Personal Information Processing Policy
Function12, Inc. (hereinafter referred to as the “Company”) values
Personal Information of Users, and as a Provider of Information and
Communication Services, shall comply with Act on Promotion of
Information and Communications Network Utilization and Information
Protection, Personal Information Protection Act, Protection of
Communications Secrets Act, Telecommunications Business Act and other
relevant laws / regulations. According to such laws and regulations,
the Company has established Personal Information Processing Policy and
is safely managing Personal Information. Furthermore, the Company has
kept disclosing this Policy for Users to easily check anytime.
Collection and Use of Personal Information
The Company collects and processes all Personal Information for
the following purposes such as member management, development /
provision / improvement of services and safe mobile use
environment. Personal Information that has been processed shall
not be used for purposes other than the followings and if such
purposes are changed, the Company will seek prior consents from
the Users.
1. The Purposes of the collection and use of Personal
Information and relevant items
The services provided by the Company are freely accessible
without a separate membership registration. Personal
Information collected and used for membership services of the
Company will not be used for purposes other than the
followings, and as explained above, necessary measures such as
obtaining separate consents if the purposes are changed, shall
be executed.
1.1 Execution of contracts about provision of services,
provision and purchase and payment of contents about fee
settlements according to provision of services, etc., identity
verification for financial transaction and other financial
services
1.2 Member management identification for services
provided by the Company, Personal identification, Prevention
of illegal and unauthorized usage by defective/faulty members,
confirmation of intent for registration of membership,
confirmation of age, complaint handling and delivery of
notices
1.3 This information shall not be combined
with personally identifiable information.
1.4
Development and Specialization of new services (products) to
be utilized for marketing and advertisement, delivery of
advertising information such as coupons and events, provision
of services according to demographic characteristics as well
as advertisements
(Optional, and the Company does not provide personalized
advertisements to anyone aged under 14)
2. The Company only uses Users’ Personal Information within
the notified purposes under 「 The Purposes of the collection
and use of Personal Information and relevant items」 and the
Company shall not use such Personal Information outside the
aforementioned purposes and provide it to a third party.
However, the Company may provide Users’ Personal Information
to a third party in the following cases.
2.1 Cooperation Relationship: The Company may provide Personal
Information of Users to affiliates for provision of better
services. In this case, the Company shall obtain consents from
Users in advance after explaining about items of Personal
Information to be provided, the purposes and period of
provision, as well as protection measures. If Users do not
consent, the Company shall not provide Personal Information to
affiliates and notify to Users any changes or terminations of
relevant Cooperation Relationship. When a Cooperation
Relationship is terminated, and Users do not consent about
provision of their Personal Information, that information
already provided shall be destroyed without delay, Users can
always withdraw their consent about provision of their
Personal Information at any time.
2.2 Consignment: For smooth business operation and to provide better services to Users, the Company can consign processing of Users’ Personal Information to third parties. In this case, the Company shall notify to Users about names of consignees, purposes of consignment, scopes of Personal Information to be consigned, consignment periods in advance.
2.3 Disposal of Business, Mergers and Acquisitions: If the rights and obligations of the Service Provider are succeeded or transferred, this must be notified in advance, and Users’ option to withdraw their consents about personal information shall be given.
2.4 If there are special provisions in relevant laws and regulations. if it is necessary for fee settlements, if a transaction is made through the Service provided by the Company, for smooth communication and transaction between parties to a transaction and if it is necessary to provide information relevant to delivery within the required range, the Company may provide Personal Information to a third party.
2.2 Consignment: For smooth business operation and to provide better services to Users, the Company can consign processing of Users’ Personal Information to third parties. In this case, the Company shall notify to Users about names of consignees, purposes of consignment, scopes of Personal Information to be consigned, consignment periods in advance.
2.3 Disposal of Business, Mergers and Acquisitions: If the rights and obligations of the Service Provider are succeeded or transferred, this must be notified in advance, and Users’ option to withdraw their consents about personal information shall be given.
2.4 If there are special provisions in relevant laws and regulations. if it is necessary for fee settlements, if a transaction is made through the Service provided by the Company, for smooth communication and transaction between parties to a transaction and if it is necessary to provide information relevant to delivery within the required range, the Company may provide Personal Information to a third party.
3. Items of Personal Information for collection: Information
Users directly enter for using services provided by the
Company such as User ID, users’ play data, passwords,
addresses of delivery, transaction details, mobile phone
number, e-mail address, encrypted user verification value
(CI), bank account information, Business registration number,
name of business, name of representative of business, details
regarding connected third party accounts (such as the e-mail
or username for a connected PayPal, Google or Facebook
account), scanned identification documents provided to the
Company (such as an ID card, driver’s license, passport or
official company registration documents, student ID), service
use records, access logs, cookies, access IP information,
geo-location, payment records, etc.
4. Methods of collecting Personal Information
4.1 Via Homepage (membership registration, profile editing,
account setting, etc.)
4.2 Automatically collected through running or using service programs provided by the Company
4.3 Collection through voluntary provision of Personal Information by Users during service subscription or usage
4.2 Automatically collected through running or using service programs provided by the Company
4.3 Collection through voluntary provision of Personal Information by Users during service subscription or usage
The Period for retaining and using Personal Information
1. The Company processes and retains Personal Information
within the period agreed by Users when collected
1.1 Membership Information: up to 90 days after membership
withdrawal
1.2 Non-Membership Information: Until purposes of business are achieved
Nevertheless, the Company may retain Personal Information until cases are closed if an investigation is in progress about violations of laws and regulations by a particular User, and until the time of settlement if there remains a claim-obligation relationship due to that User’s usage of services.
1.2 Non-Membership Information: Until purposes of business are achieved
Nevertheless, the Company may retain Personal Information until cases are closed if an investigation is in progress about violations of laws and regulations by a particular User, and until the time of settlement if there remains a claim-obligation relationship due to that User’s usage of services.
2. In accordance with Article 29 of 『Act on Promotion of
Information and Communications Network Utilization and
Information Protection』, if there has been no record of usage
of services for 1 year, such User will be notified in advance
and Personal Information shall be separated and retained for 1
year from the date of conversion to a dormant account.
3. To prevent members from doing expedient or illegal actions
such as re-joining or arbitrarily cancelling memberships after
withdrawal or suspension of memberships to obtain economic
benefits e.g. discount coupons and event benefits provided by
the Company, or using others’ names without permission, the
Company shall retain Users’ Personal Information for 90 days
after withdrawal of membership.
4. The Company may retain Personal Information for a certain
period of time by moving it to a separate database (DB) or by
changing the storage location with the provisions of relevant
laws and regulations such as Act on the Consumer Protection in
Electronic Commerce.
| Name of Statutes | Items | Period |
|---|---|---|
| Act on The Consumer Protection in Electronic Commerce | Records about indications or advertisements | 6 months |
| Records about contracts or cancellation of orders etc. | 5 years | |
| Records about payment and supply of goods etc. | 5 years | |
| Records about complaints from Users or resolution of disputes | 3 years | |
| Act on the Protection and Use of Location Information | Records about personal location information | 6 months |
| Electronic Financial Transactions Act | Records about electronic financial transactions | 5 years |
| Protection of Communications Secrets Act | Personal Information related to usage of services (log records) | 3 months |
| Framework Act on National Taxes | National Tax Evidence etc. | 10 years |
| Reported data of Tax base and the amount | 5 years | |
| Value-Added Tax Act | Reported data of Value-Added Tax base and the amount | 5 years |
The Right of Data Subjects to deny consent and disadvantages, if
any, resulting from the denial of consent
Users have the right to refuse consent to collection and use of
Personal Information. Nevertheless, in the case of refusal to
consent to collection and use of minimum Personal Information
necessary for conclusion and execution of the contract, services
cannot be used. In the case of refusal to consent to collection
and use of Personal Information and/or selective collection and
use of Personal Information for marketing activities and public
relations, there may be disadvantages, for instance, not being
able to receive information about events and benefits, be provided
with free gifts and promotional materials, use affiliated
services, discounts, and accumulate points.
Outsourcing of Personal Information Process
1. The Company consigns Personal Information processing tasks
for smooth handling of Personal Information as follows.
2. The Company consigns only some of tasks necessary for
provision of services to external companies. When consigning
contracts are concluded, prohibiting provisions of processing
Personal Information other than the purposes of performing
consigned tasks, technical and administrative protection
measures, restrictions on reconsignment, management and
supervision of consignees, compensation for damages shall be
specified in consigning contracts in accordance with relevant
laws and regulations. The Company shall regulate, manage, and
supervise matters necessary for consignees to safely process
Personal Information in accordance with relevant laws and
regulations.
| Consignee | Details of consignment tasks |
|---|---|
|
Paymentwall KGinicis Co., Ltd, Kakao Pei Corporation, NHN KCP Corporation, Naver Corporation, SBV Peiko, eBay Korea, Samsung Electronics, Google Payment Korea, People Corporation |
Provision of electronic payment methods |
| AWS | Identification |
|
SendinBlue MailChimp |
Mail services |
| AWS | Operation of services |
| Zendesk | Help Center |
| Google analysis | Service usage behavior analysis |
|
Apple Goolge AWS |
Certification |
Provision of Personal Information to a Third Party
1. The Company processes Users’ Personal Information only within
the scope specified below, and only provides such Information to
a third party when there is a consent from Data Subjects or a
special provision of relevant laws and regulations. Without a
User’s prior consent, the Company shall not use his/her Personal
Information outside the scope of given consent or provide
Personal Information to a third party in principle.
2. Currently, the Company does not provide Personal Information
to a third party except cases necessary for performance of
consignment tasks in the preceding article. If Personal
Information is provided to a third party other than for the
purpose of performing consigned tasks, the Company shall seek
consent from Users with regard to ① the Person receiving
Personal Information, ② the purposes of using Personal
Information by such Person, ③ items of Personal Information to
be provided, ④ Retention and period of usage of Personal
Information, as well as the fact that Users have the right to
refuse consent to provision of their Personal Information and
following disadvantages arising out of refusal of consent, etc.
The Rights and Obligations of Data Subjects and their Legal
Representatives and How to Execute Such Rights
1. Users can exercise the following rights related to their
Personal Information protection against the Company at any
time.
a) The right to request access to Personal Information
b) The right to request a correction if there is an error, etc.
c) The right to request an erasure
d) The right to request suspend the processing of Personal Information
b) The right to request a correction if there is an error, etc.
c) The right to request an erasure
d) The right to request suspend the processing of Personal Information
2. Users may exercise the rights specified in the preceding
Paragraph in writing, by phone, e-mail, fax, etc., and the
Company will handle the issues within 10 business days
according to its internal procedures.
3. If a User requests correction or deletion of errors with
regard to his/her Personal Information, the Company shall not
use the relevant Personal Information before requested
correction or deletion.
4. Users may exercise the rights specified in Paragraph 1 of
this Article via an agent such as a legal representative or
delegate, and the agent can exercise all the above rights on
behalf of a particular user.
5. Users shall not infringe on Personal Information and
privacy of themselves, or third parties processed by the
Company in violation of relevant laws and regulations such as
Act on Promotion of Information and Communications Network
Utilization and Information Protection, and Personal
Information Protection Act.
6. Users have rights to view, correct, or withdraw their
Personal Information through 『Settings』 at any time.
7. If any User wishes to withdraw from membership, the User
can click 『Settings』-> 『Withdrawal of Membership』 or
contact the person in charge of Personal Information
Protection by fax, mail, phone. Then, the Company shall take
necessary measures such as deletion of Personal Information
after retention of that information, for 90 days from the
application for withdrawal of membership.
8. Users shall prevent any unexpected accidents or incidents
by entering or notifying their Personal Information up to date
to the Company.
9. Users are responsible for any accidents or incidents that
occur due to inaccuracies of information provided or entered
by Users, and provision of services may be restrained if false
information such as a non-relevant person’s information is
entered.
10. Users have the right to be protected from infringement of
their Personal Information and the duty to protect themselves
/ not to infringe Personal Information of others. Users shall
also be careful not to leak and damage other Users’ Personal
Information. If a User fails to fulfill the above
responsibilities and somehow damages Personal Information and
dignity of others, he/she may be subject to punishment under
「Act on Promotion of Information and Communications Network
Utilization and Information Protection」, 「Personal
Information Protection Act」.
Protection of Personal Information of Data Subjects aged under
18
To protect Personal Information of persons aged under 18, the
Company shall not allow registration of membership of those
children aged under 18.
Installation and Operation of an Automatic Collection Tool for
Personal Information and the denial thereof
1. When using services provided the Company, service usage
records and connected device information such as cookies (text
files sent by the server used in the Company service to Users’
browser and saved on the hard disk of Users’ device), IP
address etc., are automatically created and stored.
2. The purpose of using Cookies is as follows, and bulletin
board post registration Cookies expire when the browser is
closed or logged out.
- By analyzing frequency of access or usage of time spent, etc., Users’ preferences and interests are identified and used for targeted marketing (this is not combined with information that can identify Users)
- Measures such as service reorganization and etc. by analyzing Users’ habitual behaviors
Users can refuse to install cookies (IE standard setting
method: Tools at the top of the browser > Internet Options
> Personal Information > Site Blocking). Nevertheless,
if a User refuses to install cookies, it may be difficult to
use a number of services that require login.
Destruction of Personal Information
The Company shall destroy all Personal Information without
delay, after the purpose of collecting and using the above
information is achieved. Personal Information recorded and
stored in electronic format should be destroyed so that it
cannot be reproduced. Personal Information recorded and stores
in written format (paper) should be shredded or incinerated.
Copyright © 2022 Function12 Co., Inc