Effective Date: July 2, 2020
2. WHAT INFORMATION DOES THE WEBSITE COLLECT?
2.1 User Submitted Personal Information
We collect personal information that you voluntarily provide to us, such as when you register for any type of account with the Website, when you indicate via electronic communication or otherwise a desire to obtain information about the Website or its services, when you participate in any activities on the Website (such as posting messages within the Website’s forums, rating, subscribing to, commenting upon, publishing or accessing e-comics, etc.) or by otherwise contacting or interacting with the Website. The personal information collected as a result of your use, visitation or access of the Website depends on the nature of your specific interactions with the Website.
In operating the Website, we may collect user-submitted or communicated information, including first and last names, postal addresses, zip codes, phone numbers, self-descriptions, email addresses, social media user names, gender identifications, photos, images, likenesses, dates of birth and other identifying information provided to us by users or otherwise made available by users on or through the Website. We further store your Website passwords along with related security information used for Website user authentication and to facilitate account access (i.e. hints, answers to security questions, etc.).
The Website may also collect data necessary to process payments in the event you make purchases from the Website, including your method of payment and the method’s corresponding identification numbers (i.e. credit card numbers), and any security code or other verification information associated with your method of payment. The Website’s payment processor stores all payment data. It is suggested that you review any privacy policies of any Website payment processor and, if you have any questions concerning the payment processor’s practices, to contact the payment processor directly.
Further, we may provide you with the ability to register for a Website account or to log in to the Website by using the account details of one of your preexisting social media accounts, such as Facebook, Tumblr, Twitter or other social media account. If you use your social media account, we may collect the information described in the section called "How Do We Handle Your Social Media Access?" below.
NHN does not guarantee the accuracy, completeness, suitability, or veracity of any personal information provided by or otherwise made available on or through the Website by you or others. However, all personal information that you provide on, to or through the Website must be true, complete and accurate, and you must notify NHN of any changes to the personal information you have previously provided or with respect to any inaccuracy therein.
2.2 Automatically Collected Or Logged Information
2.3 Information Collected By Mobile Applications
The Website may offer applications or programs allowing users to use, visit or access the Website or its services via a mobile device or otherwise. If you use any of the Website’s mobile applications, you may also be providing NHN with the following data:
- (1) A Physical Location. Any application might request access to and permission to track location-based information transmitted from your mobile or other device, on either a continuous or "during-use" basis, so that location-based services may be provided. The settings on your specific device will allow you to modify your location-based settings or permissions.
- (2) Access to Mobile Devices. Any application may request access and permission to certain features from your mobile or others devices, including your mobile device’s memory, software, hardware, storage, camera, contacts, microphone, reminders, sensors, SMS messages, Bluetooth, calendar, social media accounts, and any other mobile device functions or features. The settings on your specific device will allow you to modify permissions and access to your mobile device’s functions and features.
- (3) Pop-Up or Push Notifications. Any application may request to send you mobile notifications, alerts, or "push notifications" regarding the Website, your Website account, or any of the Website's mobile applications. If you wish to stop receiving these types of notifications, you will be able to turn them off in your device's settings.
- (4) Automatically Collected Information. Any application may automatically record and collect your device’s information. This information may include your mobile device identification number, the device model and manufacturer, the device’s operating system and settings, the device and its hardware and software version information, as well as the device’s IP address.
- (5) Social Media Access. If you choose to access any application using your social media account, where that option is available, the Website may gain access to your basic information saved on the social media account, including your name, email address, gender identification, date of birth, listed city location, profile picture URL, as well as other information which you may have chosen to make public through your social media account. We may also request access to other features of your social media account, such as the identities of your "friends," "check-ins," "likes," and other similar information associated with your social media account. You have discretion in what information is made available when you use your social media account to access any application.
2.4 Information Collected From Publicly Available Sources
We may obtain information about you from other sources outside of your use, visit or access of the Website, including through public databases, from our marketing partners, through social media platforms, and from any other third party where, with or to whom you have made available any information about yourself.
3. HOW IS YOUR INFORMATION USED?
We use personal information submitted to or collected through the Website for a variety of business activities, discussed below. In short, we may process your personal information for these reasons, in order to confirm or to act under any agreement made with you, to complete a task for which you have provided your consent, and/or to comply with our legal obligations. We may use the information we collect or receive for the following:
- 3.1 To transmit promotional and marketing materials to you. We and/or our third-party marketing affiliates may use any personal information you send to us for promotional or marketing purposes, and to send you information regarding the Website and/or its services, NHN's products or services, or any third party's products or services. You may "unsubscribe" from or opt-out of receiving these types of electronic communications as discussed below.
- 3.2 To provide account initiation and logon processes. We may request personal information in order to register and verify Website user accounts or identities. Should you choose to connect your account with us to a third party account (such as a third party social media account), we may use the information you permit us to collect from the third party administrators of that third party account to facilitate Website account creation and logon processes. Please review the section below called "How Do We Handle Your Social Media Access?" for further information.
- 3.3 To send Website administrative information to you. We may use your personal information to notify you with respect to the initiation of, verification of, or changes to your account, to notify you concerning changes to the Website's terms and conditions and other policies, and to provide you with information regarding Website products, services and new features.
- 3.4 To manage your purchases. We may use your information to complete and manage your purchases of and/or payments for services and/or products made on or through the Website.
- 3.5 To administer contests. The Website may offer you the ability to enter into promotions, contests or other opportunities. In order to participate, you may be prompted to submit information about yourself. This information will be used to verify user or participant identities and to contact participants. Also, the name or names of participants may be made available on or through the Website. Further, any named Website partners or co-sponsors may use this information collected to contact participants regarding goods or services they offer or to facilitate transactions. The Website may employ third-party service providers or websites, which may request or collect your information in order to facilitate entry into a promotion, contest or other type of opportunity. The collection of information by these third-party service providers or websites is subject to their privacy policies.
- 3.7 To request feedback. Your personal information may be used in order to solicit comments or feedback from you regarding the Website and/or its services.
- 3.8 To protect the Website and its security. Your information may be used to detect, deter, prevent or otherwise address violations of the law, fraud, potential or actual Website security breaches, to improve or assess Website security, or to address other technical issues related to the use, visitation or access of the Website.
- 3.9 To facilitate "user to user" and "user to Website" communications. We may use your information in order to enable your communications with other users of the Website and vice versa, as well as to enable your communications with the Website and/or NHN and vice versa.
- 3.11 To respond to requests of law enforcement and to prevent harm. NHN may use, without your consent, your personal information if it is believed that doing so is reasonably necessary to comply with a law or legal request (such as a court order or subpoena), or to protect the wellbeing of any person or property, or the protect any other party's rights.
- 3.12 For other valid Website business reasons. We may use your information for other business purposes, including data analysis of the Website, identifying usage trends of Website features, to assess the effectiveness of marketing or promotions and to evaluate and improve the Website, its services and marketing, as well as the user experience.
4. DO WE SHARE YOUR INFORMATION WITH THIRD PARTIES?
Your information may be shared with others in the following circumstances:
- 4.1 For legal compliance. We may disclose your information if legally compelled or required to do so, under either governmental order or applicable law, such as in response to a valid subpoena.
- 4.2 For the protection of the Website. We may disclose your information to others in the event it is reasonably necessary to investigate, prevent or enforce against actual or potential violations of Website policies, including the Terms-Of-Use Agreement and Copyright Policy, suspected fraud, situations involving actual or potential threats of bodily injury to another, and other illegal activities. We may also provide your information to others as evidence in any proceeding, including in litigation in which we are involved either as a named or third party.
- 4.3 For the needs of our vendors and other third-party service providers. NHN engages service providers to perform functions and provide basic services (such as hosting, data, customer service, technical support, marketing assistance, mailing assistance, storage security, delivery of services and reporting services) related to the operation of the Website. NHN may share your information with such service providers or their agents who perform services on our behalf and require access to such information to do the tasks for which they have been engaged.
- 4.4 For business transfers. As a going concern, NHN may, from time to time, buy and sell various properties and assets, including the Website. In the event all or a portion of the property or assets NHN owns or controls are sold, transferred or assigned to or acquired by another party, or in the event a portion of the property or assets of the Website is sold, transferred or assigned to or acquired by another party, the information from, about, regarding or concerning Website users, including your information, may be among the properties or assets sold, transferred, assigned or acquired.
- 4.7 For other Website users. What you post to the Website may be viewable by other users, and other users of the Website will have the ability to view descriptions of your activity, communicate with you within our Website, and view your Website profile. When you share personal information (for example, by posting comments, ratings, e-comics, contributions, or other content to the Website) or otherwise interact with public areas of the Website, any personal information posted may be viewed by the public and may be distributed outside the Website, in any territory, in perpetuity. Further, if you register to use the Website through a social media account (such as Facebook), your contacts on the social network might see your name, profile photo, and a description of your Website activity.
- 4.8 Through Offer Walls. A third-party hosted "offer wall" may be made available on or through the Website. This may allow third parties to offer you physical or digital items in return for your acceptance and completion of an advertisement offer. Offer walls may also appear in any of the Website’s mobile applications. They may also be displayed to you based on your specific geographic or demographic data. You will leave the Website platform if you click on an offer wall. An identifier, such as your user ID, will be shared with the offer wall provider.
- 5.1 Advertising Cookies. This type of cookie is placed on your computer or device by advertisers and ad servers to display advertisements to you. Advertising cookies allow advertisers and ad servers to gather information about your visits and use of the Website and other websites, change ads sent to a specific identified computer or device, and track the frequency at which an ad has been viewed and by what computer or device. These cookies are linked to a computer or device and do not reveal a person’s identity.
- 5.2 Analytics Cookies. An analytic cookie is a type of technology that monitors how users access the Website, and how they interact with and navigate through the Website. We may use these cookies to provide us with information concerning which Website features are working, and how we can improve the Website. Further, as discussed below, we use Google Analytics to collect statistical information regarding how the Website is used. This information is not personally identifiable.
- 5.3 Cookies Created by NHN. We may use our own cookies, which can be either permanent or temporary. These cookies may be necessary to the proper functioning of the Website and its features. Some of these cookies may be manually disabled in your browser. However, if these cookies are blocked or removed, the Website and its features may not work properly for the user.
- 5.4 Personalized Cookies. In order to identify repeat visitors of the Website, we may use personalization cookies. These types of cookies record your Website browsing history, the pages you have visited, and your settings and preferences at each visit to the Website.
- 5.5 Website Administration and Management Cookies. Cookies may be used to manage and administer, including to maintain your identity or session on, the Website. These types of cookies may keep you from being logged off from your account unintentionally and to ensure that any information you enter on a given Website page is maintained from page to page. These types of cookies cannot be separately turned off. They can be disabled through the disabling of all cookies through the settings in your browser.
- 5.7 Third Party Cookies. Third-party cookies may be placed on your computer or device when you visit the Website. These cookies allow the third parties to gather and track certain information about you. These cookies can be manually disabled in your browser. These third party services used by the Website include Google Analytics, Google AdSense and Google Adwords, discussed below. Google uses what is known as the "DoubleClick" cookie in the ads served on the websites of Google’s partners, such as websites displaying AdSense ads or participating in Google certified ad networks. When users visit a Google partner's website and either view or click on an ad, a cookie may be dropped on that end user's browser.
6. DOES THE WEBSITE USE ITEMS OTHER THAN COOKIES TO TRACK YOU?
Besides cookies, we may use web beacons, pixel tags, clear gifs, and different tracking technologies on the Website in order to customize the Website experience to your use thereof and to improve your use experience. A “web beacon,” “pixel tag,” or “clear gif” is a small object or image embedded in a web page or email. These objects are used to track the number of users who have visited a page, who have viewed emails, and to acquire other statistical data. These objects collect only a limited set of data, such as cookie numbers, time and date of page or email views, and descriptions of the page or email on which the objects reside. Web beacons, clear gifs and pixel tags cannot be declined. However, you can limit their function by controlling the cookies that interact with them through your web browser preferences.
7. WHAT HAPPENS IF YOU REFUSE TO ACCEPT COOKIES OR PROVIDE THE WEBSITE WITH INFORMATION?
Many Internet browsers are configured to automatically allow cookies. Conversely, your browser may allow you to bar, remove or reject cookies. If you choose to get rid of, bar or reject cookies, this may have an adverse effect on your use of the Website, its services, or your account.
Further, you may opt not to provide the Website with any facts about yourself or other requested information. However, any decision to refrain from providing the Website with information, or any decision to unsubscribe from an account, service, or content may restrict your ability to access, visit or use the Website, or features or functions of the Website.
8. DOES THE WEBSITE USE GOOGLE ANALYTICS?
Google Analytics offers a deactivation add-on for most browsers. This add-on may provide you with more control over what data Google can collect on websites you access. You can acquire information on how to install this add-on at the following link: https://tools.google.com/dlpage/gaoptout?hl=en. However, this browser deactivation add-on offered by Google Analytics does not prevent information from being transmitted to us or to other web analysis services we may engage. Google Analytics may also use web beacons or pixel gifs, along with cookies, to compile aggregated statistics and to analyze how the Website is used.
9. DOES THE WEBSITE USE GOOGLE ADWORDS?
10. DOES THE WEBSITE USE GOOGLE ADSENSE?
The Website makes use of Google AdSense, a third party marketing network service. Google AdSense utilizes cookies to ensure that the Website receives payments when Website users buy a product or service after clicking on a portal, link or ad banner displayed on the Website that ultimately took the user to the website or web page of a Google AdSense associated product or service provider.
11. HOW DO WE HANDLE YOUR SOCIAL MEDIA ACCESS?
The Website may also offer you the ability to register for an account or to log in to the Website by using one of your social media accounts (such as your Facebook, Google, or Twitter account logins). Should you choose to do this, we will obtain information about you from the particular social media provider corresponding to the social media account used. The information obtained from your social media provider will depend on the social media account used. However, the information obtained will likely include your first and last name, electronic mail address, “friends” or “following” lists, “likes,” “check-ins,” profile pictures, as well as other facts you have chosen to make public about yourself through the given social media provider. The Website’s ability or permission to access this social media account information may be managed through your particular social media account.
12. NOTICE REGARDING INTERNATIONAL USE.
This Website is intended solely for users residing in the United States. Further, the Website is not intended to offer any products or services to any person or in any location outside of the United States. If you are using the Website from regions with data collection and use laws that may differ from the law of the United States (such as, by way of example only, the European Union), then be advised that your personal information will be transferred to and stored in Japan, and by using, visiting or accessing the Website you are consenting to the transfer and storage of your personal information.
13. WHAT IS THE WEBSITE’S POLICY CONCERNING THIRD-PARTY WEBSITES?
14. HOW LONG DO WE KEEP YOUR INFORMATION?
When we have no ongoing or further legitimate business needs or legal requirements to process your personal information, we may either delete it, make it anonymous, or, if neither option is possible (because, for example, the information has been archived in backups), then we will properly store your personal information by isolating it from any further processing until its deletion becomes possible.
15. HOW IS INFORMATION KEPT SAFE?
No transmission over the Internet can be made completely secure, and no security measure is entirely invincible. NHN takes reasonable measures to protect data on the Website’s servers from destruction, disclosure, loss, misuse, unauthorized access, damage, or unauthorized alteration, taking into account the level of risk and the type of data at issue. However, NHN does not guarantee the security of any information you send to NHN or the Website or the security of the Website’s servers or databases. By using the Website, you assume all risk in connection with the information sent to or collected by the Website. You are also responsible for taking reasonable precautions on your own behalf to protect unauthorized access to any account you may have registered with the Website.
16. DO WE COLLECT INFORMATION FROM MINORS?
The Website is a general audience website. Neither NHN nor the Website knowingly collects data from any person under the age of 13 years. We do not knowingly solicit information from or market to children under the age of 13 years. By using the Website, you represent that you are at least 13 years of age or that you are the parent or guardian of the same and consent to such minor’s use of the Website. If we learn that personal information from users less than 13 years of age has been collected improperly, upon notice, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you are aware of any data we have collected from a child under 13 years of age, please contact us at: firstname.lastname@example.org
17. DO I HAVE ADDITIONAL PRIVACY RIGHTS AS A CALIFORNIA RESIDENT?
Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), natural persons who are California residents have certain rights concerning their personal information held by us, as described below:
- 17.1 Right to Know About Personal Information Collected, Disclosed, or Sold. You have the right to request that we disclose what personal information we collect, use, disclose, and sell. You may submit a consumer request to know this information by contacting us at email@example.com. In order to verify your request, we will ask you to provide your name, email address, and certain other information for identification and authentication. Once you have submitted this information and any necessary supporting documentation, we will confirm the information by reviewing it against our records.
We indicate below (i) the categories of personal information (as defined in the CCPA) we may collect about you; (ii) the categories of sources from which that information is collected; (iii) the business and/or commercial purposes for collecting that information; and (iv) the categories of third parties to whom that information is disclosed.
Categories of Personal Information
- • Personal identifiers: name; alias; telephone number; email address; postal address; account name; online identifier; device identifier; IP address.
- • Characteristics of protected classifications: date of birth/age; gender.
- • Commercial information: records of personal property; products and service purchased, obtained or considered; purchasing or consuming histories or tendencies.
- • Internet or network activity information: browsing history, search history, information regarding your interaction with a website, application or advertisement.
- • Geolocation data: any information used to identify your physical location.
- • Communications, recordings, images: audio, electronic, visual.
- • Inferences: any derivation of information, data, assumptions, or conclusions drawn from any of the above categories used to create a profile reflecting the consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Categories of Sources from Which We Collect Personal Information
- • When you provide it to us (e.g., when you register with the Website, contact us via email or telephone, or by any other means)
- • Information that you manifestly choose to make public, including via social media (e.g., we may collect information from your social media profile(s), to the extent that you choose to make your profile publicly visible).
- • From third parties who provide it to us (e.g., our partners, third-party vendors or co-sponsors of programs).
- • When you use, visit or access the Website or use any features or resources available on or through the Website. When you visit our Website, your device and browser may automatically disclose certain information (such as device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connecting to the Website and other technical communications information), some of which may constitute personal information.
Business or Commercial Purposes for Use of Personal Information
- • Marketing/prospecting: communicating with you via any means (including via email or social media) subject to ensuring that such communications are provided to you in compliance with applicable law; and maintaining and updating your contact information where appropriate.
- • Services operation: operation and management of the Website; providing content to you; displaying advertising and other information to you; and communicating and interacting with you via the Website.
- • IT operations: management of our communications systems; operation of IT security; and IT security audits.
- • Research: conducting market or customer satisfaction research; and engaging with you for the purposes of obtaining your views on our products and services.
- • Security: including login records and access details, where you access our electronic systems.
- • Investigations: detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law.
- • Legal compliance: compliance with our legal and regulatory obligations under applicable law.
- • Legal proceedings: establishing, exercising and defending legal rights.
- • Improving our products and services: identifying issues with existing products and services; planning improvements to existing products and services; and creating new products and services.
- • Risk Management: audit, compliance, controls and other risk management.
- • Fraud prevention: detecting, preventing and investigating fraud.
Categories of Third Parties to Whom Personal Information is Disclosed
- • Third party service providers (such as payment processors)
- • Governmental, legal, regulatory, or other similar authorities and/or local government agencies, upon request or where required
- • Anti-fraud services
- • Accountants, auditors, financial advisors, lawyers and other outside professional advisors, subject to confidentiality
- • Data aggregation services
- • Accreditation bodies
- • Any relevant third-party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation)
- 17.2 Right to Request Deletion of Personal Information. You have the right to request the deletion of your personal information collected or maintained by us. You may submit a consumer request to delete this information by contacting us at firstname.lastname@example.org. In order to verify your request, we will ask you to provide your name, email address, and certain other pieces of identifying information. Once you have submitted this information and any necessary supporting documentation, we will confirm the information by reviewing it against our internal records and/or third-party databases. Deletion of certain personal information may restrict your ability to use, visit or access the Website, or features or functions of the Website.
- 17.3 Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights. You have the right not to receive discriminatory treatment by us for exercising the privacy rights granted by the CCPA. We do not and will not sell personal information of any consumer (including personal information of minors under 13 years of age).
In order to exercise the rights described above, you may designate an authorized agent to make a request under the CCPA on your behalf.
18. CAN I REMOVE PERSONAL INFORMATION FROM THE WEBSITE?
You may notify NHN at any time that you wish to end NHN’s storage of your personal information, and upon receipt of that notice NHN will remove all information about you from NHN’s database. If you request the removal of personal information you will no longer be able to access any part of the Website or NHN’s services that require personal information or registration unless you provide us with the information or register again. Any information or content that you have posted to public areas of the Website may remain irrespective of the status of your user account, personal information, or your request to delete personal information, including, but not limited to in the event you have posted personal information on publicly available parts of the Website. The deletion of your personal information from NHN’s database may not cause the removal of any content you may have previously posted, uploaded or otherwise made publicly available on or through to the Website.
19. CAN YOU REVIEW OR CORRECT PERSONAL INFORMATION?
Users who have provided personal information on or through the Website may request to review and/or correct this information by sending us an email or by logging into their user account and changing any information therein, where applicable.
20. CAN I OPT OUT OF RECEIVING ELECTRONIC COMMUNICATIONS?
Any user who wants to stop receiving electronic newsletters, marketing materials, promotions, offers or other correspondence from the Website may opt out of the Website’s email list at any time by following the “Unsubscribe” instructions contained in any email from NHN, or by sending an email from the account you wish to unsubscribe with the word “Unsubscribe” in the subject line to NHN at email@example.com.
21. HOW DOES THE WEBSITE RESPOND TO “DO NOT TRACK” OR “DNT” SIGNALS?
The Website does not respond to “DNT” or “Do Not Track” signals. We are awaiting the results of efforts by the policy community and the relevant industry to determine when such a response to “DNT” or “Do Not Track” signals will be appropriate and what form they should take.
22. HOW WILL I KNOW IF THIS POLICY IS UPDATED?
23. HOW CAN YOU CONTACT US ABOUT THIS POLICY?
NHN GLOBAL, INC.
3530 WILSHIRE BLVD STE 1600
LOS ANGELES CA 90010