This Policy (the "Policy") explains the way of treatment of the information which is provided or collected on the websites on which this Policy is posted. In addition, the Policy also explains the information provided or collected in the course of using the applications of the Company which exists on the websites or platforms of other companies.
The Company is the controller of the information provided or collected in the websites on which this Policy is posted and in the course of using the applications of the Company which exists in the websites or platforms of other companies.
Through this Policy, the Company regards the personal information of the users as important. It informs them of the purpose and method of the Company's using the personal information provided by the users and the measures taken by the Company to protect that personal information.
This Policy will be effective on the 4th day of March 2023. In case of modification thereof, the Company will make public notice of it by posting it on the bulletin board of the Company's website or individual notice through sending mails, fax, or e-mails).
1. Information to be collected and method of collection
1.
Personal Information Items to be Collected
a.
Information provided by the users
The Company may collect the information directly provided by the users.
i.
Internet membership service: Email, Password, Gender, Birth date, Name, Nationality, and third-party single sign-on information (if you opt for such a sign-on method)
ii.
Online payment service: Payment information including account number and card number
b.
Information collected while the users use services
Besides information directly provided by the users, the Company may collect information in the course that the users use the service provided by the Company.
i.
(Equipment information) Equipment identifier, operation system, hardware version, equipment set-up, type and set-up of the browser, use information of website or application, and telephone number
ii.
(Log information) IP address, log data, use time, internet protocol address, cookie, and web beacon, language, reference webpages, pages visited, location, telecommunications service provider, search terms and search ID (including those whose access is not requested), advertisements posted to you by the Company, identifiers generated by the Company, and identifiers connected to cookies. Also, the Company receives log data when you click, access, or interact with a link on the Company’s services, including when you install another app through the service.
iii.
(Usage Information) Chatting (transmitted within the Company is encrypted both in transit and at rest)
iv.
(Other information) Preference, advertisement environment, visited pages regarding service use of users
2.
Method of Collection
The Company collects the information of users in the way of the followings:
a.
Webpage, written form, fax, telephone calling, e-mailing, tools for collection of created information
b.
provided by partner companies
i.
If you use online products or services from a third party, the concerned party may share data on your usage with the Company (including advertising partners, developers and publishers, and solution services). The Company’s advertising and business partners share the data on browser cookie ID, Webudding-generated identifiers, mobile device ID, hashed user information, and service usage information with the Company.
2. Use and Processing of Collected Information
1.
Use and Purpose of Collected Information
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.
a.
Member management and identification
b.
To detect and deter unauthorized or fraudulent use of or abuse of the Service
c.
Performance of the contract, service fee payment, and service fee settlement regarding provision of services demanded by the users
d.
Improvement of existing services and development of new services
e.
Making notice of the function of company sites or applications or matters on policy change
f.
To help you connect with other users you already know and, with your permission, allow other users to connect with you
g.
To make statistics on members’ service usage, to provide services, and to place advertisements based on statistical characteristics
h.
To provide information on promotional events as well as opportunity to participate
i.
To determine the situation in the event of a problem.
j.
To comply with applicable laws or legal obligations
k.
The Company shall consider the following in cases where users’ data are used or provided without consent.
i.
Whether the purpose of additionally using or providing personal data is relevant to the initial purpose of collection.
ii.
Whether the additional provision of use is predictable in light of the reasons for collecting personal data or processing practices.
iii.
Whether the data subject’s interest is disadvantageously infringed due to additional use or provision of personal data.
iv.
If any measures needed to secure safety such as pseudonymization or encryption have been taken.
2.
Lawful Processing of Personal Information under GDPR
Processing personal information by the Company shall be lawful only if and to the extent that at least one of the following applies:
a.
A user has given consent to the processing of his or her personal information.
b.
Processing is necessary for the performance of a contract to which a user is a party or to take steps at the request of a user prior to entering into a contract:
i.
Member management, identification, etc.
ii.
Performance of a contract in relation to providing the services required by users, payment and settlement of fees, etc.
c.
Processing is necessary for compliance with a legal obligation to which the Company is subject
i.
Compliance with relevant laws, regulations, legal proceedings, and requests by the government
d.
Processing is necessary to protect the vital interests of users or other natural persons
i.
Detection of, prevention of, and response to fraud, abuse, security risks, and technical issues that may harm users or other natural person
e.
Processing is necessary for the performance of a task carried out in the public interest or the excise of official authority vested in the Company
f.
Processing is necessary for the legitimate interests pursued by the Company or by a third party (except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child).
3. Disclosure of Collected Information
Except for the following cases, the Company will not disclose personal information with a 3rd party:
1.
when the Company discloses the information with its affiliates, partners, and service providers;
a.
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
2.
when the users consent to disclose in advance;
a.
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
b.
when the user selects to allow his or her personal information to be shared with the sites or platform of other companies such as social networking sites
c.
other cases where the user gives prior consent for sharing his or her personal information
3.
when disclosure is required by the laws:
a.
if required to be disclosed by the laws and regulations; or
b.
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, Beacons and Similar Technologies
The Company may collect collective and impersonal information through 'cookies' or 'web beacons'. Cookies are very small text files to be sent to the browser of the users by the server used for operation of the websites of the Company and will be stored in hard-disks of the users' computer.
Web beacon is a small quantity of code which exists on the websites and emails. By using web beacons, we may know whether a user has interacted with certain webs or the contents of email.
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:
1.
strictly necessary cookies
This cookie is a kind of indispensable cookie for the users to use the functions of the website of the Company. Unless the users allow this cookie, the services such as shopping cart or electronic bill payment cannot be provided. This cookie does not collect any information which may be used for marketing or memorizing the sites visited by the users
a.
Memorize the information entered in an order form while searching other pages during web browser session
b.
For the page of products and check-out, memorize ordered services
c.
Check whether login is made on website
d.
Check whether the users are connected with correct services of the website of the Company while the Company changes the way of operating its website
e.
Connect the users with certain application or servers of the services
2.
performance cookies
This cookie collects information on how the users use the website 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 website so that users can search that website more comfortably. This cookie does not collect any information about who the users are. Any and all the information collected by this cookie will be processed collectively and anonymity will be guaranteed.
a.
Web analysis: provide statistical data on the ways of using website
b.
Advertisement response fee: check the effect of advertisement of the Company
c.
Tracing affiliated companies; one of the visitors of the Company provides anonymous feedback to the affiliated companies
d.
Management of error: measure an error that may occur so as to give help for improving the website
e.
Design testing: test other designs of the website of Company
3.
functionality cookies
This cookie is used for memorizing the set-ups so that the Company provides services and improves visits of users. Any information collected by this cookie does not identify the users individually.
a.
Memorize set-ups applied such as layout, text size, basic set-up, and colors
b.
Memorize when the customer responds to a survey conducted by the Company
4.
targeting cookies or advertising cookies
This cookie is connected with the services provided by a 3rd party such as the buttons of 'good' and 'share'. The 3rd party provides these services by recognizing that the users visit the website of the Company.
a.
carry out PR to the users as targets in other websites by connecting through social networks and these networks use the information of users' visits
b.
provide information on users' visits to ad agencies so that they can suggest an ad that may attract the interest of the users
The users have an option for cookie installation. So, they may either allow all cookies by setting the option in the web browser, make each cookie checked whenever it is saved, or refuses all cookies to be saved: Provided that, if the user rejects the installation of cookies, it may be difficult for that user to use the parts of services provided by the Company.
5. User’s right
The users or their legal representatives, as main agents of the information, may exercise the following rights regarding the collection, use, and sharing of personal information by the Company:
1.
(The right to access personal information) The users or their legal representatives may access the information and check the records of the collection, use, and sharing of the information under the applicable law.
2.
(The right to rectification) The users or their legal representatives may request to correct inaccurate or incomplete information.
3.
(The right to erasure) The users or their legal representatives may request the deletion of the information after the achievement of their purpose and the withdrawal of their consent. If you delete your account, all of your account information (profile picture, introduction, hashtags, reward points, coupons, purchased items, liked items) will be deleted, and restoration of such data will not be available. Your posts and comments will not be automatically deleted even if you delete your account, but will be left as is. However, your ID will be hidden. After deleting your account, you cannot delete the content arbitrarily, as your identity can no longer be verified. If you want to delete something, please do so before deleting your account.
4.
(The right to restriction of processing) The users or their legal representatives may make temporary suspension of treatment of personal information in case of disputes over the accuracy of the information and the legality of information treatment, or if necessary to retain the information.
5.
(The right to data portability) The users or their legal representatives may request to provide or transfer the information.
6.
(The right to object) The users or their legal representatives may suspend the treatment of personal information if the information is used for the purpose of direct marketing, reasonable interests, the exercise of official duties and authority, and research and statistics.
7.
(The right to automated individual decision-making, including profiling) The users or their legal representatives may request to cease the automated treatment of personal information, including profiling, which has a critical impact or cause a legal effect on them.
If, in order to exercise the above rights, you, as a user, use the menu of 'amendment of member information on the webpage or contact the Company by sending a document or e-mail, or using the telephone to the Company (person in charge of the management of personal information or a deputy), 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.
6. Security
The Company regards the security of personal information of uses as very important. The company constructs the following security measures to protect the user's personal information from any unauthorized access, release, use, or modification.
1.
Encryption of personal information
a.
Transmit users' personal information by using encrypted communication zone
b.
Store important information such as passwords after encrypting it
2.
Countermeasures against hacking
a.
Install a system in the zone the external access to which is controlled to prevent leakage or damage of users' personal information by hacking or computer viruses
3.
Establish and execute internal management plan
4.
Install and operate the access control system
5.
Take measures to prevent forging or alteration of access records
7. Protection of personal information of children
In principle, the Company does not collect any information from children under 13 or equivalent minimum age as prescribed in the laws in the relevant jurisdiction. The website, products, and services of the Company are the ones to be provided to ordinary people, in principle. The website or application of the Company has the function to do age limit so that children cannot use it, and the Company does not intentionally collect any personal information from children through that function.
8. Modification of Privacy Protection Policy
The Company has the right to amend or modify this Policy from time to time. In such a case, the Company will make a public notice of it through the bulletin board of its website (or through individual notice such as written document, fax ,or e-mail) and obtain consent from the users if required by relevant laws.
9. Data transfer
Considering it engages in global businesses, the Company may provide the user's personal information to companies located in other countries for the purpose expressed in this Policy. For the places where personal information is transmitted, retained, or processed, the Company takes reasonable measures to protect that personal information.
In cases related to merger, acquisition, restructuring, asset sale, or bankruptcy, the Company may share, sell, or transfer data related to you. This Privacy Policy shall apply to your personal data which will be shared with or transferred to the new business entity (before and after the closure of relevant transactions).
10. 3rd Party’s Sites and Services
The website, product, or service of the Company may include links to the ones of a 3rd party, and the privacy protection policy of the site of the 3rd party may be different. Thus, it is required for the users to check additionally the policy of a 3rd party site linked to the site of the Company.
11. Contact information of Company
Please use one of the following methods to contact the Company should you have any queries concerning this policy or wish to update your information:
1.
Company name: Noutecompany Corp.
•
Address: 122, Mapo-daero, Mapo-gu, Seoul, Republic of Korea
•
Tel.: (+82) 1877-8160
•
E-mail: contact@noutecompany.com
2.
DPO of the Company
•
Address: 122, Mapo-daero, Mapo-gu, Seoul, Republic of Korea
•
Tel.: (+82) 1877-8160
•
E-mail: ceo@noutecompany.com
Addendum
The latest update date: March 16th, 2023.
This Privacy Policy shall take effect from March 24, 2023.
