Privacy Policy

Article 1 (Items of Personal Information Collected and Methods of Collection)

1. Sign-up

   When users agree to the collection of personal information and enter their personal information themselves during the sign-up process or while using the service, the relevant information will be collected. If a user does not agree to the collection of personal information, they will not be able to sign up for an account and may be restricted from using some of the services. The items collected are as follows:

   Sign-up Method	Items Collected	Purpose of Collection	Retention Period
   Traditional Sign-up	Email address, password, gender, and year of birth	To enable services and to conduct analysis for providing customized services and improving the services	One year after deletion of account
   Sign-up Using Social Media Account	Required : (All) Social media ID Kakao : (Required) Nickname, profile picture, email address, year of birth, status and history of Kakao Talk Channels, and phone number (Optional) Gender and age (range) Google : (Required) Email address Apple : (Optional) Email address

2. Payment

   Personal information may be collected by the personal information trustee (payment providers) during the payment process done in-app or through an external website, but the Company does not keep any information related to the payment.

3. Customer Support

   In the process of providing customer support through the customer center, personal information may be collected via web pages, email, messenger service (Channel.io Live Chat), telephone, etc.

   This information includes the user's email address, details of the customer support interaction (including text, images, videos), etc.

4. Marketing and Advertising

   After obtaining consent from users, personal information may be collected through campaigns, promotions, surveys, etc. conducted for marketing purposes. In the event that additional personal information needs to be collected, further consent will be obtained after informing users of the items to be collected, the purpose of collection and use, and the retention period at the time of collection.

5. History of Using the Service

   Automatically-generated information, such as device information, may be collected in the process of using the mobile application.

   This information includes: IP address, cookies, history of using the service, and/or device information

Article 2 (Purpose of Collecting and Using Personal Information)

1. For fulfilling a contractual obligation regarding providing services and processing payments occurring therefrom:

   To provide content, deliver goods, send invoices, process identity verification, and enable purchases and payments

2. For managing accounts:

   To check users for their subscriptions, identify individuals, prevent any abusive or unauthorized use, confirm the user's intent to subscribe, check the user's age, confirm the legal guardian's agreement to the collection of personal information for children under the age of 14, provide customer support, and inform users of notices

3. For use in marketing and advertisements

   To provide information on the service, conduct marketing and advertising activities, provide services and display advertisements according to demographic characteristics, compile statistics on users' use of services, send advertising information related to special promotional events, and conduct customer surveys

Article 3 (Consent to Collection of Personal Information)

Article 4 (Period of Retention and Use of Personal Information)

1. When retaining personal information based on the Company's policies:

   1. Retention period in the case of deletion of an account:

      -Grounds for retention: To prevent abusive users from signing up again, or for cooperation in defamation disputes and/or investigations

      -Retention period: One year after deletion of the account

2. When retaining personal information based on the laws of the Republic of Korea:

   1. Records of contracts or cancellations of contracts:

      - Grounds for retention: Act on the Consumer Protection in Electronic Commerce

      - Retention period: Five years

   2. Records on payment and provision of goods, etc.:

      - Grounds for retention: Act on the Consumer Protection in Electronic Commerce

      - Retention period: Five years

   3. Records of consumer complaints or dispute handling:

      - Grounds for retention: Act on the Consumer Protection in Electronic Commerce

      - Retention period: Three years

   4. Records on identity verification:

      - Grounds for retention: Act on Promotion of Information and Communications Network Utilization and Information Protection

      - Retention period: Six months

   5. Records on visiting history:

      - Grounds for retention: Act on Promotion of Information and Communications Network Utilization and Information Protection

      - Retention period: Three months

Article 5 (Disposal Procedures and Methods for Personal Information)

1. Procedure

   1. Once its purpose has been fulfilled, the information entered by the user during sign-up, etc. is transferred to a separate database (separate filing cabinet in case of paper) and it is deleted or otherwise destroyed after being stored for a certain period of time (see Article 4 Period of Retention and Use of Personal Information) in accordance with the information protection grounds established by the Company's policies and other relevant laws and regulations of the Republic of Korea.
   2. Personal information will not be used for any other purposes except for when it needs to be used in accordance with the laws and regulations of the Republic of Korea.

2. Methods

   1. Personal information printed on paper is destroyed by shredding or incineration.
   2. Personal information stored in the form of electronic files will be deleted in such a way that the records cannot be reproduced.

Article 6 (Consignment of Collected Personal Information)

1. The companies to which the Company entrusts personal information, the details of entrusted operations, and the period of retention and use of the entrusted personal information are as follows:

   Entrusted companies	Entrusted operations	Period of retention and use of personal information
   Google Cloud Platform	Operating servers	Until the account is deleted or the consignment contract is terminated
   Amazon Web Services, Inc.
   Microsoft Azure
   Danal, Inc.	Providing identity verification programs
   NURIGO, Inc.	Sending text messages and KakaoTalk notifications
   Kakao Pay Corp.	Providing electronic payment services
   NICE Payments Co., Ltd.
   Channel Corp.	Providing live chat services for customer support

2. The Company transfers personal information to partners overseas to provide services, and the details are as follows:

   Name and email address of the entrusted company	Location of the entrusted company	Entrusted operations	Transfer time and method	Transferred items	Period of retention and use of personal information
   Braze, Inc. (privacy@braze.com)	USA	- Collecting history of using mobile application - Sending mobile notifications - Sending notices such as in-app push notifications, emails, etc	Transferred through networks when the user uses the service	- Email address - Mobile number - Mobile device ID	Until the account is deleted or the consignment contract is terminated

Article 7 (Rights of Users and Legal Guardians and Exercising Their Rights)

1. A user or legal guardian may view or correct their registered personal information at any time and retract their agreement to the Privacy Policy by deleting the account.
2. In the event that a user or legal guardian requests to correct an error in their personal information, the Company will not use or provide their personal information until the correction is completed.
3. The Company shall process personal information that has been modified or deleted upon the request of a user or legal guardian as specified in "Article 4 (Period of Retention and Use of Personal Information)" and shall not allow it to be viewed or used for any other purposes.
4. A user or legal guardian may inquire about any related matters by emailing the Chief Privacy Officer.

Article 8 (Installation, Management, Refusal of Automatic Collection for Personal Information)

Article 9 (Technical and Administrative Measures to Protect Personal Information)

1. The Company minimizes the number of employees handling personal information, emphasizes the importance of compliance with the Privacy Policy through training of the employees in charge, and implements the following technical and administrative measures to protect personal information:

   1. The Company is fully equipped with firewalls and security systems to prevent hacking.
   2. The Company installs SSL certificates to protect information when sending and receiving personal information.
   3. Access to personal information is strictly limited to only the relevant employees and those for whom handling personal information is unavoidable when performing their own duties, and all other employees are prevented from accessing it.
2. The user's personal information is protected by a password. An account's password can only be known by the user themself, and thus checking and changing personal information is possible only by the person who knows the password. The Company shall not be held responsible for any leakage of personal information due to user negligence.

Article 10 (Personal Information of Children Under 14)

Article 11 (Privacy Officer)

Chief Privacy Officer

Name - Park Jongheum

Organization - EpopSoft Inc.

Position – CEO

Privacy Officer

Name - Kim Woojun

Organization - EpopSoft Inc.

Position - CPO

Email address - privacy@epop.ai

Addendum