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Privacy Policy

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

We process your personal data in accordance with the applicable regulation relating to personal data protection. This Privacy Policy explains how we, as the data controller, collect, use, and disclose your personal data. In addition, we regularly review and update this Privacy Policy and in case of any significant update to this Privacy Policy, we will inform you as appropriate.
2. Personal Data to be Collected
“Personal Data” 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 Data when users consent to the collection of their Personal Data in the process of registering as a member and using the Company’s service to achieve the purposes described in this Privacy Policy.

• We collect your changeable nickname, password, Facebook registration ID or Google account during the process of registering, modifying, or using the Company’s service account.

• When signing up for membership with a real-name-authenticated ID, encrypted connecting information (CI), and duplication information (DI).

• Personal Data of users may be collected during the consultation process through the Company’s customer center via web pages, emails, faxes and telephone calls, etc.

• Personal Data may be collected through written documents at Company’s offline events, seminars, etc.

• Personal Data may be provided by external companies and organizations affiliated with the Company, and in such cases, in accordance with the Personal Data Protection Act, the affiliated company shall obtain consent from the user to provide Personal Data, etc. before providing it to the Company.

• During the use of PC web and mobile web/application to access the Company's service, certain information, such as device details, will be automatically generated and collected.

• We collect the content you submit to the Company’s services. Personal Data may be collected through all content posted or shared in the course of using the Company's services, including but not limited to postings, images, comments, and conversation content.

• We collect the following information using third party analytics tools to measure service traffic and usage trends.

- Pages and sections of the Company’s service visited, posted text queried, comments, poll results, time spent, user location, etc.

The above information is collected on an overall user basis, not on an individual user basis, and those shall not be used to identify specific users.

3. Purpose of Processing of Personal Data
• Personal Data is used only to manage members of the Company’s service and all other related services (including mobile web/app), develop, provide, and improve services, and establish a safe internet environment.

• Personal Data is used for management, such as confirming members’ intention to subscribe, confirming their age, proceeding with obtaining consent from legal representatives, verifying the identity of users and their legal representatives, identifying users, and confirming their intention to unsubscribe.

• In addition to the purpose of providing existing services (including advertisements) such as contents, Personal Data is also used for demographic analysis, analysis of visits to services and usage records, building relationships between user-to-user relationships based on Personal Data and interests, and providing customized services based on acquaintances and interests, in order to discover new service elements and improve existing services.

• For the development of new service elements or the enhancement of existing services, artificial intelligence (AI) technology is utilized for tasks such as information searching, user communication, the creation, provision, and recommendation of content.

• Personal Data is used to protect users and operate services by means such as preventing and imposing sanctions against acts that interfere with the smooth operation of services, including measures such as restricting the use by members who breach the statutes and User Agreement provided by the Company, preventing account theft and fraudulent transactions, sending out notices regarding a revision to the terms and conditions, preserving records for dispute mediation, and handling civil complaints.

• Personal Data is used for marketing and promotion purposes such as providing event information, opportunities for participation, and advertising information.

4. Destruction of Personal Data
Personal Data shall be held and used until the time of membership withdrawal of the services provided by the Company or the end of the outsourcing contract. In principle, the Company destroys users' Personal Data without any delay either when they withdraw from membership or when the company achieves its purpose of use.

However, if the Company has obtained separate consent from users regarding the retention period of Personal Data or if the laws and regulations impose duties to retain information for a certain period, Personal Data may be stored safely during the designated period. The Company shall obtain consent from users for the retention period of Personal Data at the time of their member or service subscription.

Personal Data that fully serve its purpose of collection and use, by means such as membership cancellation, service termination, and/or expiration of the retention period of Personal Data approved by the user, is destroyed to an irreversible state.

Information required to be retained under the statutes is also destroyed to an irreversible state without delay after the expiration of the required period.

Personal Data stored in electronic form is securely deleted by technical means to prevent its recovery or restoration, while written information is shredded or incinerated.

5. Legal Basis for Processing of Personal Data
The legal basis for the processing of your Personal Data 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.

In the event that the Company processes your Personal Data relying on a consent, you have the right to withdraw your consent at any time by the method separately designated by us from the timing of obtaining your consent. However, your withdrawal of consent will not affect the legality of processing conducted based on your consent before its withdrawal.

We will notify you separately, if the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as the possible consequences of failure to provide such data.

6. Your Rights as a Data Subject
Users may exercise the following rights regarding Personal Data obtained and processed through the Company’s service.

• Right to withdraw consent: You have the right to withdraw your consent at any time from the moment of obtaining your consent, unless the consent provided is necessary to fulfil legal or contractual obligations. However, withdrawing your consent will not affect the legality of processing conducted based on your consent prior to its withdrawal.

• Access to Personal Data: You have the right to access and obtain a copy of the processed Personal Data concerning you and to ask the Company to disclose where the Company obtained such Personal Data from.

• Obtaining information or transferring regarding processing of data: You have the right to receive or transfer Personal Data concerning you in a structured, commonly used, and machine-readable format that can be automatically accessed or disclosed to another controller.

• Right to object the collection, the use, or the disclosure of Personal Data: You have the right to object to the processing of Personal Data concerning you.

• Deletion of Personal Data: You have the right to have the Company to delete or destroy Personal Data concerning you, or to render such Personal Data unidentifiable.

• Restriction on processing of Personal Data: You have the right to have the Company stop processing Personal Data concerning you.

• Rectification of Personal Data: You have the right to have the Company rectify inaccurate Personal Data concerning you to be a completed and updated to avoid any misunderstanding.

• Right to lodge complaints: You have the right to lodge a complaint with a competent data protection supervisory authority when the Company violates or fails to comply with the laws regarding of Personal Data protection.

If a user requests the correction of errors in his/her Personal Data, the relevant Personal Data will not be used or provided until the correction is made. In addition, in the event where the incorrect Personal Data has already been provided to a third party, the Company will notify the third party of the corrected information without delay to ensure that the necessary correction is made.

If you intend to exercise any of the aforementioned rights, please inquire using the contact details at the end of this Privacy Policy.

7. Data 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 Data.

In cases where the Company assigns any third party to process your Personal Data 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 Data.

8. International Data Transfers
The Company is based in the Republic of Korea, and we process and store information on servers located in the Republic of Korea. We may store information on servers and equipment in other countries depending on a variety of factors, including the locations of our users and service providers. By accessing or using the Company's services or otherwise providing information to us, you consent to the processing, transfer, and storage of information in and to the Republic of Korea and other countries, where you may not have the same rights as you do under local law.

9. Contact details
The Company has designated the following individual as the Personal Data Manager to address user inquiries and related complaints regarding Personal Data.

CLINKERS Co., Ltd.

Personal Data Manager: SungHyun Jung

Email: privacy@clinkers.io

Address: 542, 81, Yanghwa-ro, Mapo-gu, Seoul, Republic of Korea, 04034

Phone number: 02-6949-0521