Note that the "Supplementary Terms" contain specific additional regulations for certain jurisdictions such as the EU or California.
Effective Date: September 30, 2021
1. Personal Information We Collect
Information You Provide Directly to Us or we receive from Third Parties
We may collect information directly from you or from other companies with whom you have a relationship. For example:
Information about Your Use of Our Service
Links to Other Websites, Devices, Apps and Features
Provision of our Service based on your contractual relationship with us
We process your personal information when this is necessary under our contract with you, to:
Use of information for further purpose
3. Sharing of Information
We transfer or disclose your personal information to third parties as described below:
4. Retention of Personal Information
We take appropriate steps to ensure that we process and retain information in accordance with the following principles:
5. Your Choices
Where permitted we may contact you via email, phone call, text messages or push notifications through our mobile apps. To submit a request concerning the receipt of such communications from us, please contact us using the information specified in the “Contact Us” Section below.
You can unsubscribe from our marketing communications at any time by contacting us directly (see "Contact Us" section below). As noted in the Your Rights section below, you have the right to object to use of personal data for direct marketing purposes at any time.
6. Your Rights
To the extent provided by applicable law, you can request access to your personal information, or correct or update out-of-date or inaccurate personal information we hold about you. You may also have the right to request that we delete personal information that we hold about you. You may access and update some of your information through your account settings. You are responsible for keeping your personal information up-to-date.
To the extent provided by applicable laws, you can also ask us to restrict or limit the processing of your personal information, as well as to provide you with personal information that we have collected from you so that you may use it for your own purposes, and to ask us to share (port) this data to another controller.
In addition, to the extent provided by applicable law, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement).
You also may have the right under applicable law to object at any time to the use of your personal information for direct marketing purposes, including profiling relating to direct marketing.
However, these rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. We will inform you of relevant exemptions we rely upon when responding to any request you make. To make a request concerning your rights or to make an inquiry, use the contact details under the "Contact Us"” section below.
7. How We Protect Personal Information
We take the protection of your information seriously and we have in place safeguards designed to protect the information we collect through our Service. However, please note that although we take reasonable steps to protect your information, no website, Internet transmission, computer system, or wireless connection is completely secure.
Please note, however, that the Service allows you to share text messages, photos, screenshots, videos and other communications in the Service with other users, and if you choose to share these items with other Service users, we may not be able to remove them from our servers or make them unavailable to anyone you have shared them with. Sending and sharing text messages, photos, screenshots, videos or other communications in the Service is your decision. By choosing to share that information, you should understand that you may no longer be able to control how that information is used and that it may become publicly available (depending in part on your actions or the actions of others with whom you have shared the information). The Service is not responsible for any use or misuse of information you share.
8. Personal Information of Children
The Service is not directed to children under the age of fourteen (14) and we do not knowingly solicit or collect personally identifiable information from children under the age of fourteen (14) as part of the Service. Additionally, we do not knowingly sell the personal information of children under the age of sixteen (16). If we become aware that we have inadvertently received personally identifiable information from a user under the age of fourteen (14) as part of the Service, we will immediately delete such information from our records. If you believe that a child under the age of fourteen (14) may have provided us with personal information, please contact us using the information specified in the "Contact Us" section below.
9. Contact Us
For more information about our privacy practices, or to exercise any rights you may have pursuant to applicable law, please contact us at email@example.com or via post 20F, ASEM Tower, 517, Yeongdong-daero, Gangnam-gu, Seoul, Republic of Korea. In addition, our Data Protection Officer can be contacted at firstname.lastname@example.org. .
For Users Having Usual Residence in European Economic Area (EEA), UK or Switzerland
A. International Transfer of Personal Information
If you are a resident in the EEA (that is in the European Union and Iceland, Lichtenstein, Norway), UK or Switzerland, we will transfer your personal information to the Republic of Korea and other countries outside the EEA, UK or Switzerland including the United States, Turkey, Malta, Thailand, Egypt, India, Hong Kong and Columbia.
We are a company based in South Korea. Though there are no adequacy decisions between South Korea and your country of residence, the data transfer to Korea is nevertheless justified because all data we collect is also necessary to provide the Services.
Where we share your data with recipients as described, we will take appropriate measures, in compliance with applicable laws, to ensure that your personal information remains adequately protected. Such measures include for instance the use of EU approved Standard Contractual Clauses. In some instances, we will also rely on your explicit consent, where this is appropriate. To request more information or obtain a copy of the contractual agreements or other safeguards in place, use the contact details set out in the “Contact Us” Section.
B. How We Use this Information – additional information
The purposes and legal grounds for processing personal information are described above in section 2. In this section, we describe in which cases we will rely on consent:
On other occasions where we ask you for consent, we will use the data for the purpose explained to you at that time. When we rely on your consent, you always have the right to withdraw your consent at any time. This will not affect the lawfulness of any processing we carried out before you withdrew your consent. To exercise this right, please see the “Your Rights” section.
C. Personal Information of Children
For the users having usual residence in the EEA, UK or Switzerland, Section 8 should read as follows; Our Service is designed for a general audience and is not directed towards children. In connection with our Service, we do not knowingly collect or maintain personal information from anyone under the age of sixteen (16) or knowingly allow such persons to use our Service. If you are under sixteen (16), please do not attempt to register for our Service or provide us with any personal information. If we learn that a person under the age of sixteen (16) has provided us with any personal information, we will promptly delete such personal information. If you believe that a child under age sixteen (16) may have provided us with personal information, please contact us using the information specified in the Contact Us” section.
To comply with the General Data protection Regulation (2016/679) we have appointed a European representative. If you wish to contact them, their details are as follows:
Bird & Bird GDPR Representative Ireland
29 Earlsfort Terrace
Main point of contact : Vincent Rezzouk-Hammachi.
You can also contact a data protection authority in case of complaints.