EFFECTIVE DATE: JANUARY 21, 2022
1. The Data We Process; Purposes of Processing
Depending on how you interact with us, we process different kinds of data and in different ways. Some data is automatically processed if you visit our Sites or use our Services. Other data is only processed if you actively submit it to us (like using our web forms to get in touch with us or uploading content to our Sites).
Data we process if you visit our websites:
Even if you are only a visitor on one of our Sites, your computer or device automatically sends technical information to our web servers that we store in log files, including the following “Website Usage Data”:
Date and time of the visit and the duration of use of the Site;
The IP address of your device as well as your internet service provider (ISP);
The referral/exit URL;
The visited subsites of the Site;
Clickstream data; and
Information about your device (type of device, browser type and version, as well as settings, installed plug-ins, operating system).
Data we process if you use our Services:
TOONIT processes Personal Data when you install and register one of our Services. Some of this information will be processed automatically when installing our Services. This includes the following “Product Installation Data”:
Your browser type;
Other software on your system;
Hardware or machine ID; and
For TOONIT’s registered user only, profile ID.
We may request the certain following “Product Registration Data” during registration of our Services:
Your profile picture;
Postal address, including country;
E-mail address and/or license key/serial number (necessary to validate your purchase).
Your date of birth
We use Product Installation Data and Product Registration Data to keep a record of your Services license (that is, authenticating and periodically verifying your licensing rights in the product for anti-piracy purposes) and to enable the provision of maintenance or support services to you. We will also use this information to provide in-product messaging with information about products, features, or services offered by TOONIT.
In addition, certain of our Services may allow you to store, send, receive, edit, sync, share, or otherwise organize or manage files and folders (including any information or data stored in those folders) (“User Files”). We will record and store information regarding the size and name of all User Files that you make available via the Services.
Data we process only if you submit it to us:
When you interact with us on our Sites or using our Services, you can submit Personal Data to us in various situations, including:
Account Data: On some of our Sites (“Interactive Sites”), you can register for an account with your e-mail address and a password you create. If you register one of our Services, you will automatically create an account you can use to manage your licensed Services and communication settings, including making updates to your Personal Data. On Interactive Sites, you can create a profile, which may include your Personal Data. We will store your account data for you to be able to communicate with others on our interactive Sites. Some of our Interactive Sites offer publicly accessible blogs or forums. Any information you provide in these areas may be read, collected, and used by others who access them with a registered account as well as anyone surfing the community pages as an unregistered user.
Transaction Data: In relation to purchases you may make online, we will process your contact and billing information, such as your name, address, and credit card information. You can view the exact information required in the form provided at point of purchase. We will only use this data to complete your order, for billing purposes, and for internal accounting.
Customer Support Data: You can communicate with us through the different web-forms and chat functionalities on our Sites. For example, you can use the contact forms to request technical assistance, request information on the status of your order including any online purchase, or otherwise reach out to our customer support team. In order to respond to your request, we will process your IP address and contact data as well as the contents of your request. We will delete this data as soon as we have complied with your request.
Survey Data: From time to time, we may conduct surveys in respect of our Services. Participation in our surveys is optional. However, if you respond to one of our surveys, you may provide us with personal information about you. Unless you otherwise consent, we will only use this information to determine the types of Services that may be of interest to you and to operate and improve our service offerings.
E-mail/Direct Mail Campaign Data: From time to time, we may contact our customers directly by mail, e-mail, or telephone to inform you about upgrades, new services, promotions, or special offers that you told us you were interested in receiving (including our newsletters). However, we will not contact you with any commercial communications that are unrelated to the Services that you have purchased from us unless you have given us your prior explicit consent to receiving such information. Please note that, where you have given us your consent to receive marketing communications, you are free to withdraw your consent to receiving such communications at any point in time. When responding to one of these campaigns, you may have the option to provide us with personal information, which we will use for the purpose indicated.
Applicant Data: If you would like to apply for employment with TOONIT, you can apply online at our careers page on our Sites. We will process your application data solely for the purpose of responding to your application. Your data will be deleted within two (2) years after finalizing your application, and in either case we may retain it indefinitely if you give us your explicit consent to keep your application on file to contact you with further job offers in the future.
Business Contact or Sales Prospect Data: If you are a business contact or sales prospect that has provided us your Personal Data, we will store your data in our database so that we can follow up on previous business conversations we’ve had with you, provide you additional information about our Services, or assist you in purchasing our Services. We may also share your Personal Data with sales representatives employed with our local affiliates or resellers so that they can work with you to complete any requested purchase of our Services.
2. Sharing Personal Data with Third Parties
Service Providers: TOONIT transmits data to service providers that enable us to provide our Sites and market, sell, and deliver our Services. This includes the parties providing our third-party cookies and tracking tools, as well as parties providing us with services to assist us in processing transactions, including credit card transactions, processing of orders, providing customer support, managing customer relationships (like Saleforce.com), hosting the Sites (like Amazon Web Services), collecting, storing, or removing your information, or performing statistical analysis of our Sites (such as Google). We occasionally also share Personal Data with independent auditors acting on our behalf, for anti-piracy or revenue accounting purposes in connection with the internal operations of our business. We sometimes need to share your information with these companies in order for them to provide the applicable services.
Document/File Hosting Providers: For user-initiated file and file link sharing and storage using e-mail, social media, instant messaging and cloud services, login information is requested. For user-initiated file sharing via e-mail, social media, and instant messaging, optional contact information can be requested and saved so that it can be accessed for future use by the customer. This data is not shared with third parties for any purpose. This information is only stored locally, on your PC or other computing device.
Public Authorities: Although we make every effort to preserve user privacy, we may need to disclose personal information when required by law, such as when we have a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order, or litigation or other legal process or action (whether or not initiated by TOONIT) to protect TOONIT’s, our users’ or third parties’ rights, property or safety. We will transmit data to public authorities such as law enforcement or tax authorities only in the case of a legal obligation to do so based on a request for information from the respective authority.
Promotional Offers: As a registered TOONIT user, you have the opportunity to receive news and special offers from TOONIT regarding our Services or the services of third parties who we think may offer services that would be of interest to you.
3. Timeframe for Keeping Data
4. Reviewing and Requesting Changes to Your Information
EU users: please refer to Section 5 below for your statutory rights under the GDPR
Customers may update, delete, access, or change their account information by editing their user records. To update a user profile, login to your account at www.TOONIT.com and click on “My Info,” where users can change their information including, but not limited to, personal information, billing information, subscription status, account status, and etc.
If you have signed up to receive marketing e-mails from TOONIT, you can opt-out of receiving future marketing emails by clicking on the “unsubscribe” option located at the bottom of the marketing e-mail you wish to opt out of. If you prefer to be removed from all TOONIT marketing lists, you can follow the foregoing process. Customers cannot opt-out of receiving all transactional emails related to their TOONIT account, but may change their account settings to reduce the frequency or eliminate certain TOONIT notification emails.
5. Information for EU Residents
Our Legal Basis for Processing:
Transferring your Data outside the EU or the EEA:
TOONIT’s principal place of business is in Republic of Korea, which is a “Third Country” under the GDPR. Third Countries are generally not considered to afford the same level of protection that you enjoy in the EU, but TOONIT still provides an adequate level of protection for your Personal Data - EU Commission states that Republic of Korea is deemed to provide an adequate level of data protection regarding commercial organizations such as TOONIT. We have ensured that our service providers and affiliates have been subjected to strict contractual provisions in their contract with us to guarantee that an adequate level of data protection for your data is guaranteed.
We use your data for “Profiling.” This means that we use your data to make tailored offers based on your previous behavior as well as to serve you personalized ads. However, we will never process and analyze your Personal Data in the context of Profiling in a way that would lead to an automated decision that has a legal effect on you or significantly impairs you in a similar way.
Your rights regarding the processing of your Personal Data:
As a natural person, you have certain rights as “Data Subject.” You can assert the following rights against us under the GDPR:
Your right to information and access under Article 15 GDPR;
Your right to rectification under Article 16 GDPR;
Your right to erasure under Article 17 GDPR;
Your right to restriction of processing under Article 18 GDPR; and
Your right to data portability under Article 20 GDPR.
In addition, you have a right of objection to the competent data protection supervisory authority under Article 77 of GDPR, but only with respect to the data processing we conduct on our own behalf, as a controller. In the event TOONIT acts as a processor of your data for a third party, you must refer to the entity acting as controller to assert this right. Please note that, where you have granted us your consent to process certain Personal Data, you are free to withdraw this declaration of consent with future effect at any point in time. This also applies to the withdrawal of declarations of consent issued to us prior to the validity of the GDPR.
Information about your Right of Objection under Article 21 of GDPR:
(a) Right of objection in individual cases
In addition to the rights aforementioned, you have the right, for reasons arising from your particular situation, to object at any time to the processing of Personal Data relating to you, which is processed on the basis of Article 6(1)(e) of GDPR (data processing in the public interest) and Article 6(1)(f) of GDPR (data processing on the basis of a balance of interests); this also applies to profiling based on this provision within the meaning of Article 4(4) of GDPR. If you file an objection, we will no longer process your Personal Data unless we can prove compelling grounds for the processing that outweigh your interests, rights and freedoms or the processing serves to assert, exercise, or defend legal claims. Please also note that, if we terminate the processing due to your objection, the Sites or Services may no longer be available to you or only to a limited extent.
(b) The right to object to the processing of data for advertising purposes
You also have the right to object at any time to the processing of your Personal Data for the purpose of direct marketing, including any subscription to our newsletters or personalized ads; this also applies to Profiling, insofar as it is associated with such direct marketing. If you object, we will no longer process your Personal Data in the future.
6. Information for California Residents
TOONIT does not sell consumer personal information for monetary or other valuable consideration.
Under the California Consumer Protection Act (“CCPA”), California residents are granted five consumer rights that TOONIT will uphold:
The right to know which personal information is being collected;
The right to know if personal data is being sold or shared, and to whom;
The right to object to the sale of personal data;
The right to access one's own personal information; and
The right to equal service and price, even for consumers who exercise their privacy rights.
Any Customer wishing to exercise a right to access personal information held by TOONIT must submit a verifiable consumer request to TOONIT by either:
E-mail to TOONIT at firstname.lastname@example.org
Call at 82-2-69494233
Please note that only an individual who is a resident of California (or the legal guardian of such individual in the case of a minor child) may make a request under the CCPA.
7. Collecting Information from Children
TOONIT’s Sites are not intended for use by children under the age of 16 and we do not intentionally collect any information from users under the age of 16. If a parent or guardian becomes aware that their child has provided TOONIT with Personal Data or that we have otherwise inadvertently collected this information, contact us at email@example.com, so that we may delete the information from our servers.
8. Contact Information
Suite 623, 123 Teheran-ro, Gangnam-gu, Seoul, Republic of Korea, 06133