Shine the Light: California residents are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of personal information to third parties for their direct marketing purposes in the preceding calendar year. We do not share personal information with third parties for their own direct marketing purposes.

Do Not Track: Some web browsers transmit “do-not-track” signals to websites. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.

To submit an access, deletion, correction, or portability request, click here or contact us as specified in the Contact Us section of this Privacy Policy. We will require that you provide us with your e-mail address. When we receive your request, we will review the information that you provide and attempt to use it to verify your identity by comparing it against the information we have on file. You may also have an authorized agent submit a request on your behalf through this process. When we receive such a request, we will process the request, consistent with our standard process for verifying consumer requests. In addition, we may request information to demonstrate the agent’s authority to act on your behalf. You may appeal a denial of your consumer rights request by [describe process to appeal denial of consumer rights requests].

As noted above, we do not engage in profiling to make decisions that may affect you based solely on automated processing of your personal data. All decision-making processes related to the processing purposes described above are carried out with human intervention.

C. Data Retention

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 store the collected data even thereafter, until the expiration of any legal liability arising therefrom.

D. Other Topics

Contact Information: You can contact us by Contact Us

This Privacy Policy is effective from (effective immediately for new users).