Aitoon (Aitoon 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 Aitoon application and/or website 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 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 messages contained in our Privacy Policy. For more detailed information on how we process your information, WEBTOON™ PRIVACY POLICY 1. Information We Collect The following personal information is collected in connection with the Services: Information You Provide Directly Some Services enable you to give us information directly. For example: - When you create your own account and login to your account once created, we may need nickname, email address and password. - 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. - 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 Service staff or others, your communications will be transmitted through our systems through your email address. [For Creators] When you use CANVAS and/or AD REVENUE SHARING PROGRAM, we may need collect the following additional 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. 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 (such as search terms, and the apps and features you use), dates and times of use of the Services, any Service usage information collected through cookies. For more information about how we use cookies for our Service, please see our Cookie Policy; - 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, nation based on IP address, URL and network type; and - Transaction Data: We only process technical information that does not allow us to identify you (e.g. transaction number) 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, such as Google Analytics. 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. To learn more about Google Analytics, please visit https://www.google.com/policies/privacy/partners/. 2. How We Use the Information We Collect Provision of Services Based on Your Contractual Relationship With Us [For Users and Creators] - Provide a Service or feature you request, such as to respond to your request, questions and instructions made through 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 which 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; - Identify and authenticate you so you may use certain Services; and - Respond to your inquiries and send users important notifications when necessary. [For Creators using CANVAS and/or AD REVENUE SHARING PROGRAM] In addition to the above provision of services, we may use the information collected on creators using CANVAS and/or AD REVENUE SHARING PROGRAM for the following additional purposes: - Verify your identity to comply with applicable federal laws; - Provide AD REVENUE SHARING PROGRAM to users; - Send emails relevant to your usage, as controlled by your email preference; - Reply to your questions; - Understand how you use the Service and create better AD REVENUE SHARING PROGRAMs; - 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. Use of Information for Further Purpose - 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; and - Comply with and enforce applicable law requirements, relevant industry standards and our policies, including this Privacy Policy. 3. Information Sharing Aitoon Ltd. share information as joint controllers of your personal information whenever necessary to provide Services efficiently and in compliance with applicable law. We disclose personal information about you through 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, 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. - 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. 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. 5. Your Choices We offer you certain choices in connection with the personal information we obtain about you. To limit communications you receive from us, or submit a request, please contact us as specified in the Contact section (section 10 of this Privacy Policy). 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. You can unsubscribe from our email marketing communications at any time by clicking the “unsubscribe” link on the bottom of the email. 6. Your Rights 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. 6. 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. However, please note that although we take reasonable steps to protect your information, no website, Internet transmission, computer system, or wireless connection is completely secure. 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 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. 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. 9. 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 Support As Aitoon Ltd. will take joint action whenever necessary to comply with your rights, requests or complaints, you can also contact us at Aitoon Ltd.: Aitoon Ltd. 171, Gasan Digital 1-ro, Geumcheon-gu, Room 1513 of Gasan SK V1 Center, Seoul, South Korea 10. Children’s Personal Information The Services are designed for a general audience 11. For U.S. Residents This section supplements the Aitoon 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, but we may collect information from users under the age of 13 in the United States if we have the legal guardian’s consent consistent with the applicable laws. To read about our privacy policy for children, please see the Children’s Privacy Policy. Collection and Disclosure We may have: (1) 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; - Financial information, such as signature, bank account number, credit card number, debit card number, and other relevant financial information; - 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; - Sensory information including electronic, visual, or similar information; 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) 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; and - Social media networks. (3) Collected or sold personal information about you for the following business or commercial purposes (in addition to the purposes listed above in the Aitoon Privacy Policy) : - Performing Services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services; - Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, 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, the contextual customization of ads shown as part of the same interaction; - Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; - 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. (4) Shared 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; - Professional services organizations, such as auditors and law firms; and - Other third parties when you separately consent to or request such sharing. (5) We may also share 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) Sold the following categories of personal information about you: We may have sold advertising/marketing cookies to Google, Facebook, Twitter, Snapchat, Bing and TikTok in order to show you personalized advertisement based on your interactions with our Services when you visit such social media networks platform. - 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. - 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, predispositions, behavior, attitudes, intelligence, abilities and aptitudes. We do not knowingly sell the personal information of consumers at least 13 years of age and less than 16 years of age without prior authorization. We do not sell the personal information of consumers under the age of 13. (7) Disclosed for a business purpose the following categories of personal information about you: - Data Analytics Providers: Identifiers such as a unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements. This Privacy Policy is effective from December 03, 2021 (effective immediately for new users).