1. Introduction

This privacy policy (“Privacy Policy”) describes how Kakao Entertainment Corp. (“Kakao Entertainment Corp.”, “we”, “us”, or “our”) collect, uses and shares information about you; this Privacy Policy applies to your use of our (mobile/online) webtoon and novel platform (the “Platform”), contents, and all its related services to Kakao Entertainment Global Newsroom (hereinafter referred to collectively as the “Services”).

Note that our Terms of Service applies to this Privacy Policy. By accessing and using our services, you will be deemed to agree to this Privacy Policy. Please take a moment to read this Privacy Policy before you start to use our services. If you do not agree to this Privacy Policy, you should immediately discontinue access to or the use of our Services.

If you are resident of the EU/EEA, please take a look at Privacy Policy Addendum for GDPR.

If you are resident of California in the U.S.A., please take a look at Privacy Policy Addendum for CCPA.

2. How do we get the information about you?

We and our Service Providers (defined below) may directly collect your information via the Services. For example, we collect information when you perform the following activities:(The personal information collected and method of collecting personal information may differ slightly depending on the country in which the Service is provided).

• Creating an account of the Platform;
• Registering or connecting your existing Kakao Entertainment Global Newsroom account with social network services (“SNS”) such as Facebook, Google or Twitter;
• Registering or connecting your existing Kakao Entertainment Global Newsroom account with ”Apple ID”;
• Accessing our Services;
• Participating in any types of events organized by us through the Services;
• Participating in any types of surveys organized by us through the Services;
• Making any purchases through the Platform; 
• Contacting us via methods we provide; or
• Reporting illegal pirated content

3. What is Personal Information?

“Personal Information” is any information that identifies, relates to, or could reasonably be linked with you. 

4. What personal information do we collect?

A. Information you provide 

When you submit a report on illegal pirated content, you provide us with Personal Information such as your name and email address.

B. Information automatically collected

We may automatically collect certain information about you when you access or use our Services (“Usage Information”). Usage Information may include device identifier, operating system (OS), hardware version, device setting, device model, IP addresses, access recording, country information, language, browser, and other information about your use of the Services.

The methods that may be used on the Services to collect Usage Information include:

• Log Information: Data about your use of the Services, which is stored in log files
• Tracking Technologies: Information about your interaction with the Services or email including your browsing and activity behavior collected by cookies, web beacons, in-app tracking methods and other technologies now and hereafter developed (“Tracking Technologies”) 
  • Cookies: We may use cookies to provide customized Services for our users including guest users by identifying interests and preferences through analyzing frequency of access and visit time. You can disable cookies in your browser settings, but some parts of the Services may then not function properly. To find out more on how we use the cookies, please refer to our Cookie Policy. 
  • Web Beacons (“Tracking Pixel”): Web Beacons are small graphic images, also known as “internet tags” or “clear gifs”, embedded in web pages and email messages. Web Beacons may be used to count the number of visitors to the Services, to monitor how users navigate the Services, and to count content views. 
  • In-app Tracking Methods: There are a variety of tracking methods that may be included in our Platform and third-party Platform. These are not browser-based like cookies and cannot be controlled by browser settings. Some use device identifiers, or other identifiers such as “Ad IDs” to associate app user activities to a particular app and to track user activities across apps.
  • For details, please refer to our “Cookie Policy.”

C. Information from other sources

We may obtain information about you from other sources (as permitted by law) including Service Providers and third-party services and combine such information with information we have collected directly and/or automatically from you.

Following information is transferred to us when you register or link your existing account with your account from a third-party service provider (i.e. Apple) or SNS (i.e. Facebook, Google, Twitter): 

The name of the third-party service providers or SNS;

Name, username, email address, user identifier created by the third-party service providers or SNS, URL to the profile image.The URL to the profile image associated with your account is deleted upon reception by KaKao.

D. De-identified Personal Information

Personal information once “de-identified” is not subject to this Privacy Policy and we and our Supporting Company (defined below) may treat it as non-personal information and use it without obligation to you except prohibited by applicable law.

5. What do we do with the collected personal information?

We collect, use, process, share, and/or disclose your information for the following purposes:

• To provide the Services based on contractual relationship with you
  • to provide, operate, and maintain our Platform and Services;
  • to verify, operate, and process user identification for membership service(s) including your Kakao Entertainment Global Newsroom account;
  • to verify, operate, and process your purchases, transactions, and refunds;
  • to help you or your device register for our Services;
  • to operate our Platform and to analyze your activities;
  • to provide customized Services;
  • to suggest and operate promotional and event activities;
  • to troubleshoot any issues;
  • to monitor and analyze to improve Service performance quality;
  • to enhance confidentiality, integrity and availability of security;
  • to develop and improve operating environment for better Services;
  • to allow you to manage your Kakao Entertainment Global Newsroom account;
  • to conduct any other activities required to provide our Services; and/or
  • to receive reports of illegal pirated content
• To enforce the Terms of Service, Privacy Policy (including relevant Addendums), and other agreements with third parties
  • to detect, prevent, investigate, and report violations, unauthorized use of and/or abuse of Services, other agreements and/or suspected illegal activities;
  • to resolve any issues and claims in connection with you (including, but not limited to collecting/reviewing documents, having legal advice, and proceeding dispute resolution);
  • to store records of dispute settlements;
  • to protect the rights, privacy, safety, and property of us and our Service Providers; and/or
  • to enforce other policies and agreement 
  • To comply with legal requirements
  • to meet or comply with any applicable rules, laws, regulations, and/or guidelines established by any legal or regulatory authorities binding on us;
  • to support any criminal investigations in accordance with subpoena, court order or legal process for which we, our Service Providers, or you have legal liability; and/or
  • to support requests from government and/or investigative authorities inside and outside of the country of your residence 
• To perform customers services
  • to support customer inquiries and complaints given by (or purported to be given by) you or on your behalf and to carry out your instructions;
  • to notify you of administrative and other important information regarding the Services and to contact you when necessary; and/or
  • to otherwise render customer support and services to you 
• To promote services, events, and products
  • to send various types of communications for promotional and marketing purposes; and/or
  • to deliver targeted marketing and promotional offers 
• We may use and process your information for additional purposes under the following conditions: 
  • additional purposes are disclosed to you before your information is collected for such purposes; and/or
  • you consent to collecting/using/processing/disclosing for the additional purposes 

6. When and with whom is the personal information shared, disclosed, and provided?

In principle, we do not share your personal information with external parties.

However, we may share and provide your personal information with but not limited to our agents, vendors, and consultants (“Support Company”) of Kakao Entertainment Global Newsroom as well as companies that provide the Services on behalf (“Service Providers”) of Kakao Entertainment Global Newsroom in the following cases:

• With your consent
  • We may share your information with external parties when you obtain consent from you or with your direction
• With Service Providers (and affiliate companies) for the following processes:
  • Billing and payment processes;
  • Data storage and development; and/or
  • Administrative services and other third-party services required to provide the Services
• With affiliated companies, group companies, and/or subsidiaries for following processes on behalf of us:
  • Personalizing content and experience; and/or
  • Offering promotions and events for our products and services or third-party’s products and services
• With law enforcement and appropriate third parties for legal reasons
  • to investigate criminals, fraud, infringement of intellectual property rights, or other suspected illegal activities, or as otherwise may be required by applicable laws, or as we deem necessary in our sole discretion, in order to protect our legitimate legal and business interests.
• Corporate restructuring
  • We may share Personal Information when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.

Except as disclosed in this Privacy Policy, we DO NOT sell, trade, rent any personal information we collect online (or mobile) unless we have your explicit permission.

7. How long do we retain the personal information?

We may process and store your information in accordance with following conditions:

• while you are using our Platform (while your account is alive, not closed and deleted);
• as required under law, regulations, contracts or statutory obligations; and/or
• only for as long as your information is necessary for the purposes described in the Privacy Policy.

8. When and how is the information deleted?

We will put in place measures such that your personal information in our possession or under our control is deleted in an irreversible format and/or de-identified as soon as it is reasonable to assume that (1) the purpose for which that personal information was collected is no longer being served by the retention of such personal information; and (2) retention is no longer necessary for any other legal or business purposes.

If any personal information is to be retained as required by relevant laws and regulations, we retain it for the period as required by such laws and regulations before destruction. The personal information which is stored and managed by us will not be used for purposes not authorized by law or by you.

However, some information you have shared with others on the Platform may, and will likely, remain visible after you close your account such as comments, message board postings, and communications you have with other users of the Platform and certain submissions. In the case of Reporting Illegal Content, the submission is and will not be made public. Nonetheless, please contact Kakao Entertainment Global Newsroom at privacy@kakaoent.com and Kakao Entertainment Global Newsroom, in Kakao Entertainment’s sole and reasonable discretion, may assist you in deleting such content, and shall timely do so wherever and to the extent legally obligated.

9. Personal information of children

Kakao Entertainment is very sensitive to this issue of children’s privacy and, therefore, we endeavor to protect the privacy of children using the Internet and our Services.

We do not intentionally collect, process, use, share, and disclose information about users who are legally defined as minors (hereinafter referred as “Child” or “Children”) based on the laws in jurisdiction.

Parents or legal guardians should supervise their Children when they participate in online(mobile) activities.

10. Do we transfer your information abroad?

While you use our Services, your information may be transferred, stored, and processed within and outside of your country of residence in accordance with this Privacy Policy.

Information that you provide to us will be stored in our IT infrastructure located in the Republic of Korea (“Korea”). We make an effort to implement appropriate technical, physical, and administrative safeguards to protect the privacy and security of your information and to use it only consistent with your relationship with us and terms described in this Privacy Policy. In addition, we enter into service agreements and relevant clauses with our Service Providers whenever feasible and appropriate.

11. What type of security measures have been implemented to protect personal information?

We take personal information very seriously and make reasonable efforts to prevent loss, theft, leakage, unauthorized alteration, and deletion of personal information through implementing appropriate physical, technical, administrative security measures as below (but not limited to):

• Access control (including secure password policy);
• Pseudonymization and encryption of personal information;
• Installation of anti-virus software and firewall; and/or
• Managing and monitoring of event logs for accountability

12. What are your rights regarding your personal information?

You may exercise your rights regarding personal information as below:

• Right of access: You may ask us to provide copies of your personal information, including how we collect, store, use, process, share, and/or disclose information about you. This rights always applies unless some exemptions exist.
• Right to rectification: You may contact us if you identify that your information in our possession is not accurate. You may ask us to rectify, update, and complete such inaccurate information.
• Right to erasure (right to be forgotten): You may ask us to delete your information collected, stored, processed, shared, and disclosed by us when certain circumstances are met.
• Right of restriction of processing: You may limit the way we collect, process, use, store, share, and disclose your information if you are concerned about how we use it.
• Right to data portability: This right only applies to the information you have directly given us. You may ask us to transfer such information in a usable format from one organization to an(other) organization(s), or give it to you.
• Right to object: You may ask us to stop processing your information when certain circumstances are met.

13. Changes to this Privacy Policy

We reserve the right to change, modify, add, or remove portions of this Privacy Policy at any time without notice to you in our sole and absolute discretion, and such new Privacy Policy will immediately take effect upon its posting on the Platform. We do not provide any other notices of such changes to this Privacy Policy. Please be advised that your use of the Platform means that you will be bound by the most current version of the Privacy Policy. We encourage you to check back frequently to review the latest version of the Privacy Policy, as it is your sole responsibility to be aware of any such changes to this Privacy Policy.

If you disagree with any changes to this Privacy Policy and do not wish your Personal Information to be subject to the revised Privacy Policy, please close your account and/or stop using the Services.

14. How to contact us regarding any inquiries, concerns, and complaints?

If you have any inquiries about your rights, please contact us at privacy@kakaoent.com

If you have any questions or comments regarding our Privacy Policy or wish to access personal information collected by us, please contact us at privacy@kakaoent.com

You can also contact us in writing at the following address:

KaKao Entertainment Corp.

F8 Twosun World Bldg., 221 Pangyoyeok-ro, Bundang-gu, Seongnam-si, Gyeonggi-do, Republic of Korea

15. Last modified

November 8, 2022