This translation is for informational purposes only. If there is a difference between the Korean version and this translation, the Korean version shall prevail.
Nodamen Co., Ltd.(hereinafter referredto as the”Company”) strictly complies with domestic privacy laws such asthe Act on Promotion of Information and Communication Network Utilization and Information Protection (hereinafter referred to asthe “InformationandCommunication Network Act”)and the Personal Information Protection Act from the planning to the end of patron services(hereinafter referred to asthe “Service”).
We alsoprovide services in compliance with international standards, such as the OECD’s privacy guidelines.
TheCompanycomplieswith all personal information protection regulations and notices, orders, and guidelinesestablished bystate agencies, includingthe Personal Information ProtectionAct, the Act on Promotionof Information and Communication Network Utilization and Information Protection(hereinafter referred toas the”Information and Communication NetworkAct”),which arethe mainlaws related to the protection of personalinformation.
- Provide transparent information about what information the Companycollects, howit usesit, shares it with whomever it needsto, and when and how it destroys information that has been achieved.
- As an informationsubject, you will be informed of the rights you have to your personal information and how and how you can exercise it. It also providesguidance on what rights legal representatives(suchasparents) can exercise to protect the privacy of children under the age of 14.
2. Personal information we collect
○ The information collectedby the “Company”from the “User”at the time of membershipis as follows.
- When signingup, we collect’username, ID,password, mobile phone number’in the form of an email addressas requireditems. If the date of birth entered by the user isa child under the age of14,additional legalrepresentative information(name, date of birth, gender, duplicate registration confirmation information(DI), mobile phone number)will becollected. It also collects profile information as an optional item.
- When you sign up for a group ID, we collect groupIDs, passwords, groupname, email address, and mobile phone numbers as requireditems. We also collect the name of the organization’s representative as anoption.
○ The personal information collected from the user during the use of the “Service” is asfollows.
- Additional personal information collection may occur only to users of the service during the use of individual services within theCompany, entry to events, and application for prizes. In addition, when collecting personal information, we will inform you and consent to the “itemsofpersonal informationcollectedby users at the time of collection of personal information, the purpose of collection and use of personalinformation, andthestorage period of personalinformation”.
○ Ip addresses, cookies,service usage records, and device information may be generated and collectedduring the use of the service. Images or voices may also be collected from search services using images and voices.
- Specifically, 1) In the course of using the Service, information about the user is generated in an automated manner and stored(collected),or2) the unique information of the user’s device is safely converted and collected so that the original value can not be confirmed.
- The information collected may correspond to personal information, depending on whether it is linked to personalinformation, and may not be personal information.
○ The”Company”collects personal information through the followingmethods:
- If the user consents to the collection of personal information and enters the information directly during the registration and use of theservice, the personal information is collected.
- Your personal information may be collected through webpages, e-mails, faxes,telephones, etc. during theconsultation process through the CustomerCenter.
- Personal information may be collected in writing at offlineevents, seminars, etc.
- Personal information may be provided by external companies or entities affiliated with theCompany, in which case the Affiliate receives consent to provide personal information to the user in accordance with the Information and Communication Network Act and provides it to the Company.
- Generated information, such as device information,may be automatically generated and collected during the pcweb, mobile web,andapp usageprocess.
3. Use of collected personal information
○Member management of the company and all related services(includingmobileweb/app), service development· Personal information is used only for the followingpurposes, such as providing and improving it, and establishing a safe internet use environment.
- We use personal information to verify the intention to join themembership, verify the age and consentof the legalrepresentative, verify the identity of the user and legal representative,identify the user, and confirm the intention to withdraw frommembership.
- In addition to providing existing services such as content(including advertisements),personal information is used for the discovery of new service elements and improvement of existingservices, such as demographicanalysis, analysis of service visits and usage records, formation of user-to-user relationshipsbased on personal information andinterests, and provision of customized services based on acquaintances and interests.
- We use personal information to protect users and operateservices, such as restricting the use of members who violate laws and service terms andconditions, preventing and sanctioning acts that interferewith the smooth operation of theService, preventing account use and fraudulent transactions, delivering notices such as revisions to terms and conditions, preserving records for dispute mediation, and handling complaints.
- We use personal information for marketing and promotionpurposes, such as providing event information, opportunities to participate, and providing advertisinginformation.
- We use personal information for service usage records, frequency analysis of accessfrequency, statistics on service use, service analysis, and provision of customized services and advertisements according to statistics.
- We use personal information to establish a service environment that users can use with confidence in terms ofsecurity, privacy, andsafety.
4. Provision and consignment of personal information
○ In principle, the”Company”does not provide personal information to the outsideworld without the user’s consent.
- The Company does not provide personal information to the outside world without the prior consent of theuser. However,if the user directlyconsents to the provision of personal information in order to use the services of externalaffiliates, and if the company is obliged to submit personal information in accordancewith relevant laws and regulations, the company provides personal information only when an imminent risk to the user’s life or safety is identified and resolved.
5. Destruction of personal information
○ In principle, the “Company”destroys the user’s personal information without delay when withdrawing from membership.
- However, if the user obtains separate consent for the period of storageof personal information, or if the law imposes an obligation to retain information for a certain period oftime, the personal information will be stored securely for that periodoftime.
○ The following is the case when theuserhas obtained consent when signing up for membership or when signing up for the service for the periodof personal informationstorage.
- Prevent fraudulent sign-up and use
-Registration authentication mobile phone number or DI (di as a legal representative for under 14years old): 6months from the time of collection
-Mobile phone number of the user who left(one-way encryption(hashprocessing)that cannot bedecrypted: 6months from the date of withdrawal
○ The following cases stipulate the storage of information for a certain period of time in laws such as the Consumer Protection Act in e-commerce, the Electronic Financial TransactionsAct, and the Communications Secret Protection Act. During this period,theCompanywill retain personal informationin accordance with the provisions ofthe laws andregulations and will never use this information for any other purpose.
- Consumer Protection Act in e-commerce, etc.
– Records on contracts or withdrawals:5years storage
– Records on payment and supply of goods:5years storage
– Records of consumer complaints or dispute handling:3years of storage
- Electronic Financial Transactions Act
– Records on electronic finance:5years of storage
- Communication Secret Protection Act
– Login history:3months
○ Personal information that has been collected and used for the purpose of collecting and using personal information is destroyed in a non-renewable manner, such asthe withdrawal ofmembership, termination of service, and arrival of personal information retention period agreed to by theuser.
Information imposed by law on retention obligations shall also be destroyed in a way that cannot be reproduced without delay after the periodhas elapsed.
- In the case of electronic files, they are safely deleted using technical methods to prevent recovery andplayback, and printouts are destroyed by crushing or incineratingthem.
6. Rights of users and legal representatives and how to exercise them
- You can view or modify your personal information atany time bymodifying your membership information > yourPatron Profile.
- Users can withdraw their consent to the collection and use of personal information atany time through ‘membership withdrawal’.
- For children under the age of 14,their legal representatives have the right to view or modify the child’s personal information, and to withdraw their consent to collect and use it.
- If the user requests correction of errors in personalinformation, the personal information will not be used or provided until the correction is completed. In addition,if the wrong personal information has already beenprovided to a third party, the result of the correctionwill be notified to the thirdparty without delay so that the correction can be made.
7. The Company’s Commitment to Privacy
○ The Company does its best to securely manage the personal information of users and protects personal information beyond the level required by the Information and Communications Network Act and the Personal Information ProtectionAct.
○ Securely manage personal information from security threats both internally andexternally.
- In order to prevent the leakage or damage of members’ personal information due to hacking or computer viruses, the system is installed in areas with controlled access fromoutside. We back up data from time to time in case of personal information damage, and we use the latest antivirus program to prevent users’ personal information or data from being leaked ordamaged. We securely send and receive personal information on the network through encryptedcommunication.
○ Keep personal information recipients to aminimum.
- We minimize the management of employees who process personalinformation, and we separate external internet networks from internal networks for employees’ business PCsthat can download personal information from the personal information processingsystem, reducing the possibility of personal information leakage. In addition,through regular training for personal informationrecipients, regular training and campaigns for employees of the company, we are constantly emphasizing that the protection of member privacy is the company’s most important value.
8. Privacy Officer and Contact Information
○ The Company designates the personal information protection officer and person in charge as follows for the handling of inquiries and complaints related to the user’s personalinformation.
Last Name : Lee Won-jun
Above the ranks: CEO
[Personal Information Manager]
Last Name : Jowang Kim
Position : Service Planning Team Leader
○ If you need to report or consult about other personal information infringement, you can contact the followingorganizations:
- Personal Information Infringement Report Center (privacy.kisa.or.kr / 118 without local number)
- Cyber Investigation Division of the Supreme Prosecutor’s Office (www.spo.go.kr/ 1301 without a local number)
- Cyber Safety Bureau of the National Police Agency (police.go.kr / 182 without a local number)
10. Pre-amendment notice obligations
- Announcement Date:September 01, 2020
- Effective date:September 01, 2020