Effective Date: 20/05/2019
Samsung Electronics Co., Ltd. (“Samsung” or “We”) and its affiliated companies and subsidiaries respect your concerns about privacy. This Privacy Policy applies to the personal information we collect through the PENUP services (the “Services”). It does not apply to information collected by other apps, websites, or services provided by Samsung or its affiliated entities.
PENUP is a social network for communicating through artworks. Its features include Share artwork, Colouring, Drawing, Challenge, and Wallpapers.
Our Privacy Policy at https://account.samsung.com/membership/pp (“Samsung Privacy Policy”) will apply to your use of PENUP. This Privacy Policy provides further information about how your personal data is used in connection with PENUP, and should be read in conjunction with the Samsung Privacy Policy which sets out how long we may keep the information, the choices available to you regarding our use of the information and exercising your rights, and we also describe the measures we take to safeguard the information.
In this Privacy Policy, we describe the types of information collected through PENUP, how we may use the information, and with whom we may share it. We also describe how to contact us about our privacy practices. Samsung is the data controller for the processing of personal data.
• How We Use the Information We Obtain
• Updates to Our Privacy Policy
Information We Obtain
Through PENUP, we obtain information about you in various ways. The types of personal information we obtain include:
Samsung’s servers may receive information when you interact with PENUP, such as information about your use of PENUP, your interactions with PENUP, and the devices you use to access PENUP.
How We Use the Information We Obtain
We use the information we obtain through the Services to:
• provide you with the Services, such as to respond to your requests, questions, and instructions made through PENUP;
• identify and authenticate you so you may use certain Services;
• improve and customise your experience with the Services, such as delivering content and responses tailored to our users and the manner in which they interact with PENUP;
• respond to your requests and enquiries;
• operate, evaluate, and improve our business (including developing new products; enhancing and improving our products and the services; managing our communications; analysing our products, customer base, and the services; conducting market research; performing data analytics; and performing accounting, auditing, and other internal functions);
• allow you to interact with and use certain third party apps and services;
• protect against, identify, and prevent fraud and other criminal activity, claims, and other liabilities; and
• comply with and enforce applicable legal requirements, relevant industry standards, and our policies, including this Privacy Policy, and the Samsung Privacy Policy.
Through PENUP, we may collect personal information about your online activities on PENUP-enabled devices over time and across third party apps, websites, and other online services. We may use third party analytics services on our Services. The providers that administer these analytics services help us analyse your use of the Services and improve our 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, help provide the Services, and diagnose technical issues.
Samsung processes personal data for the purposes described above. Samsung’s legal basis to process personal data includes performance of a contract (to identify and authenticate you, to provide you with services or information you have requested, and to communicate with you regarding PENUP); and legitimate interests (to monitor and improve PENUP, and to monitor compliance with our terms and conditions of use).
Information Sharing
We do not disclose personal information about you through the Services, except as described in this Privacy Policy. Limited members of the PENUP service team in Samsung may access and otherwise process personal data in connection with their job responsibilities or contractual obligations. We may share your personal information with our subsidiaries and affiliates and with service providers who perform services for us. We do not authorise our service providers to use or disclose the information except as necessary to perform services on our behalf or to comply with legal requirements.
Some of these personnel, affiliates, and third party service providers are located outside of the EEA, including in countries that may not provide the same level of data protection as the home country of our customers, including, for example and without limitation to, the Republic of Korea, the United States of America, and Japan. Samsung takes appropriate steps to ensure that such recipients are bound to duties of confidentiality and Samsung implements measures such as standard data protection contractual clauses to ensure that any transferred personal data remains protected and secure. A copy of these clauses can be obtained by contacting us as specified in the How to Contact Us section of this Privacy Policy.
When you use PENUP to access or interact with third party apps and services, we may send certain personal information to the providers of such third party apps and services to provide you with the services you request. Examples of this information may include ID, Name, Description, Image URL, Post count, Reposted count, Favourited count, Follower count, Following count, and other data that helps facilitate the services you request. These third parties may also collect certain personal information directly from your devices through PENUP. Samsung is not responsible for these third party providers’ privacy or security practices. The privacy and security practices of the relevant providers, including details on the information they receive from us or collect about you, are subject to the privacy statements of these parties, which we strongly suggest you review.
Samsung, our subsidiaries and affiliates, and our third party service providers may also disclose information about you (1) if we are required to do so by law or legal process (such as a court order or subpoena); (2) in response to requests by government agencies, such as law enforcement authorities; (3) to establish, exercise, or defend our legal rights; (4) when we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss; (5) in connection with an investigation of suspected or actual illegal activity; (6) in the event we sell or transfer all or a portion of our business or assets (including in the event of a merger, acquisition, sale, transfer, reorganisation, dissolution, or liquidation); or (7) otherwise with your separate consent, where required.
Updates to Our Privacy Policy
This Privacy Policy may be updated periodically to reflect changes in our personal information practices with respect to the Services, or changes in the applicable law. We will post a notice on our website and/or your device to notify you in advance of material changes to our Privacy Policy and indicate at the top of the notice when it was most recently updated.
How to Contact Us
If you have any specific questions, please contact us at:
Data Controller
Samsung Electronics Co., Ltd.
129, Samsung-ro, Yeongtong-gu,
Suwon-si, Gyeonggi-do 16677, Republic of Korea
Samsung Electronics has offices across Europe, so we can ensure that your request or query will be handled by the data protection team based in your region.
The easiest way to contact us is through our Privacy Support page at https://www.samsung.com/request-desk. If you would like to exercise your rights to access, rectification, deletion/erasure, object, restrict processing or portability, please visit our Privacy Support page.
You can also contact us at:
European Data Protection Officer
Samsung Electronics (UK) Limited
Samsung House, 1000 Hillswood Drive, Chertsey, Surrey KT16 0PS
You may lodge a complaint with the relevant supervisory authority if you consider our processing of your personal data to infringe applicable law. Contact details for all EU Supervisory Authorities can be found here.