Privacy Policy

Welcome to SNOW, Inc. ("SNOW" "we," "us" or "our"). Our Privacy Policy explains how we and some of the companies we work with collect, use, share and protect information from and about you in relation to our mobile services ZEPETO app(“ZEPETO”), and Little Prince by ZEPETO(“Little Prince”), and any other services we provide (collectively, the “Service”).

By using our Service you understand and agree that we are providing a platform for you to post text, graphics, photos, videos or other materials (collectively referred to as "Content"), to the Service and to share Content publicly. This means that other users may search for, see, use, or share any of your Content that you make publicly available through the Service, consistent with the terms and conditions of this Privacy Policy and our Terms of Use.

This Privacy Policy contains the following sections:

- ZEPETO app Privacy Practices

- Little Prince by ZEPETO Privacy Practices

- SNOW, Inc. General Privacy Practices

[ZEPETO app Privacy Practices]

1. Information We collect

1) Information you directly provide us

- When you access ZEPETO with facebook account, we collect your facebook account's Public Profile (including your ID, user name and email address) and a specified friend list. We do not require that you provide us with your user profile (e.g., Real name, picture).

2) Information you provide us when you use our services

- Device Information. We collect information about your device, including the hardware model, operating system and version, unique device identifiers (including MAC address and IMEI), browser type and language, and mobile network information. We also collect certain device information that will help us diagnose problems in the (hopefully rare) event you experience any crash or other problem while using our Services. So, for example, if we detect a crash or other problematic event, we may collect the list of apps on your device and other information about your device’s performance at the time of the event for troubleshooting purposes.

Camera and Photos. ZEPETO requires us to collect images and other information from your device’s camera and photos. We’ll access your camera and photos only after you give us your consent.

Location Information. When you use our services we may collect information about your location. With your consent, we may also collect information about your precise location using methods that include GPS, wireless networks, cell towers, Wi-Fi access points, and other sensors, such as gyroscopes, accelerometers, and compasses.

- Face data. We use TrueDepth API to collect 'face blendshape information' of 'true depth camera' and synchronize with character. This information is used only to implement the 'mirror' feature, not stored on the server or shared with third parties.

3) Analytics information. We use third-party analytics tools to help us measure traffic and usage trends for the Service. These tools collect information sent by your device or our Service, including the web pages you visit, add-ons, and other information that assists us in improving the Service. We collect and use this analytics information with analytics information from other users so that it cannot reasonably be used to identify any particular individual User.

[Little Prince by ZEPETO Privacy Practices]

1. Information We collect

1) Information you directly provide us

- When you access ZEPETO with facebook account, we collect your facebook account's Public Profile (including your ID, user name and email address) and a specified friend list. We do not require that you provide us with your user profile (e.g., Real name, picture).

2) Information you provide us when you use our services

Face data. We use TrueDepth API to collect 'face blendshape information' of 'true depth camera' and synchronize with character. This information is used only to implement the 'mirror' feature, not stored on the server or shared with third parties.

[SNOW, Inc. General Privacy Practices]

1. How We Store Your Information

We store a minimum amount of information for use of the service, such as a Facebook Public Profile. We will use commercially reasonable safeguards and take reasonable steps to keep the information so that the information will not be accessible. By using the Services, you consent to the export or transfer of your information outside of your country of residence.

2. How We Use Information

We use the information we collect through our Service, where and as permitted by applicable law. We provide you with an amazing set of Services that we improve with the information we collect. But we do a lot more as well, such as:

- Provide and deliver the products, services, and functionality that you request, process transactions, and send you related information;

- Communicate with you. That means just what it says; we may send you marketing communications on behalf of us or other companies; respond to your comments and questions; provide customer service; and send you technical notices, security alerts, and other informational messages;

- Monitor and analyze trends and usage;

- Develop, improve, and refine products, services, and functionality;

- Personalize the Services by providing advertisements, content, or features that match user profiles or interests. For instance, when you set up an account we may pre-populate certain account information based on the information we collect about you from other users.

3. How We Share Information

We share the information that we collect through our Services pursuant to the Applicable law and your consent. Here’s the type of information we may share about you with others and how we do so:

- When other users view your profile, they will be able to view profile information, including your username and name.

- We may share information about you with service providers who perform services on our behalf.

- With respect to jointly offered Services or functionality or services offered separately by other companies through our Services, we may share information about you with business partners to provide the Services and functionality you request and to communicate with you about those Services;

- We may share information about you in response to legal process or a request for information if we believe disclosure is consistent with, or required by, any applicable law, rule, or regulation; to investigate or remedy potential violations of our user agreements or policies, or to protect the rights, property, and safety of us, our users, or others; or in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

- We may share information about you with your consent or at your direction, or as otherwise provided in this privacy policy.

The Services may also contain third-party links or be a co-branded or third-party-branded Service that’s being provided jointly with or by another company. By going to those links or by using a co-branded or third-party-branded Service, you may be providing personal information directly to the third party, us, or both. You acknowledge and agree that we are not responsible for how those third parties collect or use your information. We do not endorse or make any representations about third-party websites or services. As always, we encourage you to review the privacy policies of every third-party website or service that you visit or use, including those third parties you interact with through our Services.

4. How We Secure Your Information

We have put in place physical, electronic, and managerial procedures designed to safeguard, and to help prevent unauthorized access to, your information and to maintain data security. These safeguards take into account the sensitivity of the information that we collect, process and store and the current state of technology. Although we take appropriate measures to safeguard against unauthorized disclosures of information, the Internet and the services are not 100% secure so we cannot assure you that information we collect or store will be protected from all unauthorized access.

5. Children’s Privacy

SNOW Inc. respect the privacy of children under the terms of COPPA. We do not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to register for the Service. The Service and its content are not directed at children under the age of 13. In the event that we learn that we have collected personal information from a child under age 13 without parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us via this Contact Form.

6. Change to Our Privacy Policy

We may modify or update this Privacy Policy from time to time, so please review it periodically. We may provide you additional forms of notice of modifications or updates as appropriate under the circumstances. Your continued use of our Service after any modification to this Privacy Policy will constitute your acceptance of such modification.

7. Accessing and Deleting Your Information.

You may, under applicable law, have the right to access, correct, update or delete the personal information SNOW Inc. holds about you. In order to exercise your rights, to the extent permitted and required of SNOW Inc. under applicable law, please contact us at daewook.kim@snowcorp.com.

In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

8. Contact Us

If you have any questions or concerns regarding our privacy policies, please send us a message to https://web.snow.me/cs/voc, mail us at 5750 Wilshire Blvd Ste 640, Los Angeles, California, United States.

Effective: April 10, 2018

ZEPETO Privacy Policy (Effective: Feb 24, 2018 ~ 2018 ~ Apr 9, 20118)