|Division||Personal Information Protection Manager|
|Department and Position||Chief Executive Officer|
Article 2 (Definition)
(1) “Service” means all the services provided by the Company, including websites, applications, products, and contents thereof, as well as any related services, sales, marketing events, or the like;
(2) “Personal information” includes any information that is voluntarily provided to us through interactions with our Services. Personal information includes the individual’s name, user ID, email address, password, phone number, mailing address, personal preferences, billing address, payment information, and any other information that you voluntarily provide when using our Service. Personal information further includes information that is automatically collected when users visit our applications or websites.
(3) “User” (or “Users”) mean any individual (or individuals) who accesses or uses the Service provided by the Company;
(4) “ID” means an email address designated by the User and approved by the Company for user identification and Service use; and
(5) “Password” means the combination of letters, special characters, or/and numbers that the User has set himself/herself to check his/her own identify and to protect his/her rights and interests.
Article 3 (Items of Personal Information Processed and Collection Method)
(1) The Company collects the personal information of the User as follows through methods such as websites and applications:
The personal information below is information that is essential to use the Service. If the User does not agree to provide the information, the use of the Service may be restricted and the User should refrain themselves from further use of the Service.
- Membership registration information: Email address, password, and name;
- Membership registration information for children under the age of 13: Our Service is not directed to children and accordingly Users under the age of 13 is restricted from using our Service. The User must also be old enough to consent to the processing of one’s personal data in your country (in some countries the Company may allow your parent or guardian to do so on your behalf). In such case, limited use can be granted based on the provision of the name and contact information of the parent/legal representative;
- Paid service usage information: Service purchase information and membership registration information;
- Event and promotion participation Information: Email address, name, and address;
- Information for Service provision: OS information, hardware information, Android ID and Google Advertising ID, and advertising data; and
- Information automatically generated in the process of using the Service: IP address, access record, service usage record, crash logs, diagnostic information, performance data (launch time, hang rate, energy usage), product interactions, and cookies.
(2) In principle, the Company does not collect personal information of Users under the age of 13. In situation where it requires collecting personal information of the User under the age of 13, the Company will seek the consent of the legal representative in advance and destroy the information within a reasonable period upon request or withdrawal from the use of our Service.
(3) The Company also collects the content created and uploaded by the User. The Company may also collect any other content the User has received from others including other Users and third party through the use of our Service.
(5) The Company may use Google API Services, including Google Sign-In and Google Drive APIs. The Company does not use Google API Services to collect, access, or share your personal information with external parties. And the use of information received from Google APIs will adhere to Google APIs Terms of Service and Google API Services User Data Policy, including the Limited Use requirements.
Article 4 (Purpose of Processing Personal Information)
The Company uses the collected personal information for the following purposes:
- Recommending and providing optimized and customized services by analyzing the User’s intention (through the click of “likes,” the use of “emojis,” or the like), preferences, pattern of behaviors, and activities (acts of sharing certain posts, videos, images, etc.) shown through the use of the Service;
- Improvement of existing services and development of new services;
- Analysis and statistics on the use of the Service;
- Securing service stability, preventing fraudulent Users, protecting accounts, and restricting violations of laws and the Company’s Terms of Service;
- Guiding and conducting events and promotions;
- Response to complaints regarding the Service; and
- Request for viewing, correction, processing, suspension of personal information and various related reports.
Article 5 (Personal Information Processing and Retention Period)
In principle, the Company destroys personal information without delay after the purpose of processing the information has been achieved. However, if it is necessary to preserve it in accordance with the applicable laws and regulations, the Company may keep certain information for a period of time as specified by the applicable laws and regulations. In such event, the Company will transfer it to a separate database or store it in a different storage location.
Article 6 (Personal Information Destruction Procedure and Method)
(1) When the retention period of personal information pursuant to Article 5 and applicable laws has expired, the Company will destroy the personal information within a reasonable period of time unless there are other justifiable reasons.
(2) The Company deletes personal information stored in the form of electronic files using a technical method that cannot reproduce the record. The Company also destroys personal information printed on paper, etc. through shredding or incineration.
Article 7 (Matters Concerning the Installation, Operation, and Rejection of Automatic Personal Information Collection Device)
(1) The Company operates a cookie that stores and finds User information from time to time. A cookie is a very small text file sent from the User’s web browser to the server used to operate the website of the Company, and it is stored on the User’s computer hard drive and mobile device.
(3) The User has his/her options to installing cookies. The User may allow all cookies by setting options in the web browser, check cookies whenever each cookie is saved, or disable all cookies. However, if the User disables all cookies, there may be difficulties in using the Service. Please refer to the following information to understand controlling cookies in the web browser.
- How to set cookies (for Internet Explorer 8.x): Select “Internet Options” from the “Tool” Menu. Click the “Personal Information Tab.” Select “Advanced” to set the cookie acceptance level that suits you.
- How to view the received cookies (for Internet Explorer 11.x): Select “Internet Option” from the “Tool” Menu. Click the “General” Tab and enter “Settings” of “Search History” to check it through “View File”.
- Declining cookies (for Internet Explorer 11.x): Select “Internet Options” from the “Tool” Menu. Click the “Personal Information Tab.” Select “Default” and set it to “Block All Cookies” at the higher level.
- Please click here to find more information on cookie control.
Article 8 (Provision of Personal Information to Third Party)
- When the User or his/her legal representative is in a state in which it is not possible to express his/her intension or obtain prior consent and does not respond within a considerable period of time but it is clearly deemed necessary for the urgent benefit of the life, body or property of the User or any third party;
- When there is a request from the investigative agency (both State or Federal) in accordance with the provisions of the applicable laws or under the procedures and methods prescribed by law for investigation purposes;
- If necessary for the settlement of charges following the provision of the paid service;
- When personal information is processed and provided in an unidentifiable form for statistical purpose, academic research, or market research; and
- If the User agrees in advance.
(2) If the Company is required to receive consent from the User pursuant to Paragraph 1, the Company may notify the User of the following items:
In the event of any change in any of the following items, the Company will notify the User of them to obtain his/her consent.
- Recipient(s) of personal information;
- Purpose of use of the personal information (for the provision of personal information, the purpose of use of the recipient);
- Items of personal information used or provided;
- Period of retention and use of personal information (for the provision of personal information, the period and use of the recipient); and
- The User’s right to refuse the provision and what possible disadvantages may follow such decision.
Article 9 (Entrustment of Personal Information Processing)
(1) In principle, the Company does not entrust the processing of personal information to others without the consent of the User. However, the Company entrusts the processing of personal information as follows in order to improve the quality of the Service and further develop new features of the Services.
|Trustee||Trustee Policy||Entrusted Work|
(2) If the Company entrusts the processing of personal information, we clearly stipulate that the trustee shall strictly comply with the Company’s instructions regarding the protection of personal information, the confidentiality, prohibition of providing personal information to any third party and shall be held responsible for any accident through consignment contracts, and the Company keeps the details of the contracts in writing or electronically. If the entrusted company or entrusted work are changed, we will notify the User of the change by selecting more than one notification method among in writing, email, telephone, text message, website notice, etc.
Article 10 (Rights and Obligations of User and the Exercise Method)
(1) The User who has viewed his personal information may request the Company to correct or delete personal information that is not true or cannot be verified. However, if the personal information is specified as the subject of the collection in other applicable laws, the User may not request the deletion. California residents have separate rights as specified in Articles 13 and 14.
(2) If the Company takes measures such as correction or deletion of the personal information within a commercially reasonable time from the date of receipt of the request by the User under Paragraph 1, the Company may notify the User of such measures through a notice of the result of correction and deletion of personal information.
(3) The User may request the Company to suspend his personal information processing. However, in any of the following cases or for other justifiable reasons, the Company may inform the User of the reason and refuse the request for the suspension:
- If there is a special provision in the law or if it is inevitable to comply with the Company’s statutory obligations;
- If there is a risk of harming another person’s life or body, or unreasonably infringing another person’s property and interests; and
- If it is difficult to perform the contract with the User, such as failing to provide the Service promised to the User without handling personal information, and the User has not clearly expressed his intention to terminate the contract.
(4) If the Company takes measures such as the suspension of handling personal information within a commercially reasonable time from the date of receipt of the request by the User under Paragraph 3, the Company may notify the User of such measures through a notice of the result of the suspension.
(5) The Company does not sell the personal information of the User. If the Company intends to sell the personal information to any third party, we will notify the User explicitly and obtain his/her consent, and the User may refuse to sell the personal information.
(6) The User may require the Company to transfer his personal information collected by the Company to another agency or User.
(7) The User may withdraw his/her consent to collect and use the personal information. However, the User is no longer allowed to use the Service as a member, so the User must withdraw from the membership. The User may request membership withdrawal by emailing us.
(8) If the User intends to receive relief for the exercise of rights under each paragraph of this Article or infringement of rights and interests related to personal information, the User may request the relief through emailing us or the Personal Information Protection Manager.
Article 11 (International Transfer of Personal Information)
In the event of personal information transfer, the Company applies protective measures according to the applicable laws to protect personal information and keep appropriate levels of protection.
Article 12 (Measures to Ensure the Safety of Personal Information)
The Company takes necessary technical, administrative, and physical measures in handling the personal information of the User as follows:
(1) Since the Company encrypts the password of the User to store and manage it, only the User may know it, and only the User who knows the password may check and change his/her personal information.
(2) The Company installs the system in areas where access from the outside is controlled to prevent personal information of the User from being leaked or damaged by hacking or computer viruses. The Company backs up data from time to time in prevention of damage to personal information and uses the most up-to-date vaccine program to prevent it from being leaked or damaged. In addition, the Company provides secure transmission of personal information on the network through cryptographic communication.
Article 13 (California “Shine the Light” Law)
If the User is a California resident, the User can request and obtain, once a calendar year free of charge, personal information that we shared/disclosed with other third parties, including businesses for direct marketing purposes. The personal information would include the categories of User information, as well as the names and addresses of those businesses with which we shared User information for the immediately prior calendar year. To submit a request, contact us at firstname.lastname@example.org.
Article 14 (California Requirements under the California Consumer Privacy Act)
(1) The California Consumer Privacy Act (CCPA) requires specific disclosures for residents of the State of California. The CCPA provides to the residents of the State of California the right to request information about how the Company collects, uses, and discloses User’s personal information. And it gives the User the right to access the User information and request that the Company delete that information. The CCPA also provides the right to not be discriminated against for exercising the User’s privacy rights.
(2) Users can exercise their rights by using the User control settings, which allow you to manage your User information, including accessing, reviewing, revising, and removing your information. If a User is a resident of the State of California and has questions or requests related to rights under the CCPA, the User can contact the Company’s Personal Information Protection Manager.
Below are the specific categories of personal information we may collect. While the information enumerated below is not always collected by the Company, residents of the State of California may nevertheless request whether such information was collected from the Company. The Company will provide this information to the User who requested it free of charge. Further, the Company will provide the User with the following information for the 12-month period preceding the User’s request.
- Identifiers: Name (such as real name, nick name), contact details including phone number, address, unique identifiers, online identifier (such as account name, email address), and IP (Internet Protocol) address.
- Personal information: Age, gender, education, date of birth, employment, and language.
- Commercial information: History of purchases made through the use of our Service, payment information, and transaction information.
- Biometric information: Voiceprints and fingerprints if you choose to provide them.
- Internet, network, and other activity information: Search terms, search history, interest data, online behavior, such as views and interactions with certain content, certain marketing events, certain advertisements, and interactions while using our applications and websites.
- Geolocation data: Device location as identifiable by Global Positioning System (GPS), IP address, or through other sensors associated with the User’s device.
- Audio, electronic, visual, thermal, and similar information: Audio, images, voice, and stream of images generated based on the User’s interaction with our Service.
- Professional, education, or employment-related information: Education and employment information that the User provides.
- Inferences drawn from the foregoing personal information: User’s interest, preferences, and characteristics.
If the User is a California resident and is under the age of 18, the User may request removal of personal information and User content publicly posted through the Service. Such request of removal should be directed to email@example.com.
The request should sufficiently specify the content so as for the Company to properly locate the content that is being requested for removal. The Company may further request additional information, including that such request is based on the fact that the User is a California resident.
Last updated: March 29, 2021