Annexe. Informations supplémentaires sur la protection des renseignements personnels pour les utilisateurs de France

Annex. Additional Privacy Information for European Economic Area (EEA), United Kingdom (UK) and Switzerland Users

This Annex is part of and  supplements ZEPETO’s Privacy Policy and applies only to ZEPETO users residing in the territory of European Economic Area (EEA), United Kingdom (UK) and Switzerland.  In the event of a conflict between the terms of the Privacy Policy and this Annex, this Annex will prevail in relation to the processing of data relating to users in the EEA, UK or Switzerland.

Article 1 (How the Company Uses Information and the Types of Information Collected) 

The Company processes information provided directly/indirectly by user for the following purposes:

• Purpose : Provision of the Company’s services, as per your request
  • Categories of Personal Data
    • Identification and contact details;
    • Account information;
    • Social media account information (where you have linked your social media account to your ZEPETO account);
    • Registration history;
    • Purchase information.
  • Legal Basis : Contractual necessity
• Purpose : Provision of personalized functions and contents, such as targeted advertising services, analytics, or similar services, and monitoring your interactions with such features
  • Categories of Personal Data
    • Identification and contact details;
    • Account information;
    • Survey information;
    • Service usage information;
    • Device and log information;
    • Information related to your online activities on connected devices;
    • Payment information.
  • Legal Basis : Our legitimate interests to provide personalized services and analyze our services OR your consent where required by law.
• Purpose : Development, delivery, testing and improvement of the Company’s services, conducting internal research for product development, and undertaking activities to verify or maintain the quality or safety of the service
  • Categories of Personal Data
    • Identification and contact details;
    • Account information;
    • Survey information;
    • Service usage information;
    • Device and log information;
    • Information related to your online activities on connected devices;
    • Payment information.
  • Legal Basis : Our legitimate interests to improve our services OR your consent where required by law.
• Purpose : Payment processing for purchases and paid services
  • Categories of Personal Data
    • Identification and contact details;
    • Purchase information;
  • Legal Basis : Contractual necessity
• Purpose : Processing payments requested on ZEPETO Studio
  • Categories of Personal Data
    • Identification and contact details;
    • Payment information
  • Legal Basis : Contractual necessity
• Purpose : Promoting the Company’s goods or services, through emails or in-app notifications (push notifications, etc.) according to users’ communication settings 
  • Categories of Personal Data
    • Identification and contact details
  • Legal Basis : Our legitimate interests to promote our products and services OR your consent where required by law.
• Purpose : Provision of prizes or awards to event winners or participants
  • Categories of Personal Data
    • Identification and contact details;
    • Account information;
    • Social media account information (where relevant to the event);
    • Event information.
  • Legal Basis : Contractual necessity
• Purpose : User identification and authentication to enable use of specific services
  • Categories of Personal Data
    • Identification and contact details;
    • Account information;
    • Social media account information (where you have linked your social media account to your ZEPETO account).
  • Legal Basis : Contractual necessity
• Purpose : Provision of information about our services you request
  • Categories of Personal Data
    • Identification and contact details;
    • Customer service information.
  • Legal Basis : Contractual necessity
• Purpose : Response to your inquiries and provision of important notices to you
  • Categories of Personal Data
    • Identification and contact details;
    • Account information;
    • Social media account information (where you have linked your social media account to your ZEPETO account);
    • Customer service information.
  • Legal Basis : Depending on your inquiry or on the notice, contractual necessity OR our legitimate interests to grow our customer base or to defend our business in case of complaints
• Purpose : Protection, identification and prevention related to fraud and other unlawful conducts, complaint and various liabilities
  • Categories of Personal Data
    • Identification and contact details;
    • Account information;
    • Social media account information (where you have linked your social media account to your ZEPETO account);
    • Service usage information;
    • Device and log information.
  • Legal Basis : Our legitimate interests to secure our services OR compliance with applicable laws
• Purpose : Compliance with and enforcement of applicable industrial standards and company policies
  • Categories of Personal Data
    • Identification and contact details;
    • Account information;
    • Social media account information (where you have linked your social media account to your ZEPETO account);
    • Service usage information;
    • Device and log information.
  • Legal Basis : Our legitimate interests to conduct our business in accordance with appropriate standards (including to secure our services) 
• Purpose : Protection of the Company’s legal rights and interests
  • Categories of Personal Data
    • Any category of personal data identified in the Privacy Policy, as necessary to achieve this purpose.
  • Legal Basis : Our legitimate interests to protect our rights and interests 
• Purpose : Response to requests from government or legal authority
  • Categories of Personal Data
    • Any category of personal data identified in the Privacy Policy, as necessary to achieve this purpose.
  • Legal Basis : Compliance with an applicable legal requirement to cooperate with the relevant government or legal authority
• Purpose : Compliance with applicable laws and regulations in each country (e.g. tax laws)
  • Categories of Personal Data
    • Any category of personal data identified in the Privacy Policy, as necessary to achieve this purpose.
  • Legal Basis : Compliance with an applicable legal requirement
• Purpose : Additional purposes when you provide consent to process your information for those specific purposes
  • Categories of Personal Data
    • Any category of personal data identified in the Privacy Policy, as necessary to achieve this purpose.
  • Legal Basis : Your consent

Article 2 (International Transfer of Information)

As mentioned in Article 4 of the Privacy Policy, your use of the Service may involve the transfer, storage, and processing of your personal information to/in recipient in countries outside of your country of residence  (“third countries”). Such countries may potentially be located worldwide and include, without limitation, the United States, Japan, and Republic of Korea . We will take appropriate measures, in compliance with applicable law, to ensure that your personal information remains protected. Such measures include, if the recipient is located in a country that does not provide for an adequate level of protection of personal information (see sentence on third countries that are recognized as “adequate” below), , the use of the European Commission Standard Contractual Clauses and, where applicable, the UK Addendum and the adaptations required for Switzerland to  such clauses  to safeguard the transfer of personal data to third countries. We may occasionally  rely  on your explicit consent instead. Additionally, the European Commission, the Swiss Federal Council and the UK Government recognize, as applicable, that certain third countries ensure an adequate level of protection for personal information — this is known as “adequacy ” .   To request more information about our international data transfers or obtain a copy of the contractual agreements or other safeguards in place, please contact us via e-mail z_service_privacy@naverz-corp.com

Article 3 (Your Rights) 

In accordance with applicable laws, you may have the right to request access to, rectification of, erasure, deletion and/or destruction, of and portability of your personal data, and to object to or request restriction of the processing or disclosure to third parties of your personal data.  Where we are processing your personal data based on your consent, you have the right to withdraw this consent at any time without affecting the lawfulness of the processing based on consent before its withdrawal.

You also have the right to opt out of processing for targeted advertising. NAVER Z collaborates with advertising networks and third parties who may use cookies, pixels, SDKs, and tracking technologies to collect information about your activities across different apps and services for targeted advertising purposes. You may opt out of certain types of targeted advertising by adjusting your settings or using the following resources:

• You can opt out of receiving some types of ads by managing your preferences at https://optout.aboutads.info/.
• You can opt out of processing for targeted advertising by clicking the external links below. 

You also have the right to lodge a complaint with your supervisory authority. 

• Contact details for all EU supervisory authorities can be found at https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.
• The Swiss Federal Data Protection and Information Commissioner can be contacted at https://www.edoeb.admin.ch/edoeb/en/home/deredoeb/kontakt.html.
• The UK’s Information Commissioner’s Office can be contacted at https://ico.org.uk/make-a-complaint/.

Where French data protection law is applicable, you also have the right to set guidelines for the retention and communication of your personal information after your death.

You can exercise your rights by contacting us using the contact details under Article 4 below.

Article 4 (European Data Protection Representative and Data Protection Officer (DPO))

- For the purpose of this Annex, the data controller is Naver Z Corporation, whose contact details are included under Article 9 of the Main Privacy Policy.  
- For users residing in the EU/EEA: You can contact us by sending an email to our European data protection representative at the following address: eu_representative@navercorp.com
- You can also contact us by sending an email to our Data Protection Officer (DPO) at the following address: NZ_DPO@naverz-corp.com 

Article 5 Updates

This Annex is an annex to and part of the ZEPETO Privacy Policy and may be updated by us in accordance with Article 10 of the ZEPETO Privacy Policy. This Annex is effective from 10.28. 2024.

Annex. Additional Privacy Information for U.S. Users