This page is the current Privacy Policy. To view the current Terms of Service, click here. Or view Privacy Policy archived revisions.
Privacy Policy
This Privacy Policy is effective from February 28, 2023. By using our Services, you consent to the practices set forth in this Privacy Policy which is incorporated into our Terms of Service.
Privacy Policy Statement
Introduction
Contents First, Inc. (including its application, Tappytoon, hereinafter together referred to as “Company”, “we”, “our” or “us”) respects your concerns about privacy. This Privacy Policy applies to the personal information we collect through the Tappytoon application (the “Service”).
For users in the California or the EU, please review our additional Regional Privacy Disclosures which give more detailed information on how your personal information is used, shared and your rights.
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 in the section labelled Your Choices. We also describe the measures we take to safeguard the information and tell you how to contact us about our privacy practices.
Please find below a summary of the key topics addressed in this Privacy Policy. For more detailed information on how we process your information, please click on the headings or continue to read below.
When we refer to “personal information” in this Privacy Policy, we mean information that relates to an identifiable individual. The following types of personal information are collected in connection with our Service:
Information You Provide Directly to Us or Third Parties
We may collect information directly from you or from other companies with whom you have relationship. For example:
- Registration information: When you create an account and register for or use our Service, you will provide us with information such as, your email address, nickname, and password.
- Third party logins: When you login with a third party account or to your profile with us, we may ask for information such as nickname or profile picture your social media account information.
- Customer Service information: When you contact our Customer Service, we may collect any information you choose to provide, such as your requestswhen you communicate with our Customer Service staff or other representatives, we will collect any information you provide to us, including the communication itself and your email address.
- Engagement information: We collect information you provide to us when you request or purchase services, or information from us, register with us (including when you link your profile on a thirdparty site or platform with your registration account), participate activities on our sites and applications, respond to guest surveys, or otherwise interact with us using one or more devices.
- Cookies: We collect information through a variety of technologies, such as cookies, Flash cookies, pixels, tags, software development kits, and Web beacons, including when you visit our applications or use our applications on thirdparty sites or platforms using one or more devices, whether or not you are logged in or registered. Please visit our Cookie Policy for further information and how to disable cookies and otherwise make choices with respect to such data collection.
- Device information: OS platform of your device, device information including type of device, brand, model and version of OS, IP address,((which may tell us your general location), geolocation information(city level information inferred from IP address), advertising identifier, device language, device time zone, version of application that you are using, locale country and language of the device, the location (country and city) where you log in, your purchase history in application store, available languages, device capability, bandwidth, network type, and traffic to and from our websites, error-reporting information, the time the error occurred, the feature being used and the state of the Application when the error occurred.
- Log information: Usage information, such as, URL, redirected URL, performance timing, referrer, network type, network info, charge status, ad block info, cookies and access history.)
- Location information: We will process your location or geographical information based on your consent or if permitted, where this is necessary to deliver the Service you have requested.
- Commercial and payment information: When you make purchases on the Services, your information related to the payment will be collected and used by a third-party payment service provider, including the App Stores, such as Google Play Store and Apple App Store. These payment service providers will operate independently from us, collect your payment details in connection with any purchases you make through the Services, such as the products you have purchased, your method of payment, order numbers, email and other billing information based on their own privacy notices or policies which we strongly suggest you review. To the extent any linked service is not owned or controlled by us, we are not responsible for its content, use or privacy practices.
- Third Party Analytics: Through certain Services, we may collect personal information about your online activities on websites and connected over time and across thirdparty websites, devices, apps and other online features and services. We may use thirdparty analytics services on the Services. 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.
- Third Party Marketing and Interest-based Advertising information: We may allow third party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such information we have collected with third party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-Services related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected by the Service facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer that we do not share your personally identifiable information with third party advertising partners, you may opt out of such sharing.
We process your personal information when it is necessary to offer our Services, ensure the integrity of our business and to meet our obligations. We summarize these below. If you are a Swiss, UK or EEA resident we recommend that you refer to our additional Regional Privacy Disclosures towards the end of this notice.
We process your personal information when this is necessary for the following purposes:
- 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 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 that you may use certain Services; and
- Respond to your inquiries and send users important notifications when necessary.
- To improve the Services, and to develop and offer new services;
- To provide information about various events and opportunities to participate in the events, and to provide advertising information;
- To protect against, identify, monitor and prevent fraud and other criminal activities, any other activities that may violate our Terms of Service or other applicable laws, or lead to claims or 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;
-Comply with and enforce requirements under applicable laws, relevant industry standards and our policies, including this Privacy Policy;
- Comply with court orders and subpoenas, and respond to legally binding requests from government, law enforcement agencies, public authorities and/or regulators;
-Protect our legal rights, including by handling complaints, obtaining legal advice and establishing, exercising or defending legal claims relating to us and our Service.
3. Sharing of Information
We may share your personal information with a third party outside our Service except in certain circumstances, including:
- Service Providers: We use other companies, agents or contractors ("Service Providers") to perform services on our behalf or to assist us with the provision of services to you. For example, we engage Service Providers to provide marketing, advertising, communications, security, infrastructure and IT services, to customize, personalize and optimize our service, to process credit card transactions or other payment methods, to provide customer service, to analyze and enhance data (including data about users' interactions with our service), and to process and administer consumer surveys. In the course of providing such services, these Service Providers will have access to your personal information. We do not authorize them to use or disclose your personal information except in connection with providing their services (which includes maintaining and improving their services).
- Business advisors: We may share, for example, your information with our lawyers, accountants, business consultants, insurers, and auditors, to the extent it is necessary for them to provide us with their services.
- Protection of Tappytoon and others: Tappytoon and its Service Providers may disclose and otherwise use your personal and other information where we or they reasonably believe such disclosure is needed to (a) satisfy any applicable law, regulation, legal process, or governmental request, (b) enforce applicable terms of use, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address illegal or suspected illegal activities (including payment fraud), security or technical issues, or (d) protect against harm to the rights, property or safety of Tappytoon, its users or the public, as required or permitted by law.
- Business transfers: In connection with any reorganization, restructuring, merger or sale, or other transfer of assets, we will transfer information, including personal information, provided that the receiving party agrees to respect your personal information in a manner that is consistent with our Privacy Policy.
- 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 notions 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 principles:
- at least for the duration for which the information is used to provide you with our service;
- as required under law, a contract, or with regard to our statutory obligations (e.g., tax laws); or
- only for as long as it 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.
- Where we process your information with your consent, we process the data until you ask us to stop and for a short period after this (to allow is to implement your requests). We may also keep a record of your requests in order to respect them in future.
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 Us section (section 12 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 Cookie Preferences at the bottom of the website homepage.
- Email
You can unsubscribe from our marketing communications at any time by clicking the “unsubscribe” link on the bottom of the email.
- Push Notifications
You can choose to receive mobile push notifications from us. On some device operating systems, you will be automatically enrolled in the notifications. If you subsequently decide you no longer wish to receive these notifications, you can use your mobile device's settings functionality to turn them off.
Please note that if you unsubscribe from our marketing communications, we will still send you service messages to provide you with necessary information in relation to your contract and the Service you use (for example, to update you on changes to our Terms of Service).
6. Your Information and Rights
You can request access to your personal information, or correct or update out-of-date or inaccurate personal information we hold about you. You may also request that we delete personal information that we hold about you.
To the extent provided by applicable laws, you can also ask us to restrict or limit the processing of your personal information, as well as to provide you with personal information that we have collected from you so that you may use it for your own purposes, and to ask us to share (port) this data to another controller.
In addition, to the extent provided by applicable law, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement).
You also may have the right under applicable law to object at any time to the use of your personal information for direct marketing purposes.
However, these rights may be limited. 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 you rights or to make an inquiry, use the contact details under the Contact Us section below. For California residents wishing to make a rights request, please see Section 11 below.
7. How We Protect Personal Information
We take the protection of your information seriously and we have in place safeguards designed to protect the information we collect through our Service. 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.
8. International Transfer of Information
Your use of our Service may 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. 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, in which case we take steps, as required under local law, to ensure that your personal information is adequately protected.
9. Updates to Our Privacy Policy
We reserve the right at our discretion to make changes to this Privacy Policy from time to time. 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 or regulatory requirements.
We will provide notice of any such changes (including when they will take effect) in accordance with law. Your continued use of the Service after any such updates take effect will constitute acknowledgement and (as applicable) acceptance of those changes. If you do not wish to acknowledge or accept any updates to this Privacy Policy, you may cancel your use of the Service. To see when this Privacy Policy was last updated, please see the top of this Privacy Policy.
10. Children’s Personal Information
Our services are restricted to users who are 16 years of age or older. We do not permit users under the age of 16 on our platform and we do not knowingly collect personal information from anyone under the age of 16.
If we learn that personal information of persons under the age of 16 has been collected on or through our Service, we will take appropriate steps to delete such information. If you are a parent or legal guardian of a minor under these respective age limits who has become our Service member, then please contact us at privacy[@]tappytoon.com to have the minor’s account terminated and personal information deleted.
11. Regional Privacy Disclosures
The following additional terms apply respectively to users in certain countries. In the event of any conflict between the following additional terms and the provisions of the main body of this Privacy Policy, the following terms shall prevail.
11.1 For California Consumers
This California section supplements the Tappytoon Privacy Policy and applies solely to consumers in California.
A. Collection and Disclosure
(1) Notice of Collection of Personal Information:
We collect these categories of personal information when you interact with us: identifiers/contact information, demographic information (such as gender and age), commercial information, Internet or other electronic network activity information, geolocation data, electronic, visual or similar information, and inferences drawn from the above.
We collect this information for the purposes described in Section 2 above.
(2) CCPA Mandatory Disclosures
We also provide the following disclosures for purposes of compliance with the CCPA:
- We collected the following categories of personal information in the last 12 months: identifiers/contact information, demographic information (such as gender and age), commercial information, Internet or other electronic network activity information, geolocation data, electronic, visual or similar information, and inferences drawn from the above.
- The sources of personal information from whom we collected are: directly from our users, thirdparty sites or platforms that you link with your registration account, analytics tools, social networks, advertising networks, and thirdparty services that update or supplement information we hold about you.
(3) We disclosed the following categories of personal information for a business purpose in the last 12 months: identifiers/contact information, demographic information (such as gender and age), commercial information, Internet or other electronic network activity information, geolocation data, electronic, visual or similar information, and inferences drawn from the above. We disclosed each category to third-party business partners and service providers, third-party sites or platforms such as social networking sites, and other third parties as described in the “Sharing of information” section of the Privacy Policy.
(4) We may also share any of the categories of personal information we collect to 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.
(5) As the term is defined by the CCPA, we “sold” the following categories of personal information in the last 12 months:
The business or commercial purposes of “selling” personal information is for third party companies to perform services on our behalf, such as marketing, advertising, and audience measurement.
We do not “sell” personal information of known minors under 16 years of age.
B. Your Rights
(1) Right to Access
If you are a California resident, you have the right to request, up to two times each year, access to categories and specific pieces of personal information about you that we collect, use, disclose, and sell.
(2) Right to Delete
If you are a California resident, you have the right to request that we delete personal information that we collect from you, subject to applicable legal exceptions.
(3) Right to Opt Out of Sale of Personal Information
If you are a California resident, you have the right to “Opt-Out” of the “sale” of your “personal information” to “third parties” (as those terms are defined in the CCPA).
(4) Right to Non-Discrimination
If you are a California resident, you have the right not to receive discriminatory treatment for the exercise of your privacy rights conferred by the CCPA
Making Access and Deletion Requests
To submit an access or deletion request, contact us as specified in the Contact Us section of this Privacy Policy. Before completing your request, we may need to verify your identity. We will send you a link to verify your email address and may request additional documentation or information solely for the purpose of verifying your identity.
Instructions for Authorized Agents Making Requests
You may also have an authorized agent, registered with the California Secretary of State, submit a request on your behalf. The agent should submit the request in accordance with the access and deletion instructions above or the “opt out” instructions below, in addition to submitting evidence that the agent has received written permission signed by the consumer to submit the request on the consumer’s behalf. When we receive such a request, we will process the request, consistent with our standard process for verifying consumer requests. If requests submitted are manifestly unfounded or excessive, in particular because of their repetitive character, we may charge a reasonable fee to comply with your request, to the extent permitted by applicable law.
Making Requests to “Opt Out” of the “Sale” of “Personal Information”
To submit a request to opt out of the sale of your personal information, you may visit our “Do Not Sell My Personal Information” Right page or send an email to privacy[@]tappytoon.com with the subject line “do not sell info.” You may also use an authorized agent to submit a request to opt out on your behalf if you provide the authorized agent signed written permission to do so (see above).
11.2. For Users Having Usual Residence in European Economic Area (EEA), UK or Switzerland
International Transfer of Personal Information
If you are a resident in the EEA (that is in the European Union and Iceland, Lichtenstein, Norway), UK or Switzerland, we will transfer your personal information to the United States to be held on our systems and shared with our Service Providers and Business advisors.
The European Commission, UK government and Swiss Government have not determined that the United States offers an adequate level of protection.
Where we share your data with recipients as described, we will take appropriate measures to ensure that your personal information remains adequately protected which we have explained below depending on where data is transferred from.
- Adequacy Decisions: We rely on decisions from the European Commission where they recognise that certain countries and territories outside of the European Economic Area, UK or Switzerland ensure an adequate level of protection for personal information. These decisions are referred to as “adequacy decisions”.
- Categories of Personal Information transferred: registration information, engagement information, log and customer support information, device and connection information, general location information, cookies, authentication, third party login, commercial and payment information.
- Standard Contractual Clauses: We utilize standard contractual clauses approved by the European Commission (and the equivalent standard contractual clauses for the UK, where appropriate) for transfers to the United States.
While transfers to countries that don't have an adequacy decision typically take place on the basis of the standard contractual clauses, in certain circumstances, transfers can also take place on the basis of exemptions provided for under data protection law. For example, sharing with law enforcement, in emergency situations where we learn that a person’s life is at risk.
To request more information or obtain a copy of the contractual agreements or other safeguards in place, use the contact details set out in the Contact Us section.
B. How We Use this Information – additional information
In this section, we set out the legal grounds on which we rely to process your personal information and under each legal ground, we explain the purposes for which we collect and use your personal information, and the categories of data used. (1) Provision of our service or products based on your contractual relationship with us
We collect, analyze and use your personal information when this is necessary under our contract with you, to:
-Provide a Service or feature you request, such as to respond to your request, questions and instructions made through Services.
To do this we use your
-Processing payment and billing when a user purchases a product or uses a Service which is not free;
-Identify and authenticate you so that you may use certain Services; and
-Respond to your inquiries and send users important notifications when necessary.
The legal basis for this processing in the EU/EEA is Article 6(1)(b) GDPR.
(2) Legitimate interests
We process, analyze and store personal information to the extent this is necessary to fulfil our legitimate interests (or those of third parties), which include our interests to:
-To protect against, identify, monitor and prevent fraud and other criminal activities, any other activities that may violate our Terms of Service or other applicable laws, or lead to claims or other liabilities;
-Conduct surveys and analyses necessary for improving the Service;
-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;
-To improve the Services, and to develop and offer new services;
-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 requirements under applicable laws, relevant industry standards and our policies, including this Privacy Policy;
Where we rely on our legitimate interests, we have carried out a balancing test to consider what the impact of the processing will be on individuals and to determine whether individuals‘ interests outweigh our interests in the processing taking place. You can obtain more information about this balancing test by using the contact details of this Privacy Policy.
The legal basis for this processing in the EU/EEA is Article 6(1)(f) GDPR.
(3) Your consent
We process and use your personal information in cases where we will rely on consent:
- To place cookies and use similar technologies in accordance with our Cookie Policy and the information provided to you when those technologies are used. For more information, see our Cookie Policy;
- To send you marketing communications (where this is required by law or where we otherwise elect to rely on consent);
- To provide you with customized advertisements of content, products and services that we think you would like, by analysing information relating to your use of the Service combined with various information that you provide to us by other means, for the purposes consistent with this Privacy Policy. This may involve delivering marketing via various channels including through, email, our websites or mobile applications or on third party platforms (including social media); and
- On other occasions where we ask you for consent, we will use the data for the purpose explained to you at that time. When we rely on your consent, you always have the right to withdraw your consent at any time. This will not affect the lawfulness of any processing we carried out before you withdrew your consent. To exercise this right, please see the “Your Rights” section.
The legal basis for this processing in the EU/EEA is Article 6(1)(a) GDPR.
(4) Legal Obligations
We process personal information to the extent this is necessary for us to:
- Comply with court orders and subpoenas, and respond to legally binding requests from government, law enforcement agencies, public authorities and/or regulators;
- Protect our legal rights, including by handling complaints, obtaining legal advice and establishing, exercising or defending legal claims relating to us and our Service.
Where we need your information to perform our contract with you or to comply with our legal obligations, you are required to provide this information to us. In other instances, you are not required to provide personal information, however, not doing so may impact the way you use our Service.
The legal basis for this processing in the EU/EEA is Article 6(1)(c) GDPR in conjunction with relevant EU/EEA or national legislation.
C. How We Share Your Personal Information
Your personal information will primarily be shared internally as needed for providing you access to our Services, providing customer support, making decisions about Service improvements, content development, and for other purposes as described in How We Use This Information.
Your personal data will be shared with companies providing services, such as technology services including hosting, maintenance, administration and analysis, as well as other agencies, under contract to Tappytoon to help us provide our Services. We have covered these recipients at Section 3 Sharing of Information [add hyperlink] above and explain below what information is shared with them.
Your personal data also will be shared with government authorities and/or law enforcement officials if mandated by law or if required for the protection of our legitimate interests in compliance with applicable laws.
In the event that a Tappytoon is sold or integrated with another business, your details may be disclosed to our advisers and any prospective purchaser's adviser and will be passed to the new owners of the business.
D. Automated-Decision-making
Automated decision-making, including profiling, referred to in Article 22 (1), (4) GDPR does not take place.
E. Your Rights
You have the right to ask Tappytoon for a copy of your personal data; to correct, delete or restrict processing of your personal data; and to obtain the personal data you provide in a structured, machine readable format. In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement) and object to receiving any direct marketing from us. Where we have asked for your consent, you may withdraw consent at any time. If you ask to withdraw your consent to Tappytoon processing your data, this will not affect any processing which has already taken place at that time.
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep. If you have unresolved concerns, you have the right to complain to a data protection authority. [In the EEA, this will be the Data Protection Authority where you are usually resident. In the UK, this will be the Information Commissioner.]
Where we collect personal data to administer a contract with you or to comply with our legal obligations, this is mandatory and we will not be able to manage our relationship without this information. In all other cases, provision of the requested personal data is optional, but this may affect your ability to participate in certain programs or systems, where the information is needed for those purposes.
F. How Long We Retain Your Personal Information
We will retain your personal data for as long as it is needed for the purposes for which we collected it. If your account or our service to you is terminated, whether by us under the Terms of Service or at your request, we will take steps to delete your personal data or store your personal data in an anonymized form for statistical purposes or for fulfilling our legal obligations subject to appropriate safeguards.
12. 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 First Example>Customer Service. For California residents, please refer to Section 11 above if you wish to exercise your rights under California law.
Chief Privacy Officer
Tappytoon has designated the person in charge of personal information protection as below for inquiries and complaints about personal information of users.
- Name: Ernest Woo
- Position: Chief Privacy Officer
- E-mail: privacy[@]tappytoon.com
You can also contact us in writing at the following address:
Tappytoon / Contents First, Inc.
6F, 211 Teheran-ro,
Yeoksam-dong, Gangnam-gu, Seoul, Korea