ZEP Co., Ltd. Integrated Terms and Services

Integration Overview

This document has been prepared by integrating the ZEP Service Terms of Use (effective November 25, 2023) and the ZEP QUIZ Service Terms of Use (effective September 24, 2024).

Key Changes

Key Integration Details

① Expansion of Service Scope

1. Before: Applied separately to ZEP Core & ZEP QUIZ services

2. After: Applies to both ZEP Core & ZEP QUIZ services

② Integration of Terminology Definitions (Article 2)

③ Use for Commercial Use (Article 24)

1. ZEP Core: For-profit activities within ZEP Spaces

2. ZEP QUIZ: For-profit activities within ZEP QUIZ

3. Integration: Consolidated as For-profit activities within ZEP Spaces and ZEP QUIZ

④ Re-registration After Customer Account Deletion (Withdrawal)

1. ZEP Core: Re-registration available after withdrawal.

2. ZEP QUIZ: No separate withdrawal function, Customer account deletion processed via customer center inquiry.

3. Integration: Separate guidance required due to differences between services.

⑤ Data Retention Policy (Article 21, Clause 6)

1. ZEP Core: Criteria for deleting ZEP Space data

2. ZEP QUIZ: Criteria for deleting ZEP QUIZ data

3. Integration: Both policies are included

Your use of and access to the website and products and services and associated software (collectively the "Services") of ZEP Co., Ltd. and its affiliates (hereinafter referred to as "the Company") regarding the use of teleconferencing and other ancillary services provided through PC, mobile and other devices and the accompanying networks, websites and other services, shall be conditioned upon the Customer's compliance with and acceptance of these Terms and Conditions (these "Terms").

ZEP QUIZ is a mixed-audience service.

① Users 13 years or older may create an account and use the Service directly.

② Students under 13 years of age may access a quiz only under the direction of a verified teacher, school administrator, or parent/guardian.

➂ We rely on schools to obtain any consent required by the U.S. Children's Online Privacy Protection Act (COPPA) and treat the school as the parent for those purposes.

① Definitions of Terms used in these Terms are as follows:

1. "Company" shall have the meaning in Article 1.

2. "Customer" means a person who uses the Services in accordance with the terms of these Terms.

3. "Non-customer" refers to an individual or corporation that uses the Services provided by the Company without registering as a Customer.

4. "User" refers to Customers and Non-customer who use the Services provided by the Company in accordance with these Terms.

5. "Device" refers to a device that is used to access the Service, such as a personal computer, mobile phone, smart phone, PDA, and/or tablet PC.

6. "Account Information" includes information relating to the Customer including but not limited to the Customer's account number, external account information, device information, nickname, profile picture, friends list, usage information, billing information and payment history.

7. "Content" means any content created by the Company in connection with the Services.

8. "ZEP Space" refers to a metaverse space accessible to Customers within the Service.

9. "Subscription Plan" refers to the ZEP Space Subscription Plan service for spaces where they possess either ownership or administrative authority, allocated to a separate virtual server distinct from free users.

10. "Goods" means any other products or services that Customers can purchase using points within the Service, other than the Subscription Plan.

11. "Sponsorship" refers to the act of a Customer granting points to another Customer without any consideration to support their activities within the Service.

12. "Points" refers to the virtual assets to be used on the Service platform by Customers to purchase Goods or make Sponsorships.

13. "Paid Content" refers to services that Customers use for a fee, including the Subscription Plan, Points, etc.

14. "Application" means all programs downloaded or installed through a Device to access the Services.

15. "Integrated Account" refers to the account integration service provided by the Company that allows multiple ZEP services (ZEP Core, ZEP QUIZ, ZEP School, etc.) to be used with a single account.

16. "Education Records" means records directly related to a student and maintained by an educational agency or institution or by a party acting for such agency or institution, as defined by FERPA (20 U.S.C. § 1232g).

17. "Student PII" means personally identifiable information contained in education records, as defined under FERPA regulations (34 CFR § 99.3).

② Except as defined in clause 1 of this Article, the definitions of terms used in these Terms and Conditions shall be governed by the applicable laws and service-specific policies.

① The Company will post the contents of these Terms on the Service platform. Important terms such as discontinuance of Service, refund policy, withdrawal or termination of contracts, and indemnity provisions will be displayed in bold and/or color for ease of reference.

② If the Company revises the terms of these Terms, the Company will notify Customers at least 7 days in advance of the application date. If the amendments are disadvantageous to the Customer or are material in nature, Customers shall be notified at least 30 days in advance of the application date pursuant to Article 32(1). In this case, the amended provisions will be clearly displayed for ease of reference.

③ If the Company revises the terms and conditions, the Customer's consent to the application of the revised terms and conditions is confirmed after the announcement of the revised terms and conditions. When the Company provides a notice or announcement under Paragraph 2, it shall also indicate that if the Customer does not express their intention to agree or reject the revised terms and conditions by the date on which they apply, they will be deemed to have agreed to the revised terms and conditions. If the Customer does not express their intention to reject the revised terms and conditions by the enforcement date, they will be deemed to have agreed to the revised terms and conditions. If the Customers do not agree with the changes made to the Services by the Company, they have the right to express their disagreement and terminate the Use Contract.

④ The Company will take measures to enable the Customer to inquire regarding these Terms.

⑤ The Company shall comply with all applicable laws and regulations in the jurisdictions where the Service is offered, including but not limited to: (a) in the Republic of Korea, the Act on the Protection of Consumers in Electronic Commerce, the Law on the Regulation of the Terms of Use, the Personal Information Protection Act, the Act on Information Network Utilization and Information Protection, and the Content Industry Promotion Act; and (b) in the United States, the Family Educational Rights and Privacy Act (FERPA), the Children's Online Privacy Protection Act (COPPA), and applicable state student data privacy laws.

The matters not specified in these Terms and the interpretation of these Terms shall be conducted in a manner consistent with the applicable laws and ordinances of the jurisdiction in which the Customer resides. For Customers in the Republic of Korea, this includes the Act on the Protection of Consumers in Electronic Commerce, the Law on the Regulation of the Terms of Use, the Personal Information Protection Act, the Act on Information Network Utilization and Information Protection, and the Content Industry Promotion Act. For Customers in the United States, this includes FERPA, COPPA, and applicable federal and state laws governing student data privacy and children's online privacy.

① The Use Contract is established when an individual who wishes to become a Customer (referred to as the Applicant) agrees to the terms and conditions prior to using the Service and proceeds to register a service account (referred to as the Account). A person who applies for use by accessing the Service without registering an account is deemed to have agreed to these Terms, and therefore must immediately stop using the Service if they do not agree to these Terms.

② The Company reserves the right to decline an application for, or terminate an existing Subscription Plan, under the following circumstances:

1. The Customer is under the age of 13 and is not accessing the Service under the direction of a verified educational institution, teacher, or parent/guardian as described in Article 2.

2. If it is not their real name or if they use another person's name.

3. If false information is entered, the information presented by the Company is not entered, or if there is a typographical error.

4. If the Applicant has previously lost Customer status or had their Use Contract terminated due to reasons such as violation of these Terms.

5. In any other case where there are reasonable grounds to deem acceptance inappropriate, equivalent to the reasons set forth in Subparagraphs 1 through 4.

③ In the event of any of the following subparagraphs, the Company shall announce it in advance by the method in Paragraph 2 and acceptance may be withheld until the reason is resolved:

1. If there is no space in the Company's facilities or there is a technical obstacle.

2. If there is a Service failure or a failure in the Service fee payment method.

④ If the Customer accesses the Service through a social networking service (such as Facebook) (hereinafter referred to as "social networking service"), the Customer must comply with the social networking service terms of service as well.

⑤ If the Customer disagrees with these Terms, the Customer must terminate the use of the Service.

⑥ If the Customer is forbidden from using the Services under the applicable laws and regulations, then such Customer's consent to these Terms shall be void and null.

① The Customer can terminate use by choosing to close the Customer account. The Company will process this in accordance with relevant laws and regulations.

② When a Customer terminates the Use Contract, the Company deletes the Customer's information, except in cases where it is required to retain the Customer's information in accordance with relevant laws and the Privacy Policy.

③ The Customer shall bear the responsibility for any disadvantages resulting from the termination of the Use Contract, and upon termination of the Use Contract, the Company may retrieve various benefits provided to the Customer.

④ The Company may, if the Customer acts in contravention of these Terms or engages in activities otherwise prohibited per the applicable policies or regulations, suspend or terminate the Customer account upon prior notice of the applicable suspension or termination date. This includes the following:

1. If the Customer engages in or attempts to engage in acts that interfere with the smooth operation of the Service.

2. If the Customer engages in acts that violate related laws, supervisory regulations, guidelines of supervisory authorities, or these Terms.

3. If it is confirmed that the Customer has a reason for refusal of acceptance of the Use Contract as stipulated in Article 6, Paragraph 2.

4. If the Customer intentionally interferes with the Company's business.

5. Deliberate transmission or distribution of viruses, computer codes, files, programs, etc., which intend to interfere with or destroy the operation of computer software, hardware or telecommunication equipment.

6. Other cases where reasons equivalent to the preceding subparagraphs occur, making it impossible to maintain this Use Contract.

⑤ If the Company terminates the Use Contract, the Company will notify the Customer of its intention to terminate by stating the reason for termination via email, etc. In this case, before termination, the Company sets a considerable period (7 days) to give the Customer an opportunity to file an objection.

⑥ If the Use Contract is terminated by the Company, the Company may refuse to accept the Customer's application for reuse.

⑦ Damages resulting from the termination of the Use Contract must be borne by the Customer whose fault caused the termination, and the Company bears no responsibility unless stipulated by related laws.

⑧ Upon termination of the Use Contract by either party, if the Customer is an educational institution or was accessing the Service under Article 2(2), the Company shall, at the institution's or parent's request, securely delete or return all Education Records and Student PII within thirty (30) days, and provide written confirmation of deletion.

① The Company agrees to comply with the provisions in these Terms and the applicable laws and regulations in good faith.

② The Company will have in place an adequate security system to protect the personal information (including credit information) of the Customers. The Company will not disclose or provide any personal information of the Customer to any third party except as set forth in these Terms.

③ The Company must process any opinions or complaints raised by Customers in connection with the use of the Service if they are deemed justified, and the processing results are communicated to the Customers via email.

① Customers shall not engage in any of the following activities relating to the use of Services.

② Customers are responsible for the safekeeping of their Customer accounts and Devices, and are prohibited from letting others use their accounts. The Company shall not be liable for any damage caused by the mismanagement of the Device or the Customer account.

③ Use of services for purposes other than their original purpose, such as for profit, sales, advertising, publicity, political activities, and election campaigns, without the explicit consent of the Company.

④ Customer shall not use, duplicate, transmit or otherwise use (including but not limited to edits, publication, performance, distribution, broadcasting, and creation of derivative works) the information (including any intellectual property) obtained from the Service for commercial purposes without the prior consent of the Company or the original provider of such information.

⑤ The Company provides a function that allows Customers who previously signed up separately for each service (ZEP Core, ZEP QUIZ) to link them to an Integrated Account. Account linking is only possible between accounts using the same email address.

① Customers shall not engage in any of the following activities relating to the use of Services:

1. Falsifying or otherwise providing misleading information during account creation, Customer account information update and/or use of the Services.

2. Attempts to gain unauthorized access to an account, server or network relating to the Service using a method other than the user interface provided by the Company.

3. Modification of the Application or the Service platform without the consent of the Company; addition or insertion of other unauthorized programs into the Application or the Service platform.

4. Acts that infringe intellectual property rights or image rights of the Company or others.

5. Acts that damage the reputation of others or interfere with the business of the Company and other third parties.

6. Posting of information that is abusive, threatening, lewd, defamatory or libelous of others, or information that is unreasonable or offensive for racial, gender, religious or other reasons.

7. Use of services for purposes other than their original purpose, such as for profit, sales, advertising, publicity, political activities, and election campaigns, without the explicit consent of the Company.

8. Any other violation of applicable laws and regulations.

② If a Customer engages in the prohibited acts of this Article, the Company may restrict the use of the Service after notifying the Customer by e-mail, etc., and the Customer shall bear the responsibility arising in this case. The Company may notify the relevant government or judicial authorities of the Customer's prohibited acts if necessary.

③ For Customers whose use of the Service is restricted, all or part of the Service use will be suspended during that period. Specific criteria for use restriction are defined in the operational policy.

④ Customers may file an objection against the Company's use restriction measures. If a Customer provides an explanation for the reason for the Service use restriction and the reason for the restriction is resolved, the Company will immediately take necessary measures such as resuming the use of the Service.

① Customers are responsible for the safekeeping of their Customer accounts and Devices, and are prohibited from letting others use their accounts.

② If a Customer becomes aware that their ID and Password have been leaked and are being used by a third party, they must notify the Company immediately.

③ Customers must take care not to use the same ID or Password as those of other sites.

④ The Company may request the Customer to take necessary measures, such as changing the Password, to protect the Customer's personal information and prevent other fraudulent use of the Service, and the Customer must faithfully comply with the Company's request.

⑤ The Company shall not be liable for any damage caused by the mismanagement of the Device or the Customer account.

① Customers can view their personal information through the personal information management screen. When modifying personal information, they can do so after performing identity verification as determined by the Company.

② If the information entered at the time of application for use changes, the Customer must directly modify it or inform the Company of the changes by other methods such as email.

③ The Company is not responsible for any disadvantages caused by not informing the Company of the changes in Paragraph 2.

① The Company will endeavor to protect the personal information of the Customer as stipulated by the applicable laws and regulations, and shall be conducted as per the Company's Privacy Policy.

② The Company shall not provide the Customer's personal information to third parties without consent; provided that the Company may do so if requested in accordance with the applicable laws and regulations by the governmental authorities.

③ Notwithstanding any other provision of these Terms, the Company shall not collect, use, or disclose personal information from children under the age of 13 except as permitted by COPPA and in accordance with verifiable parental consent or the school consent exception under 16 CFR § 312.5(c)(3).

① The Company shall assist educational agencies and institutions in fulfilling requests by parents or eligible students to inspect and review the student's education records. The Company will comply with such requests within a reasonable period of time, but in no case more than forty-five (45) days after the request has been received by the educational agency or institution.

② If a parent or eligible student believes the education records relating to the student contain information that is inaccurate, misleading, or in violation of the student's privacy rights, the Company will cooperate fully with the educational agency or institution to amend the record.

③ Should a request for amendment be denied by the educational agency or institution, the Company will support the institution in providing the parent or eligible student an opportunity for a formal hearing to challenge the content of the student's education records, in accordance with applicable federal regulations.

④ With respect to the use and maintenance of education records, the Company operates as a "school official" with a "legitimate educational interest" and remains under the direct control of the disclosing educational agency or institution.

⑤ The Company shall not use Education Records or Student PII for any purpose other than providing the educational service contracted by the school or educational institution. The Company shall not sell, rent, or trade Student PII to any third party.

⑥ Upon termination of the service agreement with an educational institution, or upon the institution's written request, the Company shall securely delete or de-identify all Education Records and Student PII within thirty (30) days and provide written confirmation thereof.

① The Company shall make the Service available to each Customer who complies with Article 6, including the following:

1. Quiz solving and participation

2. Quiz creation and management

3. Providing quiz results and statistics

4. Development and provision of user-participatory content

5. Supporting interaction and communication between users

6. Other services additionally developed by the Company or supported in partnership with affiliated companies

7. Real-time communication such as video meetings and video chat

8. Subscription Plan (allocation of separate virtual server)

9. Use of content such as objects, skins, mini-games, etc.

10. Point purchases, product purchases, and sponsorship functions

② Services are provided in accordance with the Company's operational policies. However, the Service may be temporarily suspended if regular service maintenance, system upgrades, or the like are necessary. In such cases, the Company will notify Customers in advance through the Service screen or other appropriate means.

③ Notwithstanding the preceding clause 1, the Company may suspend all or part of the Services when it is necessary for system operation, including periodic system checks, expansion and replacement of servers, addressing unstable network situations. In such cases, the Company will notify the cause and the duration of the suspension to the Customers; provided that notification may occur afterwards during circumstances where advance notification is not feasible.

④ The Company may suspend operations because of acts of god such as fire, flood, earthquake, power outage and defects or issues which cannot be resolved by current technology, and will notify immediately after circumstances are resolved if prior notice is impossible.

⑤ The Company shall not be liable for any damages to the Customer or any third party whatsoever for problems imposing restrictions on some functions within the Service due to failures or maintenance of third-party services linked to the Service, unless there is intent or gross negligence on the part of the Company. In this case, the Customer will be notified or informed of the fact.

① In order to provide a smooth service, the Company may make changes to the Service according to the operational or technical needs and notify the Customers regarding such changes in advance. However, if such changes (1) are minor in nature, (2) are related to addressing bugs, errors, etc., or (3) are emergency updates, then notifications can be made afterwards.

② If the Customers do not agree with the changes made to the Services by the Company, they have the right to express their disagreement and terminate the Use Contract.

③ In the event of a material change that affects the processing, storage, or security of Education Records or Student PII, the Company shall provide educational institution Customers with at least sixty (60) days' prior written notice.

① The Customer may be able to purchase (a) virtual assets ("Assets") to be used on the Service platform and/or (b) any other products or services ("Goods"), as the case may be. The Company may modify the prices of any paid Content offered through the Service at any time upon notice.

② Payment procedures for any paid Content will be made in accordance with the applicable open market rules, subject to any necessary adjustments per the applicable laws and regulations. Paid Services will begin to be provided immediately upon completion of payment.

③ Falsifying or otherwise providing misleading information during account creation, the Company may restrict or suspend the User's use of the service.

④ The Company will reimburse the Customer for any applicable overpayment or if the Company cannot provide the service due to changes in service content, suspension, or other unavoidable reasons. Specific conditions and procedures for refunds are governed by the Company's refund policy.

⑤ The Customer who has entered into a contract with the Company for the purchase of paid Contents may withdraw (without any fees or penalties) from such contract within 7 days from the latter of (1) the date of purchase and (2) the date the Content is made available.

⑥ However, the Customer cannot cancel any purchase contracts if: (a) the Customer has used or partially consumed the Content or (2) the Content was received free of charge from the Company or a third party.

⑦ If a Customer withdraws their subscription, the Company will verify the purchase history through available channels, such as a Payment Gateway (PG) provider or an app market operator. Furthermore, the Company may contact the Customer using the information provided by the Customer to confirm the legitimate grounds for withdrawal, and may request additional evidence. In the event of a refund where the payer and the user of the Paid Service are different, as a general rule, the refund shall be issued to the same payment method used by the payer who paid the usage fee.

⑧ If a Customer arbitrarily withdraws their subscription or terminates the Use Contract due to other reasons attributable to the Customer, the Customer must pay the Company for the used Paid Service as follows: (1) the usage fee for the portion used and (2) a penalty. Even if the Customer was provided the service at a discounted amount, the usage fee for the used portion and the penalty will be calculated based on the non-discounted regular price.

⑨ The Customer cannot cancel any purchase contracts if: (a) the Customer has used or partially consumed the Content or (2) the Content was received free of charge from the Company or a third party.

① A portion of the Service revenues may be derived from advertising. Customers agree that when they use the Service they may be exposed to advertisements. The Company shall not be liable for any loss or damage which may arise from Customers' participation in or communication with the advertiser's promotional activities posted on the Service platform.

② The Company may place advertisements within the Service platform in connection with the operation of the Services. To the extent the Customer has agreed, the Company may send advertisements via e-mail, push notification, etc. The Customer can choose to refuse such advertisements at any time.

③ Customers may be linked to third-party advertisements or services through banners or links within the Services.

④ In the event that an advertisement or service provided by a third party is linked to the Customer in accordance with the preceding clause 3, the Customer understands that such service or advertisement is not provided by the Company, and accepts that the Company does not guarantee reliability or stability thereof and the Company shall not be liable for any damages arising out of them unless such damages arise due to the company's gross negligence or willful misconduct.

⑤ Notwithstanding the preceding clauses, users accessing the Service under the educational framework defined in Article 2 (including students under the age of 13) will not be subject to targeted advertising, behavioral marketing, or commercial promotional communications. The Company shall not use education records or personally identifiable student information to build marketing profiles or serve commercial advertisements. This restriction applies to all students using the Service through a school or educational institution, regardless of age.

① The Company shall be liable for any damages borne by the Customer if such damages arise due to its gross negligence.

② The Company shall not be liable for any failure or delay in the performance of its obligations hereunder arising out of or caused by acts of god, or for service use failures caused by the Customer's intent or negligence.

③ The Company shall not be liable for the reliability or accuracy of the information or materials posted by a Customer in connection with the Service.

① The Company shall be liable for any damages borne by the Customer if such damages arise due to its gross negligence. The scope of the Company's compensation for damages includes ordinary damages stipulated in the Civil Act, and the Company is not responsible for any other indirect, incidental, or special damages under any circumstances.

② Despite the preceding paragraph, the Customer may bear all or part of the responsibility in any of the following cases:

1. If the Customer failed to notify the Company despite knowing the cause of the damage or the fact that damage occurred.

2. If a third party obtained and used the Customer's account, etc. through falsehood or other fraudulent methods without the Company's intent or negligence.

3. Other cases where there is intent or negligence on the part of the Customer regarding the occurrence of the damage.

③ If the information provided by the Customer to the Company differs from the facts, the Company may suspend the provision of the Service at any time and terminate all or part of the contract under these Terms, and if this causes damage to the Company, the Company may claim compensation for the damage from the Customer.

④ The Customer shall indemnify the Company for any damages or liability arising from the Customer's acts in contravention of these Terms or illegal in nature.

⑤ If the Company fails to be indemnified from claims from third parties, then the Customer shall be liable for any damages or liability borne by the Company. However, the Company bears responsibility for any parts where the Company is at fault.

⑥ If a Customer (the "Provider") provides Assets or Goods on the Service platform and such Assets or Goods cause damage to another Customer, then the Provider shall be liable for any damages borne by the Customer. However, the Provider shall not be liable for the portion attributable to the Company's gross negligence.

⑦ In the event that the Company has entered into an agreement with a third-party service provider to provide certain services, then any damages to the Customer shall be borne by the applicable third-party service provider.

① Copyright and all intellectual property rights relating to all Content shall belong to the Company.

② Customer shall not use, duplicate, transmit or otherwise use (including but not limited to edits, publication, performance, distribution, broadcasting, and creation of derivative works) the information (including any intellectual property) obtained from the Service for commercial purposes without the prior consent of the Company or the original provider of such information. If the Company grants an individual license to the User for specific content among the provided services, it may specify the conditions of use, and the User must comply with those conditions.

① Regarding any communications, chats, text, images, sound, and any materials and other information uploaded to or displayed by the Customer on the Service platform ("User Generated Content"), the Customer agrees that the Company shall have the license to use such User Generated Content as deemed necessary by the Company (including but not limited to the use, storage, modifications, public display or dissemination thereof) in accordance with the applicable intellectual property laws. The Customer can revoke such license at any time by contacting customer support and request the removal of such User Generated Content.

② The User guarantees that they possess all necessary rights to the User Generated Content they post, and that the use of such content does not violate these Terms, applicable laws, or the intellectual property rights of third parties. The User bears full responsibility for all User Generated Content they post.

③ Posts that a Customer puts up within the Service may be exposed in search results or included in service information, related promotions, etc. The Company may modify, reproduce, and edit the Customer's posts for the Company's service information or promotional purposes without prior consent. At this time, the Customer may at any time request measures such as deletion, exclusion from search results, or making private regarding the post through the customer center.

④ The Company retains the right to review, monitor, edit, or remove User Content, but has no obligation to do so. The Company may remove access to or disable User Content that violates the Terms, applicable usage policies, or editing guidelines.

⑤ When a Customer sets User Content to be publicly available, the Customer grants the Company a perpetual, non-exclusive, and transferable license for ZEP QUIZ and its affiliates to use, reproduce, modify, translate, create derivative works from, and distribute that content. This right is maintained to the extent permitted by applicable law.

⑥ Notwithstanding the preceding clauses, the licenses granted to the Company in this Article do not apply to Education Records or Student PII governed by FERPA. Such data shall not be publicly distributed, transferred, or licensed to third parties without explicit written consent from the parent, eligible student, or authorizing school. The Company shall not use Education Records for any commercial purpose, including but not limited to advertising, marketing, or building user profiles.

⑦ The Company may remove, delete or refuse to register any information posted or transmitted by the Customer which contravenes Article 10(1) in the Company's discretion and provide notice thereof to the Customer following such actions.

① The Customer shall not engage in any activity in contravention of Article 10, and in case of such conduct, the Company may take necessary measures including but not limited to the restriction or deletion of the Customer account, and/or removal of information related to the said activities. For the avoidance of doubt, this right does not otherwise limit the Company's other rights or remedies. As a result of the Company's actions, the Customer may lose various privileges including but not limited to the Customer's user name, character, items (purchased or otherwise acquired) and any other benefits, and the Company shall not be liable for any direct or indirect damages arising thereunder.

1. Partial Restriction: Restrict chatting privileges for a set period of time.

2. Character Restrictions: Restrict the use of Customer's characters on a temporary or permanent basis.

3. Account Restriction: Restrict the use of Customer's current Service account on a temporary or permanent basis.

4. Customers Restrictions: Restrict the use of Service by the Customer on a temporary or permanent basis.

② If the use restrictions set forth in the preceding clause are justified, the Company shall not be liable for any direct or indirect damages incurred by such restrictions.

③ The Company may suspend the use of the Service until the investigation of each of the following cases is completed.

1. the Company received a legitimate report that the Customer's account is hacked or stolen;

2. there are reasons to suspect acts in contravention of these Terms, such as use of an illegal program;

3. if provisional restrictive measures are necessary for other reasons.

④ The Customer acknowledges and accepts that the Customer does not have ownership or any other proprietary interest in the Customer account. The Customer further acknowledges and accepts that the Customer account may not be transferred without the prior consent of the Company.

⑤ The Company reserves the right to own, license and otherwise use all Content on any of the services or products provided by the Company. In no event shall the Customer have any ownership of any Content provided on the Service (including any virtual goods or digital assets, whether purchased or otherwise acquired) arising out of or in connection with the Service.

⑥ The Company reserves the right to delete the data associated with the Customer's ZEP space from its server or other storage device. In such cases, the Customer will no longer have access to, view, check, or utilize the related data. The Customer is responsible for managing and separately backing up any necessary information related to their created ZEP space, and the Company shall not be held liable for any damages resulting from the deletion of data.

1. For Customers who do not use the ZEP service as a Subscription Plan, if neither the Customer nor any third party has accessed the Customer's ZEP space for a period exceeding 6 months.

2. For Customers who use the ZEP Space as a Subscription Plan, if the Subscription Plan use agreement has ended.

⑦ Notwithstanding Paragraph 6, Education Records and Student PII shall not be deleted, destroyed, or made inaccessible without first providing the educational institution or parent with reasonable notice and an opportunity to retrieve or transfer such data.

① The Company may establish specific reasons and procedures for restricting use under Article 23 (1) as part of its operating policy.

② When implementing restrictions on use as specified in Article 23 (1), the Company shall provide advance notification to the Customer regarding the following matters. However, in certain circumstances where advance notification is not feasible, the notification may occur afterwards.

1. Reason for use restriction

2. Type and duration of use restriction

3. How to appeal the use restriction

① If the Customer disagrees with the Company's restrictive measures, an appeal must be submitted to the Company by e-mail (or a similar method) within 14 days from the date of notification of the restrictive action. Appeal emails should be sent to: [hello@zep.us].

② The Company shall respond within 15 days from the date of receipt of the appeal via mail or e-mail. provided that if it is impractical to respond within the aforementioned period, the Company shall notify the reason for the delay and the processing schedule.

③ If the grounds for objection are valid, the Company will take appropriate action accordingly.

①  Customer may engage in the following for-profit activities within the Service upon obtaining explicit consent from the Company.

1. Promoting, marketing, or advertising third-party individuals, services, products, etc. other than themselves within the ZEP Space or ZEP QUIZ.

2. Applying or bidding for projects from administrative agencies, public enterprises, and quasi-governmental agencies (hereinafter referred to as Public Institutions) utilizing ZEP Service.

② If a Customer utilizes the Service for profit as stated in the preceding paragraph, the Company reserves the right to levy a usage fee. The specific details, rates, and other relevant factors pertaining to the usage fee will be determined in accordance with the operation policy. However, the fees, collection methods, and settlement procedures may be subject to variations based on consultations between the Company and the Customer, or the Company's internal policies.

③ A Customer planning to engage in for-profit activities within the Service (hereinafter referred to as the Applicant) must provide accurate information as requested by the Company and submit an application for for-profit use. The completion of the application for for-profit use will be confirmed when the Company notifies the Applicant of the acceptance of their application.

④ The Company reserves the right to request the submission and supplementation of data related to for-profit use. The Customer is obligated to promptly provide the requested data or supplement it upon receiving such a request from the Company. In the event that the Applicant fails to submit the required data or if the submitted data is deemed insufficient, the Company may decline approval of the Applicant's application for for-profit use.

⑤ The Applicant is required to submit monthly reports and provide evidence relating to the use of the Service for for-profit purposes to the Company. However, the specific timing for data submission and reporting can be adjusted through mutual consultation between the Company and the Applicant.

⑥ The Company reserves the right to cancel the Applicant's application for for-profit use and impose restrictions on the Service if any of the following reasons occur or are confirmed by the Applicant:

1. Where an Applicant fails to pay a fee or neglects to submit and report data as specified in Paragraph 5 of this Article, and despite the Company's request for correction, fails to rectify the situation within a minimum period of 14 days.

2. Where an Applicant submits false information or data or fails to provide the content requested by the Company at the time of application for use.

3. Where the Applicant has previously lost their membership or the Use Contract had been terminated due to a violation of these Terms and Conditions.

4. Where the Applicant violates laws or violates Article 9 or Article 10 while engaging in commercial use.

⑦ Customers who are subject to usage restrictions will be unable to access and utilize the Service during the restricted period. Additionally, they will not have access to any previously created ZEP Spaces. The specific criteria for usage restrictions will be determined by the operation policy.

⑧ The Company has the authority to lift the restrictions on Service use as stated in Paragraph 6, provided that the Customer meets the criteria established by the Company, which may include providing a clear explanation of the reasons for the restrictions.

① For Customers located outside of the United States, these Terms shall be governed by and construed in accordance with the laws of the Republic of Korea, and disputes shall be submitted to a Korean court in accordance with the procedures set forth by law (Seoul Central District Court).

② For Customers located in the United States, these Terms shall be governed by and construed in accordance with the laws of the State of Delaware, without regard to its conflict of law provisions. Any dispute arising under or relating to these Terms shall be resolved exclusively in the state or federal courts located in the State of Delaware.

③ Notwithstanding the foregoing, nothing in this Article shall limit the rights of parents, students, or educational institutions under FERPA, COPPA, or applicable state student data privacy laws to seek remedies in a court of competent jurisdiction.

① The Company shall maintain a comprehensive written information security program that contains appropriate administrative, technical, and physical safeguards designed to protect the security, confidentiality, and integrity of Customer data and education records.

② The Company shall ensure that all Customer data, including personally identifiable information, is encrypted both in transit over public networks (using industry-standard protocols such as TLS 1.2 or higher) and at rest (using advanced encryption standards such as AES-256).

③ The Company ensures that all employees, contractors, and agents who have access to Customer data are subject to strict confidentiality obligations, undergo recurring security awareness training, and have passed appropriate background checks prior to being granted access to production systems.

④ The Company will conduct regular vulnerability scanning and routine third-party penetration testing of the Service platform to identify and remediate potential security threats.

① The Company shall maintain a formal incident response plan designed to promptly identify, contain, and resolve security incidents.

② In the event the Company discovers a confirmed breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Customer data or education records (a "Security Incident"), the Company shall notify the affected Customer(s) without undue delay, and in no event later than forty-eight (48) hours after confirming the Security Incident.

③ The Company will provide reasonable cooperation and information to the Customer regarding the nature of the Security Incident, the specific data compromised, and the mitigation measures taken, to assist the Customer in fulfilling its own regulatory notification obligations.

④ In the event a Security Incident involves Education Records or Student PII, the Company shall also notify the applicable educational institution(s) and cooperate with the institution in notifying affected parents or eligible students, as required by FERPA and applicable state breach notification laws.

① The Company is committed to providing a highly available service and will use commercially reasonable efforts to maintain an uptime of at least 99.9% for the core Services, excluding scheduled maintenance windows which shall be communicated to Customers in advance.

② The Company shall maintain a comprehensive Business Continuity and Disaster Recovery (BCDR) plan. The Company will perform automated, routine backups of Customer data and ZEP Space configurations, storing such backups in geographically distributed, secure facilities to ensure data restoration capabilities in the event of a systemic failure or catastrophic event.

① The Company will utilize systematic processing controls to ensure that all data—including user inputs, quiz results, and analytics—is processed completely, accurately, and in a timely manner.

② To ensure secure and accurate data exchanges with external Learning Management Systems and third-party educational tools, the Company enforces strict API security protocols, including OAuth2 authentication and standard data validation checks, preventing unauthorized data modification during transmission.

① The Company subjects its security controls and operational practices to regular, independent third-party audits designed to test the design and operating effectiveness of its information security program, in alignment with industry-recognized frameworks such as the AICPA SOC 2 Type II standards.

② Upon written request from an enterprise Customer or educational institution, and subject to the execution of a mutually agreeable Non-Disclosure Agreement (NDA), the Company shall provide a copy of its most recent third-party security audit report or relevant executive summary to verify the Company's compliance with the commitments outlined in this Chapter.

These Terms of Service will be effective starting from March 30, 2026