Privacy Policy
Privacy
Policy
This Policy (the
"Policy") explains the way of treatment of the information which is
provided or collected in the web sites 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
websites or platforms of other company.
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 exist in the websites 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 the 7th day of March, 2022 and, in case
of modification thereof, the Company will make public notice of it through
posting it on the bulletin board of 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
Personal information items to be collected
by the Company are as follows:
• Information provided by the users
The Company may collect the information
directly provided by the users.
Title of
service |
Items to
be collected |
Internet
membership
service |
∘ Name, email address, ID, telephone
number, address, national information, encoded identification information
(CI), identification information of overlapped membership (DI) ∘ For minors, information of
legal representatives (name, birth date, CI and DI of legal representatives) |
Online
payment service |
∘ Name, address, telephone
number, and email address ∘ Payment information
including account number and card number ∘ Delivery information including delivery address, name and
contact information of recipient ∘ Information of bid,
purchase and sales |
Social
network service |
∘ Name, email address, ID, telephone
number, address, national information, address list (acquaintance) ∘ Information of place of
taking pictures and date of creation of files ∘ Information of service use of
members such as the type of contents watched or used by members, the persons
interacting or sharing contents with members, frequencies and period of
activities of members |
• 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.
Lists |
Items to be collected |
Equipment
information |
∘ Equipment identifier, operation system,
hardware version, equipment set-up, type and set-up of browser, use
information of website or application and telephone number |
Log information |
∘ IP address, log data, use
time, search word input by users, internet protocol address, cookie and web
beacon |
Location
information |
∘ Information of device
location including specific geographical location detected through GPS ,
Bluetooth or Wifi (limited to the region permissible under the laws) |
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:
•
webpage, written form, fax,
telephone calling, e-mailing, tools for collection of created information
•
provided by partner companies
2. Use of collected information
The Company uses the collected information
of users for the following purposes:
•
Member management and
identification
•
To detect and deter
unauthorized or fraudulent use of or abuse of the Service
•
Performance of contract,
service fee payment and service fee settlement regarding provision of services
demanded by the users
•
Improvement of existing
services and development of new services
•
Making notice of function of
company sites or applications or matters on policy change
•
To help you connect with other
users you already know and, with your permission, allow other users to connect
with you
•
To make statistics on member’s
service usage, to provide services and place advertisements based on statistical
characteristics
•
To provide information on
promotional events as well as opportunity to participate
•
To comply with applicable laws
or legal obligation
•
Use of information with prior
consent of the users (for example, utilization of marketing advertisement)
The Company agrees that
it will obtain a consent from the users, if the Company desires to use the
information other than those expressly stated in this Policy.
[Option to select ‘Lawful Processing of Personal
Information under GDPR’ in Appendix <1> of Personal Privacy Policy]
3. Disclosure of collected
information
Except for the following
cases, the Company will not disclose personal information with a 3rd party:
• when
the Company disclosing the information with its affiliates, partners and service
providers;
-
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 to disclose in advance;
-
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 sites 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 disclosure 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, 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 e-mails. By using web
beacons, we may know whether an 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:
Category |
Reasons for using cookies
and additional information |
strictly necessary cookies |
This
cookie is a kind of indispensible cookie for the users to use the functions
of 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
∘ Memorize the information entered in an order form while searching
other pages during web browser session
∘ For the page
of products and check-out, memorize ordered services |
|
∘ Check whether
login is made on website ∘ 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 ∘ Connect the
users with certain application or server of the services |
performance cookies |
This
cookie collects information 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 the users can search
that website more comfortably. This cookie does not collect any information
who are the users. Any and all the information collected by this cookie will
be processed collectively and the anonymity will be guaranteed. ∘ Web analysis:
provide statistical data on the ways of using website ∘ 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 website ∘ Design
testing: test other design of the website of Company |
functionality cookies |
This
cookie is used for memorizing the set-ups so that the Company provides
services and improves visit of users. Any information collected by this
cookie do not identify the users individually. ∘ Memorize set-ups
applied such as layout, text size, basic set-up and colors ∘ Memorize when
the customer respond to a survey conducted by the Company |
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 visits the website of the Company. ∘ carry out PR to the users as targets in other websites by connecting
through social networks and these networks use the information of users'
visit ∘ provide the information
of users' visit to ad agencies so that they can suggest an ad which may
attract the interest of the users |
The users have an option
for cookie installation. So, they may either allow all cookies by setting
option in 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:
•
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 rights, you, as an user, use the menu of 'amendment of member
information of webpage or contact the Company by sending a document or e-mails,
or using telephone to the company(or person in charge of 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.
[Option to select 'User’s right when applying GDPR' in
Appendix <2>of Personal Privacy Policy]
6. Security
The Company regard 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
•
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
7. Protection of personal
information of children
In principle, the Company
does not collect any information from the children under 13 or equivalent
minimum age as prescribed in the laws in 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 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.
(Additional procedure for collecting personal information from
children) However, if the Company collects any
personal information from children under 13 or equivalent minimum age as
prescribed in the laws in relevant jurisdiction for the services for
unavoidable reason, the Company will go through the additional procedure of the
followings for protecting that personal information of children:• verify, to
the extent that efforts are reasonably made, whether they are children of the
age at which consent from their guardian is required and the consenting person
is an authorized one.
•
obtain consent from the parents
or guardian of children so as to collect personal information of children or
directly send the information of products and services of the Company
•
give the parents or guardian of
children a notice of Company's policy of privacy protection for children
including the items, purpose and sharing of personal information collected
•
grant to legal representatives
of children a right to access to personal information of that children/correction
or deletion of personal information/temporary suspension of treatment of
personal information/ and request for withdrawal of their consent provided
before
•
limit the amount of personal
information exceeding those necessary for participation in online
activities
8. 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 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. Others
[Option to select 'data transfer to other countries ' in
Appendix <3> of Personal Privacy Policy]
[Option to select 'sites and service of 3rd party' in
Appendix <4> of Personal Privacy Policy]
[Option to select 'guidelines for residents in California'
in Appendix <5> of Personal Privacy Policy]
[Option to select 'guidelines for residents in Korea' in
Appendix <6> of Personal Privacy Policy]
10. Contact information of
Company
Please use one of the
following methods to contact the Company should you have any queries in respect
to this policy or wish to update your information:
•Company name : RoyceDawn
Address :
Tel.:
E-mail:
rsroycedawn@gmail.com
The latest update date: March 7, 2022.
Appendix of Privacy Protection Policy
<1> 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 user has given consent to the
processing of his or her personal information.
•
Processing is necessary for the
performance of a contract to which a user is party or in order to take steps at
the request of a user prior to entering into a contract:
-
Member
management, identification, etc.
- Performance of a contract in relation to
providing the services required by users, payment and settlement of fees,
etc.
•
Processing is necessary for
compliance with a legal obligation to which the Company is subject
- Compliance with relevant law, regulations, legal proceedings,
requests by the government
•
Processing is necessary in
order to protect the vital interests of users, or other natural persons
- Detection of, prevention of, and response to fraud, abuse, security
risks, and technical issues that may harm users or other natural persons
•
Processing is necessary for the
performance of a task carried out in the public interest or in the excise of
official authority vested in the Company
•
Processing is necessary for the
purposes of 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).
<2> User’s
right when applying GDPR
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:
•
The right to access to 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. • The
right to rectification;
-
The users or their legal
representatives may request to correct inaccurate or incomplete information.
•
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.
•
The right to restriction of
processing;
-
The users or their legal
representatives may make temporary suspension of treatment of personal
information in case of the disputes over the accuracy of information and the
legality of information treatment, or if necessary to retain the information.
•
The right to data portability
-
The users or their legal
representatives may request to provide or transfer the information. • 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.
•
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 critical impact or cause legal
effect on them.
If, in order to exercise
the above rightss, you, as an user, use the menu of 'amendment of member
information of webpage or contact the Company by sending a document or e-mails, or using
telephone to the Company ( person in
charge of 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.
<3> Data transfer to other
countries
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
those personal information.
(If used in the US, additional security measures may be available) In addition, when the personal information obtained from the
European Union or Switzerland is used or disclosed, the Company may have to
comply with the US-EU Privacy Shield and Swiss-US Privacy Shield, 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.
<4> 3rd party's sites and
services
The website, product or 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. <5> Guide for users residing in California
If the user resides in
California, certain rights may be given. The Company prepare 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, an user may request the Company to check the leakage. In
addition, all the users in the website 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 website 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.
<6> 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:
• Examples of required information
Title of service |
Items to be
collected(examples) |
Internet membership
service |
∘ Name, email address, ID, telephone number, address, national
information, encoded identification information (CI), identification
information of overlapped membership (DI) ∘ For minors,
information of legal representatives (name, birth date, CI and DI of legal
representatives) |
Online payment
service |
∘ Name, address,
telephone number, and email address ∘ For payment with credit card : name of card company, number and
expiration of card ∘ For small sum payment charged on the mobile phone: mobile phone
number, payment approval number ∘ For payment by remittance: name of bank, account number and password of
account ∘ For deposit
without a bankbook: name of remitter, contact information ∘ Delivery information including delivery address, name and contact
information of recipient ∘ Information of
bid, purchase and sales |
Social network
service |
∘ Name, email address, ID, telephone number, address, national
information, address list (acquaintance) ∘ Information of
place of taking pictures and date of creation of files ∘ Information of service use of members such
as the type of contents watched or used by members, frequencies and period of
activities of members |
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 and telephone number) ∘ Log information (Log data, use time, search word input by users,
internet protocol address, cookie and web beacon) ∘ Location information (Information of device location including
specific geographical location detected through GPS, Bluetooth or Wifi) ∘ Other created
information |
• Examples of optional items
The user may reject the
collection and use of optional items and, even in case of rejection, there is
no limit on use of services
Purpose of
collestion |
Items to be
collected(examples) |
User analysis |
∘ The reason for
membership, occupation, marriage status, wedding anniversary, interest
category and SNS account information |
Provision of customized ad
|
∘ Contents and
result of marketing activities and event participation |
Delivery of urgent notice |
∘ Information provided by
the users regarding execution, maintenance, execution, management of other
agreements and event participation |
Marketing |
∘ Preference, advertisement
environment, visited pages regarding service use of users |
• Additional procedure for
collection of sensitive information
If collection of
sensitive information is indispensible, the Company may collect it by going
through lawful procedure in accordance with relevant laws and regulations. The
sensitive information which may be collected by the Company is as follows:
∘ Thoughts and belief
∘ Membership of and withdrawal from labor
union or political party
∘ Political opinions
∘ Information of health and sexual
life
∘ Genetic information obtained from the
result of gene test
∘ Information of
criminal record including announcement, exemption and suspension of sentences,
care and custody, protective custody, treatment and custody, probation, lapse
of suspension of sentence and cancellation of suspension of execution.
(2) Commission for collected
personal information
For carrying out
services, the Company commissions external professional companies
(subcontractors) to process personal information as follows. This commissioned
works for processing personal information is carried out by each subcontractor
and service only if necessary for providing that service.
In commissioning process
of personal information, in order to secure safety of personal information ,
the Company supervises and ensure to expressly state in the agreement with
subcontractors so that those subcontractors will safely process personal
information by strictly complying with directions regarding personal
information protection, keeping personal information secret, not disclosing it
to a 3rd party and being liable for accidents and returning or destructing
personal information upon termination of the commission or process.
Name of
subcontractors |
Description of
commissioned works (services) |
|
|
(3) Details of provision of
personal information to 3rd party
Except for the following cases, the
Company does not disclose or provide personal information of the users to a 3rd
party:
Recipients of
information |
Purpose of use
of recipient |
Items to be
provided |
Period of retention and
use of recipient |
|
|
|
|
(4) 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 )
(5) 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.
(6) 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:
Items |
Examples |
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 |
(7) 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:
Dept. :
Tel. :
Contact :
rsroycedawn@gmail.com
The latest update date: March 7, 2022