NAVER Corporation (“we”, “our” or “us”), Green Factory, 6 Buljeong-ro, Bundang-gu, Seongnam-si Gyeonggi-do, Republic of Korea, respect your concerns about privacy. This Privacy Notice applies to the personal information we collect through the Scholytics (the “Service”).
In this Privacy Notice, we describe the types of personal information we process through the Service, how we may use the information, how long we may keep the information, with whom we may share it and the choices available to you regarding use of the information and exercising your rights, including a right to object to some of the processing which we carry out (if provided by applicable law). More information about your rights, and how to exercise them, is set out in the “Your Rights” section We also tell you how to contact us about our privacy practices. Below you will find a summary of the key topics contained in our Privacy Notice. For more detailed information on how we process your information, please click on the headings or continue to read below.
Effective Date:May 11, 2021
The following personal information is collected in connection with the Service:
Information You Provide Directly The Company may collect the information directly provided by the users. The types of personal information that we collect directly from you depends on the content and features of the Service you use and how you otherwise interact with us and may include:
When a user signs up to Scholytics, Email address (ID), password, name, and job title (optional) are collected.
Information About Your Use of the Service In addition to the information you provide, we will collect information about your use of our Service through software on your devices and by other means. We will collect:
Device information: computer, device and connection information, such as IP address, browser type and version, operating system and other software installed on your device, unique device identifier and other technical identifiers, error reports and performance data;
Other information about your use of the Service, such as the features you used, your favorites, the settings you selected, URL click stream data, including date and time stamp and referring and exit pages, and pages you visited on the Service;
Other Information We Collect We may also collect other information about you, your devices, or your use of the Service with your consent or where required by law.
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.
Provision of services based on your contractual relationship with us
Member identification, confirmation of the user’s will to sign up, prevention of improper usage
Send contents, etc. to the users of paid services, or shipping / payment
Use of information for further purpose based on our legitimate interests
Develop new services, provide diverse services, resolve inquiries or complaints, and deliver notices
Prevention and sanction of any act that interrupts normal service operation of the service
Recommend customized contents based on demographic features, users' interest, taste and propensity, and utilized the foregoing information as marketing methods
Statistics based on service usage record, frequency of visit and service use; development of service environment to protect privacy; development of customized services; service improvement.
Protect against, identify and prevent fraud and other criminal activity, claims and other liabilities;
Monitor use of services and use your information to help us monitor, improve and protect our products, content, services and websites, both online and offline;
Where we rely on our legitimate interests, we have carried out a balancing test to document our interests, 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 at the end of the notice.
Use of information based on your consent:
On other occasions where we ask you for consent, we will use the data for
the purpose which we explain 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 below.
For purposes which are required by law:
Comply with and enforce applicable law requirements under applicable laws (e. g. tax and accounting obligations, obligations relating to consumer protection)
Comply with court order and subpoenas, and respond to legally binding requests from government, law enforcement agencies, public authorities and/or regulators.
Respond to requests from government or law enforcement
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.
We transfer or disclose personal information about you through the Service as described in the following:
NAVER affiliates, subsidiaries and personnel: We share personal information with our personnel, including contractors and agents, and other companies in our group, to the extent this is necessary to provide our Service and to fulfil the purposes set out in section 2 above.
Service Providers. We may transfer or disclose your information to carefully selected companies that provide services on behalf of us, such as companies that help us develop and operate systems for the service with customer contact centers, customer care activities that send emails on our behalf. These entities are limited by contractual provisions in their ability to use your information for purposes other than providing services for us. Our service providers may be located in the Republic of Korea.
Other Parties When Required by Law or as Necessary to Protect Our Service. There may be instances when we disclose your information to other parties:
to comply with the law or respond to compulsory legal process (such as a search warrant or other court order);.
to verify or enforce compliance with the policies governing our Service and to investigate fraud or other unlawful activity relating to the use of our Service or affecting our business to the extent that such disclosure is permitted by the applicable data protection laws; and
to protect the rights, property, or safety of us, or, in compliance with data protection laws, any of our respective affiliates, business partners, or customers.
Other Parties in Connection with Transactions. We may disclose your information to a third party as part of a merger or transfer, acquisition or sale, or in the event of a bankruptcy.
Other Parties with Your Consent or on Your Request. In addition to the disclosures described in this Privacy Notice, we may share information about you with third parties when you separately consent to or request such sharing.
We take appropriate steps to ensure that we process and retain information about you based on the following logic:
at least the duration for which the information is used to provide you with a service;
as required under law, a contract, or with regard to our statutory obligations (e.g., tax laws); or
only for as long as is necessary for the purpose for which it was collected, is processed, or longer if required under any contract, by applicable law, or, in anonymized form, for statistical purposes, subject to appropriate safeguards.
The Service may provide the ability to connect to other websites, devices, apps and other features, which may operate independently from us and may have their own privacy notices or policies. We strongly suggest you review them. 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.
We offer you certain choices in connection with the personal information we obtain about you. To limit communications you receive from us, or submit a request, please contact us as specified in the Contact section (section 11 of this Privacy Notice).
To the extent provided by applicable law, you can ask us to for a copy of the personal information we’ve collected, and you can ask us to delete it or correct any inaccuracies. You can also ask us to restrict or limit the processing of your personal information, as well as to provide to you your personal information that you provided to us for a contract or with your consent in a structured, machine readable format, 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 have the right to object at any time to the use of your personal information for direct marketing purposes, including profiling relating to direct marketing.
However, these rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in both the GDPR and in national laws. We will inform you of relevant exemptions we rely upon when responding to any request you make. To make a request concerning your rights or to make an inquiry, see the Contact Us section below.
We take protection of your information seriously and maintain safeguards designed to protect the information we collect in connection with the 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.
Your use of our Service will involve the transfer, storage, and processing of your personal information within and outside of your country of residence, consistent with this notice. In particular, your personal information will be transferred to the Republic of Korea. Please note that the data protection and other laws of countries to which your information may be transferred might not be as comprehensive as those in your country.
[For European Economic Area (EEA) Residents]
In addition, your use of the Service may also involve the transfer, storage, and processing of your personal information to other countries; such countries include, without limitation, South Korea. We will take appropriate measures, in compliance with applicable law, to ensure that your personal information remains protected. Such measures include for instance the use of the European Commission Standard Contractual Clauses to safeguard the transfer of information outside of the EEA and reliance on your explicit consent. To request more information or obtain a copy of the contractual agreements or other safeguards in place, please contact us. See the Contact Us section below.
This Privacy Notice may be updated to reflect changes in our personal information practices with respect to the Service, or changes in the applicable law. We will post a notice on our Service to notify you in advance of material changes to our Privacy Notice and indicate at the top of the notice when it was most was most recently updated.
To exercise these rights, or for further information about the manner in which we or our service providers treat your personal information, please contact us at [firstname.lastname@example.org] or via post [Green Factory , 6 Buljeong-ro, Bundang-gu, Seongnam-si Gyeonggi-do, Republic of Korea].
In addition, Data Protection Officer can be contacted [email@example.com].
You can also contact the competent data protection authority as the responsible supervisory authority.
[For European Economic Area (EEA) Residents Only]
If you are residing in the European Union, you can also contact our representative: :[NAVER FRANCE SAS. , Address: NAVER France, 89 rue Reaumur, 75002, Paris, France, Email: firstname.lastname@example.org].
The Service are designed for a general audience and are not directed to children.
[For US Residents Only]
In connection with the Service, we do not knowingly solicit or collect personal information from children under the age of 13. If we learn that we have collected personal information from a child under age 13, we will promptly delete that information. If you believe that a child under age 13 may have provided us with personal information, please contact us as specified in the Contact Us section of this Privacy Notice.