Children’s Privacy Policy (United States)

Effective Date: October 12, 2026

This Children’s Privacy Policy explains how NAVER WEBTOON Ltd. (“WEBTOON,” “we,” “us,” or “our”) collects, uses, discloses, and protects personal information from children under 13 in connection with (1) WEBTOON ACCOUNT (our account framework) and (2) the WEBTOON application and/or website (collectively, the “Services”). This policy is intended to comply with the U.S. Children’s Online Privacy Protection Act (“COPPA”) and the COPPA Rule. When we use the term "child" or "children," we mean an individual under 13 years of age. When we use the term "parent," we mean to include legal guardians.

1. Children are not our primary audience

Children under 13 are not the primary audience for the Services. However, children may use the Services only with valid verifiable parental consent where required by COPPA and other applicable law. If a child indicates they are under 13, we will request the child’s name and the parent’s email address as needed to provide notice and obtain verifiable parental consent before allowing the child to create or use an account or access features or content that involve collection, use, or disclosure of personal information where COPPA requires it.

2. Operator and contact information

Operator: NAVER WEBTOON Ltd. (including its affiliates)
Address: NAVER Green Factory 6-10F, 6, Buljeong-ro, Bundang-gu, Seongnam-si, Gyeonggi-do, Republic of Korea
Email: dpo@webtoon.com
U.S. contact (if applicable): WEBTOON Entertainment Inc., 222 N. Pacific Coast Highway, Suite 2300, El Segundo, CA 90245, United States

If you are a parent or legal guardian and want to exercise your rights under COPPA (review, delete, revoke consent), contact us using the information above.

3. What information we collect from children

Depending on how your child uses the Services, we may collect the following categories of personal information:

A. Information we collect from your child (account/identity layer)

- Child’s email address
- Child’s nickname
- Password (or authentication token if using a third-party sign-in provider)
- Date of birth (for age gating / eligibility)
- Parent’s email address and the child’s name when needed to provide notice and obtain verifiable parental consent
- Provider-specific user identifier and related authentication information if the child uses social sign-on, including information such as display name, email address and profile picture

B. Service usage and device information

- WEBTOON ACCOUNT Identifier (a unique, system-generated account identifier)
- Device identifiers and online identifiers (e.g., device ID, cookie IDs)
- Device and Log information such as device model, OS version, IP address, setting of devices, country information based on IP address, URL and network type;
- App/site usage information (e.g., pages viewed, reading history and recent views, reading genre preferences, Coin and Free Pass balances, subscription and download history, content interactions, and timestamp)
- Information relating to the organization of contests and/or any promotional operations: date of participation, responses to the contests, and nature of the prizes offered
- Records of coins, purchases, and transaction history (including technical transaction information such as a transaction number) We do not collect or process payment details (e.g., credit card details). Such information is collected and processed only through Apple’s App Store, Google Play Store, or PayPal, which may share transaction and purchase details with us solely to validate the transaction.
- Information your child provides when contacting customer support or participating in events (where available).

C. Cookies and similar technologies

- We use cookies and similar technologies on child accounts only as necessary to operate the Services — specifically for authentication, session management, security, fraud prevention, and analytics to maintain and improve the performance of the Services (support for the internal operations of the Services). We do not use cookies or similar technologies to "sell" or "share" personal information of child accounts (as defined under applicable US privacy laws), serve targeted or interest-based advertising to children, build advertising profiles, or track children across third-party websites, apps, or devices.

We do not require a child to provide more information than is reasonably necessary to participate in an activity.

Features not available to child accounts. The following features and processing activities described in the WEBTOON Service Privacy Policy are disabled for child accounts and do not apply to children under 13: publicly visible features (including comments), creator and monetization features (including CANVAS publishing, the Ad Revenue Sharing Program, and Super Like), targeted or interest-based advertising.

4. How we use children’s information

We use children’s information to:
- Create and manage the child’s account (single sign-on/account layer) and enable sign-in
- Provide WEBTOON features and content and process the child’s requests (including coins/content purchases where available)
- Verify region and provide an age-appropriate experience
- Send service-related and marketing notifications that your child can manage at any time
- Recommend and personalize content (we do not use your child's personal information for targeted advertising or to serve personalized advertising to your child)
- Maintain the security and integrity of our Services (fraud prevention, debugging, and system administration)
- Measure performance and improve our Services and develop new series
- Support internal operations of the Services (including authentication, account recovery, security monitoring, and abuse detection)
- Allow your child to participate in events
- Respond to your child's customer support requests and inquiries
- We may also use a parent's contact information to communicate with the parent regarding the child's activities on our Services.

5. When we share children’s information

We do not sell children's personal information, we do not share it for targeted advertising or cross-context behavioral advertising, and we do not disclose it to third parties for their own purposes. We do not make children's personal information publicly available: features that would display a child's information to other users, such as commenting and creator support, are disabled for child accounts. We share children's personal information only in the limited circumstances described below:

A. Sharing between NAVER WEBTOON Ltd. and WEBTOON Entertainment Inc.

NAVER WEBTOON Ltd. operates the Services, including the WEBTOON ACCOUNT layer, and is the operator responsible for children’s personal information collected through the Services. NAVER WEBTOON Ltd. and WEBTOON Entertainment Inc. act as joint controllers for personal information processed at the WEBTOON ACCOUNT layer under a joint controller agreement. They share your child's personal information with each other only as necessary for the purposes described in Section 4 (How we use children's information). No other affiliate receives your child's personal information for its own purposes. If your child seeks to use another service that uses a WEBTOON ACCOUNT, that service will provide its own children’s privacy policy and obtain separate verifiable parental consent before collecting personal information from your child.

B. Service providers

We may share information with vendors and service providers that perform functions for us (e.g., hosting, customer support tools, analytics for service performance/operations, security, content delivery, and identity/authentication support), and they are permitted to use the information only to provide services to us.

C. Legal and safety reasons

We may disclose information to comply with law, respond to lawful requests, protect our rights and users, and maintain the security and integrity of the Services.

D. Business transfers

If we are involved in a merger, acquisition, reorganization, or sale of assets, children's information may be transferred as part of that transaction, subject to applicable law. Any successor will be required to honor the commitments in this policy. If the successor's practices would materially change how children's personal information is collected, used, or disclosed, we (or the successor) will notify parents and obtain new verifiable parental consent as required by COPPA.

We do not allow third parties to collect personal information from children on the Services for their own purposes except as permitted by COPPA and as described in this policy.

6. Parental choices and controls

Parents/legal guardians have the right to:
- Review the personal information we have collected from their child
- Request deletion of their child’s personal information
- Refuse further collection or use of their child’s personal information
- Revoke consent

To exercise these rights, contact us at Customer Care. You may also contact our Data Protection Officer at dpo@webtoon.com. To protect children’s safety, we will request proof of your identity and may deny access if we cannot verify your identity. Please note that certain information cannot be deleted because of other legal obligations.

7. Verifiable parental consent (VPC)

Before we collect, use, or disclose personal information from a child in a manner requiring consent, we will obtain verifiable parental consent using a method permitted by COPPA.

If you do not provide consent within a reasonable time, we will delete the information collected for the purpose of obtaining consent.

8. Data retention

We keep children’s personal information only as long as reasonably necessary to fulfill the purposes described in this policy, comply with legal obligations, resolve disputes, and enforce our agreements. We do not retain children's personal information indefinitely, and we do not retain it for any secondary purpose. We take reasonable steps to delete or de-identify children’s personal information when it is no longer needed.

9. Security

We maintain reasonable administrative, technical, and physical safeguards designed to protect children’s personal information.

10. Changes to this policy

If we make material changes to this Children’s Privacy Policy, we will provide notice to parents as required by COPPA and obtain new consent where required.

11. Contact us

If you have questions about this policy or our privacy practices, you may contact us at Customer Care.
You can contact us by sending an email to our Data Protection Officer (DPO) at the following address: dpo@webtoon.com

NAVER WEBTOON Ltd., NAVER Green Factory 6-10F, 6, Buljeong-ro, Bundang-gu, Seongnam-si, Gyeonggi-do, Republic of Korea
(If applicable) WEBTOON Entertainment Inc., 222 N. Pacific Coast Highway, Suite 2300, El Segundo, CA 90245, United States