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This Privacy Policy (the "Policy") explains the way of treatment of the information which is provided or collected in the applications on which this Policy is posted. In addition the Policy also explains the information which is provided or collected in the course of using the applications of the Company which exist in the applications or platforms of other company.

Through this Policy, the Company regards personal information of the users as important and inform them of the purpose and method of Company's using the personal information provided by the users and the measures taken by the Company for protection of those personal information.

This Policy will be effective on 20 Feb, 2019 and, in case of modification thereof, the Company will make public notice of it through posting it on the bulletin board of Company's Application or Homepage.


1. Information to be collected and method of collection

(1) Personal information items to be collected

• Information collected while the users use services

Besides of information directly provided by the users, the Company may collect information in the course that the users use the service provided by the Company.

[Items of personal information]
- Equipment information : Equipment identifier, operation system, hardware version, equipment set-up
- Log information: Log data, use time, internet protocol address, cookie and web beacon
- Other information: Preference, advertisement environment, visited pages regarding service use of users

(2) Method of collection

The Company collects the information of users in a way of the followings:
• Information collected on the system when using the service

2. Use of collected information

The Company uses the collected information of users for the following purposes:

[Use of collected information]

• To detect and deter unauthorized or fraudulent use of or abuse of the Service
• Making notice of function of company applications or matters on policy change
• To make statistics on member’s service usage, to provide services and place advertisements based on statistical characteristics
• To comply with applicable laws or legal obligation


The Company agrees that it will obtain consent from the users, if the Company desires to use the information other than those expressly stated in this Policy.


3. Sharing collected information

Except for the following cases, the Company will not share personal information with a 3rd party:
• when the Company shares the information with its affiliates, partners and service providers;

[ Sharing of collected information]
○ When the Company's affiliates, partners and service providers carry out services such as bill payment, execution of orders, products delivery and dispute resolution (including disputes on payment and delivery) for and on behalf of the Company

• when the users consent the sharing in advance;

[ Sharing of collected information]

○ when the user selects to be provided by the information of products and services of certain companies by sharing his or her personal information with those companies
○ when the user selects to allow his or her personal information to be shared with the application or platform of other companies such as social networking sites
○ other cases where the user gives prior consent for sharing his or her personal information


• when the sharing is required by the laws

- if required to be disclosed by the laws and regulations; or
- if required to be disclosed by the investigative agencies for detecting crimes in accordance with the procedure and method as prescribed in the laws and regulations


4. Cookies and Similar Technologies

The Company may collect collective and impersonal information through 'cookies'.
Cookies are very small text files to be sent to the browser of the users by the server used for operation of the application of the Company and will be stored in hard-disks of the users' mobile phone.

These functions are used for evaluating, improving services and setting-up users' experiences so that much improved services can be provided by the Company to the users

The items of cookies to be collected by the Company and the purpose of such collection are as follows:

[ Collecting cookies]
Category Reasons for using cookies and additional information






strictly necessary cookies This cookie is a kind of indispensable cookie for the users to use the functions of
application of the Company. This cookie does not collect any information which may be used for marketing or memorizing the sites visited by the users


○ For the page of products and check-out, memorize ordered services
○ Check whether login is made on application
○ Check whether the users are connected with correct services of the application of the Company while the Company changes the way of operating its application
○ Connect the users with certain application or server of the services







performance cookies This cookie collects information how the users use the application of the Company such as the information of the pages which are visited by the users most. This data helps the Company to optimize its application so that the users can search that application more comfortably. This cookie does not collect any information of the users. Any and all the information collected by this cookie will be processed collectively and the anonymity will be guaranteed.
○ Application analysis: provide statistical data on the ways of using application
○ Advertisement response fee: check the effect of advertisement of the Company

○ Tracing affiliated companies: one of visitors of the Company provides anonymously feedback to the affiliated companies
○ Management of error: measure an error which may occur so as to give a help for improving application
○ Design testing: test other design of the application of Company



5. Users' right to access and option
The users or their legal representatives, as main agents of the information, may exercise the following options regarding the collection, use and sharing of personal information by the Company:
• exercise right to access to personal information;
• make corrections or deletion;
• make temporary suspension of treatment of personal information; or
• request the withdrawal of their consent provided before

If, in order to exercise the above options, you, as an user, use the menu of 'amendment of member information’ of application or contact the Company by using representative telephone or sending a document or e-mails, or using telephone to the responsible department (or person in charge of management of personal information), the Company will take measures without delay: Provided that the Company may reject the request of you only to the extent that there exists either proper cause as prescribed in the laws or equivalent cause.


1. Security

The Company regards the security of personal information of uses as very important. The company constructs the following security measures to protect the users' personal information from any unauthorized access, release, use or modification

[ Security measures]

• Encryption of personal information

- Transmit users' personal information by using encrypted communication zone
- Store important information such as passwords after encrypting it

• Countermeasures against hacking

- Install a system in the zone the external access to which is controlled so as to prevent leakage or damage of users' personal information by hacking or computer virus
• Establish and execute internal management plan

• Install and operate access control system

• Take measures to prevent forging or alteration of access record


2. Modification of Privacy Protection Policy

The Company has the right to amend or modify this Policy from time to time and, in such case, the Company will make a public notice of it through bulletin board of its application (or through individual notice such as written document, fax or e-mail) and obtain consent from the users if required by relevant laws.


3. Others

[Data transmission]

Considering it engages in global businesses, the Company may provide the users' personal information to the companies located in other countries for the purpose as expressly stated in this Policy. For the places where the personal information is transmitted, retained or processed, the Company takes reasonable measures for protecting that personal information.

In addition, when the personal information obtained from the European Union is used or disclosed, the Company may have to comply with safe harbor principle as required by the Commerce Department of USA, take other measures or obtain consent from users so far as those complies with the regulations of EU so as to use a standardized agreement provision approved by executing organizations of EU or securing proper safe measures.


[3rd party's sites and services]

The service of the Company may include the links to the ones of a 3rd party and the privacy protection policy of the site of 3rd party may be different. Thus, it is required for the users to check additionally that policy of a 3rd party site linked to the site of the Company.

[Guide for users residing in California]
If the user resides in California, certain rights may be given. The Company prepares preventive measures necessary for protecting personal information of members so that the Company can comply with online privacy protection laws of California.

In case of leakage of personal information, a user may request the Company to check the leakage. In addition, all the users in the application of the Company, can modify their information at any time by using the menu for changing information by connecting their personal account.

Moreover, the Company does not trace the visitors of its application nor use any signals for 'tracing prevent'. The Company will not collect and provide any personal identification information through ad services without consent of users.

[Guide for users residing in Korea]
The Company guides several additional matters to be disclosed as required by the information network laws and personal information protection laws in the Republic of Korea as follows:

(1) Information collected
The items collected by the Company are as follows:
• Required information

- In the course of using services, the information as described below may be created and collected:
○ Information of devices (equipment/device identifier, operation system, hardware version, equipment set-up)

○ Log information (Log data, use time, cookie)


○ Location information (Information of device location including specific geographical location detected through GPS, Bluetooth or Wi-Fi)

○ Other created information

• Additional procedure for collection of sensitive information

(1) Period for retention and use of personal information

In principle, the Company destructs personal information of users without delay when: the purpose of its collection and use has been achieved; the legal or management needs are satisfied; or users request: Provided that, if it is required to retain the information by relevant laws and regulations, the Company will retain member information for certain period as designated by relevant laws and regulations. The information to be retained as required by relevant laws and regulations are as follows:

○ Record regarding contract or withdrawal of subscription: 5 years (The Act on Consumer Protection
in Electronic Commerce)
○ Record on payment and supply of goods: 5 years (The Act on Consumer Protection in Electronic Commerce)
○ Record on consumer complaint or dispute treatment: 3 years (The Act on Consumer Protection in Electronic Commerce)

○ Record on collection/process, and use of credit information: 3 years (The Act on Use and Protection
of Credit Information)

○ Record on sign/advertisement: 6 months (The Act on Consumer Protection in Electronic Commerce)

○ Log record of users such as internet/data detecting the place of user connection: 3 months (The Protection of Communications Secrets Act)

○ Other data for checking communication facts: 12 months (The Protection of Communications Secrets Act)


(1) Procedure and method of destruction of personal information

In principle, the Company destructs the information immediately after the purposes of its collection and use have been achieved without delay: Provided that, if any information is to be retained as required by relevant laws and regulations, the Company retain it for the period as required by those laws and regulations before destruction and, in such event, the personal information which is stored and managed separately will never be used for other purposes. The Company destructs: hard copies of personal information by shredding with a pulverizer or incinerating it; and delete personal information stored in the form of electric file by using technological method making that information not restored.


(2) Technical, managerial and physical measures for protection of personal information

In order to prevent the loss, theft, leakage, alteration or damage of personal information of the users, the Company takes technical, managerial and physical measures for securing safety as follows:

- Technical measures:


○ Utilize security servers for transmitting encryption of personal information

○ Take measures of encryption for confidential information
○ Install and operate access control devices and equipments.
○ Establish and execute internal management plan
- Managerial measures

○ Appoint a staff responsible for protecting personal information

○ Provide education and training for staffs treating personal information

○ Establish and execute internal management plan
○ Establish rules for writing passwords which is hard to be estimated
○ Ensure safe storage of record of access to personal information processing system
○ Classify the level of authority to access to personal information processing system

- Physical measures
○ Establish and operate the procedure for access control for the facilities for storing personal information

○ Store documents and backing storage containing personal information in safe places which have locking device


(3) Staff responsible for managing personal information

The staff of the Company responsible for managing personal information is as follows:

 Name of staff responsible for managing personal information : Jihyun Kim
 Dept. : Service management
 Tel. : +82 2-718-6600 (#302)
 Contact : firenze@d-antwort.com


4. Responsible department of Company

The Company designates the following department and person in charge of personal information in order to protect personal information of customers and deal with complaints from customers:
[Department responsible for privacy protection and customer service]
 Name of staff responsible for managing personal information : Junhyung Park
 Dept. : Service management
 Tel. : +82 2-718-6600 (#902)
 Contact : catchupseoul@d-antwort.com


The date of latest update: 18 Feb , 2019




본 약관은 ㈜네이버의 『글로벌 서비스를 위한 영문 Privacy Policy 작성 가이드라인』 을 참고하여 작성되었습니다.