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TERMS OF USE

WEBTOON™ TRANSLATE Terms of Use

This WEBTOON™ TRANSLATE Terms of Use (the “Agreement”) is an agreement between you and NAVER WEBTOON Ltd. (including its affiliates, WEBTOON Entertainment Inc., hereinafter together referred to as the "Company" or "We"). Please read this Agreement, and Privacy Policy found at [http://translate.webtoons.com] and incorporated herein by reference before using WEBTOON TRANSLATE Website and/or Digital Content.

By downloading or using WEBTOON TRANSLATE Website, or any Digital Content, and/or clicking on a button indicating your consent to the Agreement, you agree to be bound by the terms of this Agreement and Privacy Policy. The Company may at any time amend these Terms of Use and Privacy Policy by publishing amended version on WEBTOON TRANSLATE Website. You accept that by doing this, The Company had provided you with sufficient notice of the amendment.

If you do not accept these terms, then you may not download or use WEBTOON TRANSLATE Website or Digital Content. In addition, when using WEBTOON TRANSLATE Website and/or Digital Content, you shall be subject to any posted guidelines or rules applicable to such service, features or offers that may be posted from time to time. All such guidelines or rules are hereby incorporated by reference into this Agreement.

1. Definition

For the purposes of this Agreement:

"Contributor" means the users who translate the Digital Content into certain languages.

"Digital Content" means digitized comic books, including single issues and trade publications and other digital content provided by the Company through the Service.

"General Users" means the users who are allowed to read the User Translation, leave the comments, and share the User Translation through social network services.

"WEBTOON TRANSLATE Website" means translate.webtoons.com.

"My Page" means the profile page of the Contributor, which is automatically created upon clicking the box to agree on the Terms of Use.

"Official Version" means official translation of the script of the Digital Content provided by the Company through the Service.

"Service" means the service of Digital Content and User Translation of Digital Content provided by the Company and its affiliates and subsidiaries through WEBTOON TRANSLATE Website.

"Team Manager" means the user who is selected and authorized by the Company to organize a translation team (“Team”), invite Contributors to its team, and manage the team to create Team Version.

"Team Member" means the Contributor who is invited to join the Team organized by Team Manager.

"Team Profile" means the profile page of the Team, which is created upon organizing the Team.

"Team Version" means the User Translation created collectively by the Team.

"Unofficial Version" means the User Translation created by the Contributor or created collectively by the Team, which includes Wiki Version and Team Version.

"User Translation" means translated text of the script of the Digital Content created by the Contributor or the Team using certain translation tools of our Service, which is automatically saved in the service operator’s server, posted on the Service and provided to other users. User Translation refers to Unofficial Version including Wiki Version and Team Version.

"Wiki Version" means the User Translation created by the Contributor.

2. Use of Service

WEBTOON TRANSLATE Service is to provide the Digital Content and the translation tools to the users who voluntarily translate the script of Digital Contents into certain languages (User Translation) and share User Translation with other users. General Users are allowed to read the User Translation, leave the comments, and share the User Translation through social network services. Once the Contributor clicks the box to agree on the Terms of Use, My Page is automatically created and his or her User Translation will be stored and listed in My Page. The service operator may appoint the Contributor as Team Manager in its own discretion, give the Team Manager the authority to select Contributors as Team Members, and create and manage the Team to create the Team Version. Team Version and Team activities and Team Version will be stored and listed in Team Profile. The service operator has the right to take away the authority given to Team Manager and appoint another Team Manager to lead the Team, if the Team Manager is found irresponsible or inappropriate to lead the Team.

3. Digital Content and Limited License Term

A. Digital Content. You understand and agree that WEBTOON TRANSLATE Website and WEBTOON TRANSLATE tools are owned by the Company and Intellectual Property Rights in or to Digital Contents are and will remain the exclusive property of copyright owners and are protected by the copyright laws of the Republic of Korea, as well as other intellectual property laws and treaties.

B. Use of Digital Content. Upon your download or use of Digital Content, WEBTOON TRANSLATE tools and WEBTOON TRANSLATE Website, the Company grants you a limited, non-exclusive and non-transferable, non-sublicensable, revocable license to access, view, download, use, transmit and translate such Digital Content, solely for the use of the Service and the provision of the User Translation on the Service, subject to the terms of this Agreement. Under such license, you are granted to create User Translation which will be used only in relation to the Service, and prohibited from using, displaying, publishing, or transmitting User Translation for other services.

The license does not confer on you any ownership interest in such Digital Content. Digital Content is licensed to you by the Company; not sold, transferred or assigned to you. The Company may post additional terms for Digital Content in WEBTOON Translate website. Those terms will also apply, but in the event of a conflict between those terms and the terms of this Agreement, this Agreement will govern.

C. Limitations. Unless otherwise stated in writing by the Company, you must not copy, redistribute, sell, rent, lease, convey, reconvey or sublicense the Digital Content. You must not attempt to circumvent, avoid, bypass, remove, deactivate, impair or otherwise defeat any encryption, rights signaling or copy protection technology in which the Digital Content is wrapped or otherwise associated with. You must not duplicate or otherwise reproduce (including but not limited to “burning”) the Digital Content, or any portion thereof, onto any physical medium, memory or device (other than within your personal device that is allowed for download of Digital Content for thirty day period), including but not limited to CDs, DVDs, computers or other hardware, or any other medium now known or hereafter devised.

4. WEBTOON TRANSLATE Website

A. Use of WEBTOON TRANSLATE Website. You may not separate any individual component of such software for use on another device or computer, may not transfer it for use on another device or computer or use it, or any portion of it, over a network, and may not sell, rent, lease, lend, distribute, or sublicense or otherwise assign any rights to such software in whole or in part.

B. Updates. In order to keep your WEBTOON TRANSLATE Website up-to-date, the Company may make available updates/upgrades to the Website. If you do not download such updates/upgrades, you may not receive certain features and/or functionality and/or you may lose certain features and/or functionality of the Website.

No Reverse Engineering, Decompilation, Disassembly, or Circumvention. You may not modify, reverse engineer, decompile, reproduce, copy, disassemble WEBTOON TRANSLATE Website or otherwise reduce the computer file in which the Digital Content is stored to a human-readable form, whether in whole or in part, or bypass, modify, defeat, or tamper with or circumvent any of the functions or protections of WEBTOON TRANSLATE Website; e.g., by modifying, defeating, augmenting or substituting any digital rights management functionality.

5. Terms of Use

A. Users’ Age Limit. You must be at least fourteen (14) years old to use the Service. The use of the Service by anyone under the age of fourteen (14) years old is unauthorized and unlicensed.

The use of any of our Service by the minor (as defined in the law of your own country) is subject to the consent of their parent or legal representative. (“Representative(s)”). Representatives who wish to give the consent to their represented minor’s use of our Service should send the email to [dl_webtoontranslate@webtoonscorp.com].

You represent to us that (1) you are at least fourteen (14) years old and (2) if you are the minor, you have obtained your parents’ consents of use of the Service or the use of the Service is for personal daily need. We may request you to provide evidence of your Representatives’ consent or your age. We may also terminate your use of the Service if it comes to our attention that any of your representations to us is not correct. You declare that if you are the minor, your Representative(s) have read and agreed with these Terms of Use and Privacy Policy before you start to use the Service or any other products or services offered by the Company. We advise Representatives who permit their represented minors to use an interactive service to communicate with them about online safety, as well as about the content rating and any occasional improper contents which may be found in the Service. Represented minors permitted to use any interactive service should be made aware of the potential risks to them. Representatives shall be liable for the acts or omissions of their represented minors.

The Company does not intentionally nor unintentionally collect information from children or the minor in cases where Representatives have not consented to the use of the Company’s Service by the minor. However if a Representative identifies that a minor has provided the Company with personal information without the correspondent Representative’s permission, Representative should contact the Company at dl_webtoontranslate@webtoonscorp.com. Upon Representative’s request, the Company will delete any personal information of such minor without any further recourse from the Representative. The Representative will fully indemnify and release the Company from any liabilities, damages, claims or any other legal actions in respect of the provision of the personal information of such minor to the Company.

B. Compliance with Law and Reservation of Rights. You must use WEBTOON TRANSLATE Website and Digital Content in compliance with all applicable laws. All licenses are non-exclusive and all rights not expressly granted in this Agreement are reserved to the Company.

6. Privacy

The Company respects your privacy and has established certain policies and procedures relating to the collection and use of your personal information in connection with your use of the Service. Our Privacy Policy is available on WEBTOON TRANSLATE Website and applies to your use of the Service. By using the Service or clicking the consent box under the Privacy Policy, you are agreeing to the terms of our Privacy policy as undated from time to time.

We do not knowingly collect personal information from children under 14. Any parent or guardian who believes that a child may have provided personal information to us should contact us at [dl_webtoontranslate@webtoonscorp.com]. In such case, we will immediately take necessary actions to delete the personal information of children under 14.

7. Intellectual Property and Other Rights

WEBTOON TRANSLATE Website and Digital Content are owned and operated by the Company and its licensors. Digital Content, software, visual interfaces, interactive elements, features, information, graphics, design, compilation, computer code, products, look and feel, and all other elements of the Service, are protected by the laws of the Republic of Korea relating to the protection of intellectual property and proprietary rights, including copyright, patent, trade dress, and trademark laws, as well as laws relating to data protection and security. All Digital Content and the Service, including intellectual property rights herein and thereto, are the property of the Company or its subsidiaries or affiliated companies and/or third-party licensors. You may not reproduce, distribute, rent, lease, sell, license, copy, modify, publicly perform or display, transfer, transmit, publish, edit, adapt, prepare derivative works based on, or otherwise use Digital Content except as expressly authorized by this Agreement. The Company reserves all rights not expressly granted in this Agreement.

8. User Translation

A. You retain all of your ownership rights in your User Translation. The Contributor who creates User Translation alone is the exclusive copyright owner of his or her User Translation. The copyright to Team Version is jointly owned by Team Members who create Team Version together and all of Team Members hereby agree on the License Term and other terms stipulated below. (“Joint Ownership”) Unless you agree on such Joint Ownership of Team Version and the License Term in this Agreement, you must not join and participate in creating Team Version.

For User Translation, you grant to us a worldwide, exclusive , royalty-free, and sub-licensable (through multiple tiers), right, in any media existing now or in the future, to use, copy, reproduce, distribute, electronically transmit, publicly display, publicly perform, edit, modify, adapt, exploit and prepare derivative works (collectively, “Use”) based on your User Translation in connection with the service and business of the Company and its subsidiaries and affiliates or the service of the third party licensed by the Company. You also grant each user of the Service a non-exclusive license to use, copy, and transmit User Translation to social media services and improve your Content through the Service by editing and/or translating your User Translation. (“License Term”)

B. By submitting User Translation, you represent and warrant to us that you own all of the rights to such User Translation and that your User Translation does not and will not (i) infringe the copyright, trademark, publicity/ privacy right or other intellectual property right of any third party; (ii) violate any applicable law or (iii) violate the rights of, or cause physical, financial, or other harm to, any person or entity. You acknowledge that your indemnification obligation as described in Section 13 applies to your User Translation. Your User Translation may be Used with or without the name you use in connection with such postings. You agree that the Company is not responsible for User Translation, whether by you or anyone else.

C. You acknowledge that the content similar or identical to your User Translation (“Similar or Identical Content”) may have been or may in the future be submitted to the Company by other persons, or may have been or may in the future be made public by other persons. You agree that you are not entitled to any compensation from the Company, will not assert any claim against the Company, and the Company will not be liable to you, for any matter relating to such Similar or Identical Content, including the reproduction, sale, distribution, public display, public performance, exploitation of, and the making of derivative works based on such Similar or Identical Content. You acknowledge that it would not be feasible for the Company to offer features involving User Translation without your agreement to the terms of this Section 8.D.

D. You acknowledge that the Company does not pre-screen any User Translation, posted by you or other users but that the Company and its affiliates shall have the right (but not the obligation) in their sole discretion to refuse or remove any User Translation. The Company and its affiliates shall have the right to remove any User Translation that violate the Agreement or is otherwise objectionable, as well as terminate your access to the Website. You agree that the Company has no liability or responsibility for the storage or deletion of any User Translation that you submit or post.

9. Copyright Infringement Notification

If you believe the User Translation or comments within the Service violate your copyright or if you are the legal representative to represent the copyright holder, you may send the takedown notice to our registered email address with the following information. These requests should only be submitted by the copyright owner or any agent authorized to act on the owner’s behalf. (We do not provide an offline method of reporting inappropriate content)

  • ① The signature of the copyright holder or the copyright holder’s legal representative;
  • ② Materials which prove that the person is the copyright holder (or a description of your work that you believe has been infringed);
  • ③ Each allegedly infringing specific URL on Webtoon (including Challenge League);
  • ④ The contact information of the copyright holder or legal representative (address, phone number, email address);
  • ⑤ Include the statements: “I have a good faith belief that the use of the material in the manner complained of is not authorized by the copyright owner, its agent, or the law”; and
  • ⑥ Include the statement: “The information in this notification is accurate, and under penalty of perjury, I am the owner, or an agent authorized to act on behalf of the owner, of an exclusive right that is allegedly infringed”, and “The contents of the copyright violation report are true, and that the reporter of the violation has received permission from the copyright holder to report the violation on their behalf.”

The Company takes the following measures when we receive a takedown notice as indicated above.

  • ① The Company immediately takes down the User Posting at issue;
  • ② The Company notifies the user who posted such User Posting; and
  • ③ If the Company does not receive a response from such user within 14 days, we continue suspending the display of the User Posting and ultimately delete it.

10. Termination

Your rights under this Agreement will automatically terminate if you fail to comply with any term of this Agreement or any of your activities related to the Service or your User Translation violate public order and social ethics. The Company reserves the right to decide whether User Translation or users’ activities violate these Terms of Use for reasons other than copyright infringement, such as, but not limited to, pornography, obscenity, or excessive length. The Company may any time without prior notice and in its sole discretion, remove such Content and/or terminate a user’s account for submitting such material in violation of these Terms of Use. In case of such termination, you must cease all use of WEBTOON TRANSLATE Website. The Company's failure to exercise or enforce any term of this Agreement will not constitute a waiver of such term or any of the Company's rights or remedies.

If the Contributor wishes to terminate the account or delete User Translation, he or she may delete the account information in My Page or delete it in translation page. If the Contributor who failed to delete User Translation before deleting the account information wishes to withdraw User Translation from the Service, the Contributor may request the service operator to delete User Translation from the Service by contacting [dl_webtoontranslate@webtoonscorp.com].

11. Disclaimer of Warranties

USE OF WEBTOON TRANSLATE WEBSITEAND/OR DIGITAL CONTENT, AND SOFTWARE IS AT YOUR SOLE RISK. NO ORAL OR WRITTEN INFORMATION OR ADVICE GIVEN BY THE COMPANY OR AN AUTHORIZED REPRESENTATIVE OF THE COMPANY CREATES A WARRANTY, AND WEBTOON TRANSLATE WEBSITE, WEBTOON APP AND/OR DIGITAL CONTENT ARE PROVIDED "AS IS" WITH ALL FAULTS AND WITHOUT WARRANTY OF ANY KIND, AND THE COMPANY AND ITS LICENSORS DISCLAIM ALL WARRANTIES, EXPRESS, IMPLIED, OR STATUTORY, INCLUDING BUT NOT LIMITED TO, IMPLIED WARRANTIES OR CONDITIONS OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, ACCURACY, QUIET ENJOYMENT, SATISFACTORY QUALITY, NON-INFRINGEMENT OF THIRD-PARTY RIGHTS, AND THEIR EQUIVALENTS UNDER THE LAWS OF ANY JURISDICTION . THE COMPANY MAKES NO REPRESENTATIONS OR WARRANTIES THAT THE SERVICE OR YOUR ACCESS TO AND USE OF THE SERVICE WILL BE UNINTERRUPTED OR ERROR-FREE, FREE OF VIRUSES, MALICIOUS CODE, OR OTHER HARMFUL COMPONENTS, OR OTHERWISE SECURE. THE COMPANY IS NOT RESPONSIBLE FOR ANY DAMAGE TO YOUR MOBILE, TABLET, LAPTOP OR DESKTOP DEVICE, COMPUTER SYSTEM, OTHER HARDWARE, OR SOFTWARE, OR FOR ANY LOSS OF OR DAMAGE TO DATA THAT MAY RESULT FROM YOUR USE OF THE SERVICE.

12. Limitation of Liability

TO THE EXTENT NOT PROHIBITED BY LAW, THE COMPANY AND ITS LICENSORS AND AFFILIATES WILL NOT BE LIABLE TO YOU FOR ANY INCIDENTAL OR CONSEQUENTIAL DAMAGES FOR BREACH OF ANY EXPRESS OR IMPLIED WARRANTY, BREACH OF CONTRACT, NEGLIGENCE, STRICT LIABILITY, OR ANY OTHER LEGAL THEORY RELATED TO WEBTOON TRANSLATE WEBSITE, WEBTOON APP AND/OR DIGITAL CONTENT, SUCH AS ANY DAMAGES ARISING OUT OF LOSS OF PROFITS, REVENUE, DATA, OR USE OF WEBTOON TRANSLATE WEBSITE, WEBTOON APP AND/OR DIGITAL CONTENT OR ANY ASSOCIATED PRODUCT, EVEN IF THE COMPANY HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. USE OF WEBTOON TRANSLATE WEBSITE, AND/OR DIGITAL CONTENT, AND SOFTWARE IS AT YOUR SOLE RISK. FOR FREE OF CHARGE SERVICE, THE COMPANY AND ITS LICENSORS AND AFFILIATES WILL NOT BE LIABLE TO YOU FOR ANY DIRECT, INDIRECT, INCIDENTAL OR CONSEQUENTIAL DAMAGES OR LOSS INCORRED TO YOU. IN ANY CASE, THE COMPANY'S AND ITS AFFILIATES' AGGREGATE LIABILITY UNDER THIS AGREEMENT WITH RESPECT TO ANY CLAIM RELATING TO PURCHASE OF DIGITAL CONTENT IS LIMITED TO THE AMOUNT YOU ACTUALLY PAID FOR THAT DIGITAL CONTENT.

13. Indemnification

You agree to indemnify, defend, and hold harmless the Company and its affiliates against any losses, liabilities, claims, causes of action, and expenses (including, but not limited to, reasonable attorney’s fees and costs of investigation, whether before or after assertion of a formal claim, and reasonable litigation expenses) arising out of or relating to (i) your use of and access to the Service, (ii) your violation of any term of this Agreement, (iii) your violation of any third party right, including without limitation any copyright, property, or privacy right, or any claim that your User Translation caused damage to a third party, or (v) your violation of any applicable law or regulation.

14. Governing Law; Disputes

The laws of the Republic of Korea, without regard to principles of conflict of laws, will govern this Agreement and any dispute of any sort that might arise between you and the Company. You agree that any cause of action that may arise under this Agreement shall be commenced and be heard in the appropriate court in the Republic of Korea. You agree to submit to the personal and exclusive jurisdiction of the courts located within the Republic of Korea.

15. Complete Agreement and Severability

This is the entire agreement between us and you regarding WEBTOON TRANSLATE Website, and/or Digital Content and supersedes all prior understandings regarding such subject matter. If any term or condition of this Agreement is deemed invalid, void, or for any reason unenforceable, that part will be deemed severable and will not affect the validity and enforceability of any remaining term or condition.

16. Amendment

We may amend any of the terms of this Agreement in our sole discretion by posting the revised terms on WEBTOON TRANSLATE Website. Your continued use of WEBTOON TRANSLATE Website, and/or Digital Content after the effective date of any such amendment constitutes your agreement to be bound by such amendment.

17. Contact Information

For help with WEBTOON TRANSLATE Website, and/or Digital Content, please contact Customer Service by email to [dl_webtoontranslate@webtoonscorp.com].


This Agreement is effective from June 27, 2023 (effective immediately for new users).

If you are accessing from France (Français), Indonesia (Indonesia), Taiwan (中文(繁體)) Thailand(ภาษาไทย) respective regional Privacy Policy will apply.

WEBTOON™ PRIVACY POLICY HIGHLIGHTS

Last Updated: June 27, 2023

NAVER WEBTOON Ltd. (including its affiliates, 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 WEBTOON application and/or website, WEBTOON TRANSLATE and CANVAS (collectively “Services”).

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 exercise of 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 messages 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. Data Controllers
2. Information We Collect
3. How We Use the Information We Collect
4. Information Sharing
5. Retention of Personal Information
6. Your Rights
7. Exercising Your Rights and Your Choices
8. How We Protect Personal Information
9. Children’s Personal Information
10. Contact Us
11. Links to Other Websites
12. Updates to Our Privacy Policy
13. Regional Privacy Disclosures

WEBTOON™ PRIVACY POLICY

1. Data Controllers

NAVER WEBTOON Ltd. and WEBTOON Entertainment Inc. share joint controllership for processing personal information and share information as joint controllers of your personal information to provide Services efficiently and in compliance with applicable law.

In any event, you can contact us in writing at the following addresses:

NAVER WEBTOON Ltd.
TechONE Tower1 11-12F,
131, Bundangnaegok-ro, Bundang-gu,
Seongnam-si, Gyeonggi-do,
Republic of Korea.
or

WEBTOON Entertainment Inc.
5700 Wilshire Blvd Suite 220,
Los Angeles, CA 90036
United States

2. 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:
- Date of Birth: When you access our Services, we may request your date of birth to verify your age depending on your jurisdiction.
- Contact information: When a user is considered a child in accordance with applicable law in user’s jurisdiction, we may need the user’s name and legal guardian’s e-mail address to obtain legal guardian’s consent depending on your jurisdiction. Moreover, 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.
- Account information: When you create your own account and login to your account, we may need your nickname, email address and password. Additionally, when you login to a third party account or to your profile with us, we may ask for information such as nickname or profile picture.
- Survey information: 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.
- Image Information: When you choose to use toon filter, we may collect photos and gather information about the images, including identifying the objects and scenery that appear, as well as the presence and location of facial and body features and attributes within your photos. This information is not linked to your account and is soley used to enable the toon filter effect and detect inappropriate images. Please note that we do not use this information to identify specific individuals or for the purpose of training or improving our technology.
- Customer Care information: To provide responses when you contact our Customer Care, we may collect any information you choose to provide, such as your requests or inquiries. When you communicate with our Customer Care staff or others, your communications will be transmitted through our systems through your email address.
- Identifiers such as a unique personal identifier (such as (i) device identifiers (e.g., cookies, beacons, pixel tags), (ii) mobile ad identifiers and similar technology, (iii) customer number, unique pseudonym, or user alias, (iv) telephone number and other forms of persistent or probabilistic identifiers), online identifier, Internet Protocol address other similar identifiers.

[For Creators]

When you use CANVAS and/or AD REVENUE SHARING PROGRAM, we may need to collect the following additional information:
- Creator Profile information: We may request information that you have voluntarily shared with the public through your Creator Profile page, including your profile picture, bio, social media links, website and more.
- We may request that your PayPal ID or Patreon ID be linked to the Service.
- We may request your uTip ID to provide reward or bonus.
- AD Revenue Payment Information: If you choose to provide your PayPal account, we may ask for additional information such as your Name (Legal Name/Business Alias), Full name/Business Name, Country, Residency, Address, Postal code, E-mail, Signature and Tax ID (or Social Security Number when applicable) for tax processing purposes.

[For WEBTOON TRANSLATE Users]

When you use WEBTOON TRANSLATE, we may need to collect the following additional information:
- Profile information: We may collect information that you have voluntarily shared with the public through your profile page, including your profile picture, nickname, user site URL, location and language of your choice.
- Team manager application information: If you apply as a team manager, we may request your “My Profile” URL, the language of your choice and other translating experiences.

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 cookies 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 or through the Cookie Settings. 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

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 likes, 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 model, OS version, IP address, setting of devices, country information based on IP address, URL and network type; and
- Transaction /Purchase details: we do not collect or process any payment details concerning you (e.g., credit card details). Such information is only collected and processed through Apple’s App Store, Google Play Store, and PayPal. The only information that Apple, Google and PayPal may share with us is transaction and purchase details (e.g., transaction number, purchase history). Such information is only processed to validate the transactions.

Information collected through 3rd Party Analytics

- Through certain Services, we may collect personal information about your online activities on websites and connected devices over time and across third-party websites, devices, apps and other online features and services. We may use third-party analytics services on the Services. The information we obtain may be disclosed to or collected directly by these providers and other relevant third parties who use the information, for example, to evaluate use of the Services or help administer the Services.

3. How We Use the Information We Collect

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

[For Users and Creators]

- (i) Identify and authenticate you and (ii) administer your account
- Provide a Service or feature you request, such as to respond to your request, questions and instructions made through the Services;
- Conduct surveys and analyses necessary for improving the Service;
- Send you information and prizes for campaigns and events;
- Processing payment and billing when a user purchases a product or uses a Service that is not free;
- Provide you with tailored functions such as recommendation based on your most visited webpages and additional content tailored to your interests via the Interest tab;
- Send you communications via email or in-product notifications (e.g., pop-up notification, push notification) in relation to our Services as controlled by your communication preferences;
- 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;
- 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, our statutory obligations (e.g., tax laws), relevant industry standards and our policies, including this Privacy Policy;
- Validate transaction and prevent fraud and abuse;
- Respond to your inquiries and send users important notifications when necessary; and
- Carry out any other purpose described to you at the time the information was collected

[For Creators using CANVAS and/or AD REVENUE SHARING PROGRAM]

In addition to the above purposes, we may use the information collected on creators using CANVAS and/or AD REVENUE SHARING PROGRAM for the following additional purposes:
- Provide rewards, bonus or deliver prizes to survey participants, contest entrants or winners;
- Verify your identity to comply with applicable federal laws;
- Provide AD REVENUE SHARING PROGRAM to users;
- Send emails relevant to your work or usage, as controlled by your email preference;
- Reply to your questions;
- Understand how you use the Service and create better AD REVENUE SHARING PROGRAMs;
- Generate statistical data pertaining to usage of the Services;
- Conduct research and development to improve AD REVENUE SHARING PROGRAM and develop future products;
- Comply with and enforce applicable law requirements, our statutory obligations (e.g., tax laws), relevant industry standards and our policies, including this Privacy Policy; and
- Prevent fraud and abuse of AD REVENUE SHARING PROGRAM and prevent other criminal activity, claims and liabilities.

4. Information Sharing

NAVER WEBTOON Ltd. and WEBTOON Entertainment Inc. share information as joint controllers of your personal information whenever necessary to provide Services efficiently and in compliance with applicable law. We disclose or share personal information about you through the Services as described in the following:
- Publicly Available Information. 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, profile picture, short bio, social media links, website, other information on your public profile, and any information or content you share with a public audience.
- 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, advertising (including customized advertising on our websites, third-party websites, or online platforms), 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 information 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.
- Payment Partners. Payment and purchase information is collected and processed by payment partners for payment processing and anti-fraud purposes.
- Other Parties When Required by Law or as Necessary to Protect Our Services. 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 in the event of a bankruptcy.
- 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.
- Links to Other Websites, Devices, Apps and Features. The Service may provide the ability to connect to other 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.

5. Retention of Personal Information

We take appropriate steps to ensure that we process and retain information about you based on the following logic:
- at the minimum 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 information, we will securely delete or destroy it.
We will store the collected data even thereafter, until the expiration of any legal liability arising therefrom.

6. Your Rights

Your personal information belongs to you. Depending on the jurisdiction in which you reside, you can ask us to provide details about what we’ve collected, and you can ask us to correct any inaccuracies. The details of your rights are as follows:

Your right of access: you have the right to ask us whether or not we are using or storing your personal information. You can also ask us for copies of your personal information.
Your right to rectification: you have the right to ask us to rectify information you think is inaccurate. You also have the right to complete information you consider is incomplete.
Your right to erasure: you have the right to ask us to erase your personal information in the following circumstances: (i) we no longer need your personal information, (ii) you initially consented to the use of your personal information, but have now withdrawn your consent, (iii) you have objected to the use of your personal information and your interests outweigh those of our company, (iv) we have collected or used your personal information unlawfully, and/or (v) we have a legal obligation to erase your personal information.
Your right to restrict processing: you have the right to ask us to restrict the processing of your personal information in the following circumstances: (i) you have challenged the accuracy of your personal information, (ii) you have objected to the use of your personal information, (iii) we processed your personal information unlawfully without you wishing to delete it, and/or (iv) we no longer need your personal information but you wish us to keep it in order to defend or exercise legal claims.
Your right to object to processing: you have the right to object to the processing of your personal information if we are using your personal information for (i) a task carried out in the public interest, (ii) our legitimate interests, (iii) scientific or historical research or statistical purposes, or (iv) direct marketing.
Your right to data portability: this right applies to personal information you have provided to us and where the processing is automated, based on your consent or made under a contract. You have the right to ask us, if technically feasible, to transfer your personal information to another organisation or directly provide it to you in a way accessible and machine readable.
You also have the right to withdraw consent: at any time where the processing is based on your consent, without affecting the lawfulness of processing based on consent before such withdrawal.
You have the right to lodge a complaint before a supervisory authority: you can lodge a complaint with the relevant supervisory authority if you consider that our processing of your personal information infringes applicable law.

7. Exercising Your Rights and Your Choices

If you want to exercise the above rights or if you would like to submit your request, please contact us as specified in the Contact Us section (section 10 of this Privacy Policy). However, if permitted by law, we may charge you a small fee for providing you with this ability. Subject to applicable law, we may decline to process requests that are unreasonably repetitive, require disproportionate technical effort, jeopardize the privacy of others, or for which access is not otherwise required by local law.

You may access or correct your personal information registered with us at any time via the “Account” or “Creator Profile” page.

You may ask us to delete your personal information by deleting your account at any time. If you have any series published on CANVAS, you must delete them first to delete your account. Once you delete your account, your account profile and subscription history will be deleted permanently and become unrecoverable. Any tax information submitted to us will be maintained for a period of time, as required by financial laws and regulations.

If you would like to change your preference regarding our communications (including marketing communications), you can change your communication preferences from “Account” page or “Settings” page. You can also unsubscribe from our email marketing communications at any time by clicking the “unsubscribe” link on the bottom of the email.

You can manage the use of optional cookies by clicking on the “Cookie Settings” solution displayed when you open the application/visit the website and at any time through the Cookie Settings. To find out more on how we use the cookies collected, please refer to our Cookie Policy. You can also restrict or disable certain types of cookies by visiting https://www.allaboutcookies.org/ or https://optout.networkadvertising.org/?c=1.

8. How We Protect Personal Information

We take protection of your information seriously and maintain safeguards designed to protect the information we collect in connection with the Services. 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.

9. Children’s Personal Information

The Services are designed for a general audience. If the consent of the parent (or legal guardian) is required to process the child's personal information pursuant to the applicable law, we will process such information upon obtaining consent of the parent (or legal guardian) in accordance with the legally required process.

10. Contact Us

- If you have any questions, concerns or inquiries concerning the Policies for handling personal information, you may send them to our personal information management department at: Customer Care.
- You can contact us by sending an email to our Data Protection Officer (DPO) at the following address: dpo@webtoonscorp.com
- In any event, you can contact us in writing at the following addresses.

NAVER WEBTOON Ltd.
TechONE Tower1 11-12F,
131, Bundangnaegok-ro, Bundang-gu,
Seongnam-si, Gyeonggi-do,
Republic of Korea.

As NAVER WEBTOON Ltd. and WEBTOON Entertainment Inc. will take joint action whenever necessary to comply with your rights, requests or complaints, you can also contact us at WEBTOON Entertainment Inc.:

WEBTOON Entertainment Inc.
5700 Wilshire Blvd Suite 220,
Los Angeles, CA 90036
United States

11. Links to Other Websites

You may identify hyperlinks to access the websites of other organisations on our websites or in the content we provide to you (e.g., promotional email or events). Please note that this privacy policy does not cover how other companies will process your personal information. We recommend you to read the privacy policies applicable to such other websites.

12. 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.

This Privacy Policy is effective from – June 27, 2023 (effective immediately for new users).

13. Regional Privacy Disclosures

13.1 For U.S. Residents

This section supplements the WEBTOON 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.
- When a child is under 13 years of age, we collect the child's name and parent's e-mail address from the child that are necessary to provide any necessary notice and to obtain parental consent.

Children’s Personal Information
Users under the age of 13 are not the primary audience for our service as it relates to the COPPA compliance. We may ask you to provide age-related information in order to help us comply with data protection laws. In particular, we will request your date of birth to determine whether or not you are allowed to benefit from the services or if we have to obtain verifiable parental consent from your parent or relevant holder of parental responsibility before allowing you to access and/or benefit from the services. If parental consent from user’s parents or legal guardian is necessary, we will obtain such consent before processing personal information of children. To read about our privacy policy for children, please see the Children’s Privacy Policy.

13.2 For Consumers Residing in Certain U.S. States

This section supplements the WEBTOON Privacy Policy and applies to consumers who reside in jurisdictions where there is a privacy statute (excluding WEBTOON ENTERTAINMENT Inc. applicants and personnel).

A. Collection, Use, and Disclosure of Personal Information

(1) Categories of Personal Information We Collect: We may have collected the following categories of personal information about you in the last 12 months:
- Identifiers such as name, citizenship, residence address, 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 (including date of birth, contact information, account information, identifiers, survey information, customer care information, Creator Profile information, PayPal ID, Patreon ID, uTip ID, AD Revenue Payment Information, WEBTOON TRANSLATE Profile and team manager application information stipulated in section 2 above);
- Other identifying information, such as social security number, tax ID, tax form;
- Commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies (including transaction and purchase details stipulated in section 2 above);
- Internet and other electronic network activity information, including, but not limited to information regarding your interaction with websites, applications or advertisements (including information about your use of Services and information collected through 3rd Party Analytics stipulated in section 2 above);
- Sensory information including electronic, visual, or similar information;
- Biometric identifiers and biometric information: when you choose to use toon filter, we may collect biometric identifiers and biometric information as defined under certain U.S. state laws, such as image of face and features and attributes of your face and body to enable filter effect and detect inappropriate images. We do not use this information to identify specific individuals or for the purpose of training or improving our technology. Where required by law, we will seek your consent from you prior to any such collection; and
- 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: Depending on the state in which you reside, we may collect some sensitive personal information about you when you use the Services, such as social security number for tax purposes.

(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;
- Vendors who provide Services on our behalf;
- Advertising networks;
- Data analytics providers;
- Payment partners; and
- Social media networks.

(4) Business & 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 WEBTOON Privacy Policy):
- Performing Services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing targeted advertising or 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, short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of a consumer’s current interaction with the business;
- Helping to ensure the security and integrity of the Service;
- Debugging to identify and repair errors that impair existing intended functionality;
- 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;
- Payment partners;
- Social networks;
- Other users or creators;
- Professional services organizations, such as auditors and law firms;
- Ad networks and analytics providers; 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 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 (e.g., social security number), financial information, 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; and
- Inferences, which we share with our service providers, advertising partners, and other vendors to provide the Services.

We do have actual knowledge that we have sold personal information of consumers under the age of 16 only with consent.

(8) Categories of Personal Information Shared for Targeted Advertising & Third Parties: The categories of personal information that we have shared for targeting advertising include:
- 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; and
- Inferences, which we share with our service providers, advertising partners, and other vendors to provide the Services.

We do have actual knowledge that we have shared personal information of consumers under the age of 16 only with consent.

B. Consumer Rights

Depending on where you reside, and subject to applicable law and exceptions, you may be entitled to the following rights with respect to your personal information:

- Right to Know: Subject to applicable exceptions, 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:
o the categories and specific pieces of personal information we have collected about you; o the categories of sources from which we collected the personal information; o 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; and o the business or commercial purpose for which we collected or sold the personal information.
- Right to Data Portability: You may 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, subject to applicable law and exceptions, 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: Subject to applicable law and exceptions, you may have the right to correct or modify inaccurate personal information that we may have collected about you.

- Right to Delete: You may have the right to request that we delete the personal information we have collected from you, subject to applicable law and exceptions.

- Sale of Personal Information & Targeted Advertising: Depending on the state in which you reside, you may have the right to opt out of the sale of your personal information and targeted advertising. To opt out, please click "Do Not Sell or Share My Personal Information" or click the link on our homepage.

- 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 California Rights:
o 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. o 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 may 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 have the right to appeal a denial of your consumer rights request by Customer Care or email contact (dpo@webtoonscorp.com).

As noted above, we do not engage in profiling to make decisions that result in a legal or similarly significant effect based solely on automated processing of your personal information. All decision-making processes related to the processing purposes described above are carried out with human intervention.

Although some of the information that we may collect could be considered sensitive information under certain U.S. state privacy laws, we only use and disclose sensitive information for a subset of the purposes described above. For example, we may collect and process SSNs and information of citizenship for tax purposes.

C. Data Retention

We take appropriate steps to ensure that we process and retain information about you based on the following logic:
- at the minimum 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 information 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 information, 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 sending an email to the following address: DPO@webtoonscorp.com