Privacy Policy

1. Our Privacy Statement

CLINKERS Co., Ltd. (the “Company” or “we”) has established and disclosed this privacy approach to explain how we handle your personal information, since the protection of your personal information is of great importance to us.

We handle your personal information in accordance with relevant regulations on data protection. This policy outlines how we collect, use, and disclose personal information as a data controller. We regularly review and update this policy and will notify you appropriately if significant updates are made.

2. Purpose of Collection, Data to be Collected, and Retention Period

“Personal Information” means any information relating to an individual, which enables the identification of such individual, whether directly or indirectly, but not including the information of the deceased persons.

In principle, we collect following personal information when users consent to the collection of their personal information in the process of registering as a member and using the Company’s service to achieve the purposes described in this Privacy Policy.

Service

Purpose of Collection

Collected Items

Retention Period

Notes

User Registration

Account creation, identity verification, service provision, user management, prevention of abuse, sending notifications, confirming intent to join, age verification, parental consent procedures, confirming user/legal guardian identity, user identification, confirming intent to withdraw

Email, nickname, password, social account info (Kakao, Facebook, Google, Apple)

Until account deletion

Social Sign-Up (Google)

[Required] Linked SNS ID, name, profile photo, email

Social Sign-Up (Kakao)

[Required] Linked SNS ID, nickname, email, KakaoTalk channel subscription info [Optional] Gender, birth date, birth year, phone number, profile photo

Social Sign-Up (Facebook)

[Required] Linked SNS ID, name, profile photo, email

Social Sign-Up (Apple)

[Required] Linked SNS ID [Optional] Email

Identity Verification

User identification for financial services, identity confirmation, personalized financial info

Encrypted CI (Connecting Information), DI (Duplication Information)

Until purpose is fulfilled

Customer Support

Handling inquiries and support requests

Info collected via web, email, fax, or phone

Up to 1 year after resolution

Offline Events

Event/seminar management and communication with participants

Collected through written documents

Until event ends or specified period

Third-party (Partner) Data Sharing

Personal information provided by partner/affiliated companies

Any information provided with user consent

Until purpose is fulfilled or within agreed consent period

Consent is required in accordance with the Personal Information Protection Act (PIPA)

Automatically Collected Items

Device info, statistics, personalized content

IP address, cookies, timestamps, usage records, device info

While using the service

Posts and Content

Collection of personal information through content uploaded, posted, or shared while using the service

Posts, images, comments, messages

While using the service

Includes all content submitted by the user

Traffic and Analytics

Measuring traffic and usage trends

Pages visited, post views, comments, poll results, session time, connection city, etc.

Collected and analyzed in anonymized, aggregated format

Not identifiable to individual users


•Automatically generated data such as device information may be collected during your use of the service via PC web or mobile web/app.
•We collect content that you submit through the company's services. Any content posted or shared during your use of the service (including but not limited to posts, images, comments, and chat messages) may contain personal information and may be collected.
•We use third-party analytics tools to collect data in order to measure service traffic and usage patterns.

3. Purpose of Personal Information Processing

The company processes collected personal information within the scope outlined below.

This applies as a policy-based and integrated purpose across all functions and services. • Personal information is used solely for member management, service development, provision, improvement, and the establishment of a secure internet environment for the company and other related services (including web/app).

• In addition to the purpose of providing existing services (including advertisements), personal information is used for demographic analysis, analysis of service visits and usage history, and building relationships between users based on personal information and interests (such as viewed posts, comments, poll results, time spent, and providing customized services based on mutual interests with acquaintances) in order to improve existing services and discover new service features.

• AI (Artificial Intelligence) technology is used for tasks such as information retrieval, user communication, content creation, provision, and recommendations in the development of new service features or the enhancement of existing services.

• Personal information is used to protect users and operate the service by taking preventive and sanction measures against actions that interfere with the smooth operation of the service, including but not limited to: imposing usage restrictions on users who violate applicable laws or the company’s terms of service, restricting service usage, preventing account theft and fraudulent transactions, sending notifications of changes to the terms, retaining records for dispute resolution, and handling civil litigation.

• Personal information is used for marketing and promotional purposes such as providing event information, opportunities to participate, and advertising content.

4. Destruction of Personal Information

• Personal information is retained and used until the user withdraws membership or the consignment contract is terminated, and the company, in principle, promptly destroys the user’s personal information once the purpose of use is fulfilled or the user withdraws membership. 

• However, if separate consent has been obtained from the user regarding the retention period of personal information, or if applicable laws require a certain retention period, the company securely stores the information for that period. 

• Personal information that has fully fulfilled its collection and use purpose due to reasons such as membership withdrawal, service termination, expiration of the user-agreed retention period, or expiration of the legally mandated retention period, is destroyed in an irreversible manner. 

• Information that is legally required to be stored (e.g., login records under the Protection of Communications Secrets Act: required to be stored for 3 months) is also destroyed without delay in an unrecoverable manner after the mandatory retention period expires. 

• Personal information stored in electronic form is securely deleted using technical methods to prevent recovery or reproduction, and information in paper form is shredded or incinerated for destruction. 

• CI (Connecting Information) and DI (Duplication Information) collected for identity verification are also promptly and securely destroyed using equivalent technical and managerial protection measures after their collection and use purposes have been achieved. 

5. Legal Basis for Processing Personal Information

The legal basis for processing your personal information is as follows:

• A consent basis, when it is required by law to obtain a consent for processing;

• When the processing activity is necessary for the performance of contractual obligations to perform contractual obligations between you and the Company;

• When the processing activity is required for the pursuit of legitimate interests of the Company, except the case where your primary right should be greater than such benefit; and

• When the processing activity is required for the compliance with our legal obligations.

If we rely on your consent for processing, you may withdraw your consent at any time by the method separately designated by us from the timing of obtaining your consent. However, withdrawal does not affect the legality of processing based on consent before it was withdrawn.

If the provision of certain personal information is legally or contractually required, or necessary to enter into a contract, we will notify you of any consequences of not providing such data.

6. Your Rights as Data Subject

You have the following rights regarding the personal information we collect and process through the service at any time.
 
• Right to withdraw consent: You have the right to withdraw your consent at any time from the moment it is given. However, this does not apply when the consent is necessary to fulfill legal or contractual obligations. Withdrawal of consent does not affect the lawfulness of processing carried out based on consent before its withdrawal.
 
•Right of access to personal information: You have the right to access the personal information processed about you and to obtain a copy of it, as well as the right to request disclosure of how the company obtained such information.
 
•Right to receive or transfer personal information: You have the right to receive your personal information (in a structured, commonly used, and machine-readable format) or to have it transmitted to another party.
 
•Right to object to the collection, use, or disclosure of personal information: You have the right to object to the processing of your personal information.
 
•Right to deletion of personal information: You have the right to request the deletion or destruction of your personal information, or to make such information unidentifiable.
 
•Right to restrict processing of personal information: You have the right to request the company to stop processing your personal information.
 
•Right to correction of personal information: You have the right to request the correction of inaccurate personal information to ensure it is complete and up to date to avoid misunderstandings.
 
•Right to file a complaint: You have the right to file a complaint with the competent data protection supervisory authority if the company violates or fails to comply with data protection laws.
 
If a user requests correction of an error in their personal information, the company will not use or provide that information until the correction is completed. If the inaccurate personal information has already been provided to a third party, the company will promptly notify the third party of the correction result so the correction can be applied. To exercise the above rights, please contact us through the contact details provided at the end of this Privacy Policy.

7. Information Protection Security Measures

The Company implements appropriate and strict security measures for preventing unauthorized or unlawful loss, access to, use, alteration, correction, or disclosure of Personal Information.

In cases where the Company assigns any third party to process your Personal Information pursuant to the instructions given by or on behalf of the Company, the Company shall appropriately supervise such third party to ensure the protection of your Personal Information.

8. Contact Information

The Company has designated the following individual as the Data Protection Officer to address user inquiries and related complaints regarding Personal Information.

CLINKERS Co., Ltd.
Data Protection Officer: Jung Sung Hyun
Email: privacy@clinkers.io
Address:
19-115, 83 Uisadang-daero, Yeongdeungpo-gu, Seoul, Korea
Phone: +82-2-6949-521