[THEKKING] Privacy Policy

'EZWIN Company Co., Ltd.' (hereinafter referred to as the 'Company') considers the protection of personal information on mobile and the Internet very important, and allows users to use mobile services provided by EZWIN Company Co., Ltd. When using 'THEKKING' (hereinafter referred to as 'service'), we are doing our best to protect the personal information provided to EZWIN Company Co., Ltd.

This Privacy Policy may be changed from time to time due to changes in government laws and guidelines or changes in EZWIN Company Co., Ltd.'s internal policies, etc. personal information handling policy).

1. Collection of personal information

The company requires specific information to provide services to users (hereinafter referred to as 'members').

If a member chooses to create an account, some personal data must be provided to the company so that the company can provide services. When creating an account, members can sign up for or connect to the service with an account on another service such as Google, Apple or Kakao.

In addition, in order to provide convenient and diverse services to members, the company may use personal information collected from members to advertise or market various services provided by the company by e-mail or push method. In this case, the member can reject unwanted services at any time through e-mail, etc.

1.1 How we collect personal information

If you select and click the "I agree" button to the company's terms of service when registering as a member, you agree to this Privacy Policy at the same time, and accordingly, the company collects personal information based on the information entered in the registration form.
The company collects personal information in the following ways to provide services.

• Directly collected from users in the process of membership registration and use of services
• Information provided by the Company's third parties and business partners;
• 1:1 consultation inquiry and user input directly

2. Items of personal information to be collected

2.1 Basic Account Information

The company collects and uses the following personal information for account creation, login service, smooth customer consultation, and verification of age of use.

• Log in with Google account: Google email, nickname
• Log in with Apple account: Apple ID, email, nickname
• Log in with Kakao account: Kakao account (email), profile information (nick name / profile image)

If identification is required for age verification or compliance with related laws, the following information may be collected with the user's separate consent.

• Encrypted personally identifiable information (CI)
• Duplicate subscription confirmation information (DI)

In the process of using other services, the following information may be generated and collected.

• Service-related activities such as video viewing, viewing history, and search terms
• Additional collection of e-mail address and shipping information in the process of handling events and customer inquiries, etc.

2.2 Technical information

The Company may use technologies such as application programming interfaces (APIs) to securely and reliably set up and maintain member accounts and operate services, allowing websites, applications and other users to collect certain types of information, such as: information to help you.

Log data:

The company collects information referred to as "log data" when a member interacts with the service, even if the member does not create an account. This log data includes information such as the member's IP address, device identification number (UUID), operating system, carrier and device information (including device language settings), and advertising identifiers (GAID/ IDFA).

The company uses information and data provided by members and log data from third parties to infer the topics, ages and languages spoken by members that may be of interest to members. This allows us to design our services more effectively.

Location information:

The company may collect information about the member's location (such as IP address and country of residence), and we may use that information to know the member's location to customize our services and features. By accessing and using the Services, members consent to the collection and use of location information.

The company receives information about how its members use the service from business partners and service providers (eg Google Analytics) who support the provision and improvement of the service.

Below is a list of our service providers.

• Google Analytics
• Firebase

3. Purpose of use

The company uses the collected information for the following purposes.

• To help users use the service smoothly
• To identify users according to service use and prevent illegal use
• To prepare statistical data on service use
• For surveys and analysis necessary for service improvement;
• When there is an inquiry from a user, to verify the identity of the user and respond to inquiries
• To provide important notices as needed (push notifications, mail, online message channels)
• For the delivery of advertising information (push notifications, mail, online message channels) such as events
• To deliver customized services and information (including advertisements) provided by the company

※ The company collects minimal behavioral information to transmit online customized advertising information. Behavioral information collected through advertisement identifiers is stored for up to 6 months to provide customized advertisement information and then destroyed. Members can block customized advertisements at any time, and if blocked, customized advertisements will no longer be displayed.

How to refuse to collect behavioral information

• Android phone
- Google Settings → Ads → Advertisement customization on or off

• Iphone
- Settings → Privacy → Advertising → Restrict Ad Tracking

4. Sharing of personal information

In principle, the company does not provide users' personal information to outside parties without the user's prior consent.
However, exceptions are made in the following cases.

Affiliates and service providers that support smooth service provision

Technology infrastructure providers (such as servers) or companies that perform services on our behalf, such as engineering or other support, technical services and feature developers, research and analytics companies, and email providers (including both third parties and affiliates)

When users consent in advance

Concerns about an individual's physical safety, if disclosed by applicable laws and regulations, and where such sharing is permitted by law, or reasonably necessary to investigate, prevent or take action against suspected illegal or fraudulent activity; Potential Threats, Violations of this Privacy Policy or Terms of Use

For the overall business benefits and operational purposes of the Affiliate

The company shares user data with advertising technology providers. These ad technology providers may collect user shape information and use data about users to personalize and measure ads.

Below is a list of the company's advertising technology providers, which may vary by country.

※ Method, procedure and effect of refusing transfer of personal information: Users may refuse overseas transfer of personal information through the company’s personal information protection manager and responsible department. If a user refuses to transfer personal information overseas, the company excludes the user's personal information from being transferred overseas. However, in this case, use of the company's services that necessarily involve overseas transfer of personal information may be restricted.

4.1 Public Information

When a member creates an account, their nickname and profile image information is always public and shared with other members of the service. When a member posts a post in the in-app community, the content is made public. Any comments posted to other members' posts are also visible. Members are responsible for the information they provide through the service, and must be careful about the information they disclose, especially sensitive information.

5. Children's Privacy

(1) We do not knowingly collect or solicit personal data from anyone under the age of 16 in countries with EU GDPR amendments. If you are under the minimum age, do not attempt to register for the service or send any personal information about yourself to the company. If we become aware that we have collected personal data from a child under the required minimum age, we will delete that information as soon as possible. If you believe that a child under the minimum age has provided personal information, please contact thekking.official@gmail.com.

(2) Through individual laws in each country, the age limit for children who require the consent of a legal representative such as parents may be lowered to 13 years of age. In the case of children under the age of 13, this can be done through the member's legal representative or an agent such as a person who has been delegated. In this case, the legal representative has all the rights of the member.

You must fully understand the purpose of collection and use of personal information and apply for membership after obtaining the consent of a legal representative such as a parent. In addition, legal representatives such as parents may request to view, correct, or update personal information about children or withdraw consent for membership registration, and in this case, the company must take necessary measures without delay.

If you believe that a parent has provided personal information to a child under the required minimum age, please contact thekking.official@gmail.com.

6. Member's rights and how to exercise them

Members can view or modify their registered personal information at any time and request account deletion. Account settings allow Members to access, edit or delete the following information provided to the Company from time to time.

• Nickname and password
• Email Address
• Profile image
• Community and comment posts, including text, images, and links uploaded by members to the service

Information that members can view, update, and delete may change as the service changes. If a member requests correction of errors in personal information, the personal information will not be used or provided until the correction is completed.

The company handles the personal information that has been canceled or deleted at the request of the member as specified in the “period of retention and use of personal information” below, and handles it so that it cannot be viewed or used for any other purpose.

7. Period of retention and use of personal information

The member's personal information is retained and used only for the period the company provides the service (period of use) or dispute resolution period (retention period). We are destroying personal information using the personal information method.

In the case of membership registration information, when membership is withdrawn or expelled from membership

(Commerce) In the case of payment information, the date of completion of payment or expiration of the prescription period

For product delivery information, when goods or services are delivered or provided

However, if the obligation to keep is stipulated in accordance with the provisions of laws such as the Commercial Act or if the person's consent has been obtained, if the retention period notified in advance has not elapsed, litigation or disputes may occur or may occur, so the retention of related personal information is restricted. Personal information may be retained for the necessary period, for example, when necessary for legal action.

In the following cases, the storage of information for a certain period of time is stipulated in laws such as the Consumer Protection Act in Electronic Commerce Transactions, Electronic Financial Transactions Act, and Communication Secret Protection Act. During this period, the company keeps personal information in accordance with the provisions of laws and regulations, and never uses this information for any other purpose.

Act on Consumer Protection in E-Commerce, Etc.

Records on contract or subscription withdrawal, etc.: 5 years

Records on payment and supply of goods: 5 years

Records on consumer complaints or dispute resolution: 3 years

Electronic Financial Transactions Act

Records related to electronic finance: 5 years

Service use record: Communication Secret Protection Act

Login history: 3 months

However, the viewing and use of personal information during this period is limited to the relevant reason, and if it is necessary to keep it after that, the member is notified of this fact and consent is obtained.

It is revealed that the personal information is provided for a temporary purpose (events, surveys, etc.), and after the purpose is achieved, the personal information is processed as information necessary for membership registration according to the will of the user or member, or stored on the disk in a way that cannot be reproduced. It will be completely deleted so that it cannot be viewed or used in the future.

However, even if the membership is withdrawn, service use records such as postings in the service and voting for the account and records of participating in specific events may be kept for reasons such as management and reporting of service and event operation. Event participation data of a member who has withdrawn is managed in the following way.

Members who withdrew from membership are excluded from winning the event.

Even if you withdraw from membership, the results of participation in events such as voting are not deleted.

In the event that a member has stopped using as a member for a long time, the company sets the membership period and notifies it through the service screen or e-mail for a certain period of time. In accordance with this, related personal information can be stored and deleted separately.

8. Personal information destruction procedure and method

The company's personal information destruction procedures and methods are as follows.

8.1 Destruction Procedure

After achieving the purpose of collection summarized in this Privacy Policy, the user's personal information will be processed in '7. Retention and use period of personal information' is followed, and then destroyed in accordance with internal policies and related laws. Such personal information will not be used for any purpose other than preservation, except as required by law.

8.2 Destruction method

Personal information printed on paper is shredded with a shredder. Personal information records stored in the form of electronic files are deleted using a technical method that cannot be reproduced.

8.3 Other personal information of dormant accounts

In accordance with the 「Domestic Information and Communication Network - Personal Information Protection Act」, if there is no record of using the ducking service for one year, the company converts the account to a dormant account, and the user's personal information is stored separately.
The company notifies users of dormant accounts up to 30 days before the expiration date, and the notification details are as follows.

• Notification contents: the fact that the account is scheduled to be converted into a dormant account, the expected date of separate storage of personal information, and items of personal information to be kept separately
• Notification target: E-mail subscribers
• Notification method: Email
• Notification date: 00: 00 (KST) 30 days before inactive account conversion

8.4 Restoring dormant accounts

When a dormant account user later activates the account and re-uses the ducking service, the personal information stored separately will be recovered.

9. Technical and Administrative Measures to Protect Personal Information

The company is taking the following measures in terms of technical and administrative aspects to protect personal information.

(1) Minimization and training of personnel handling personal information

We are implementing measures to manage personal information by designating employees who handle personal information and limiting them to the person in charge.

(2) Conduct regular self-audits

To ensure the stability of personal information handling, we conduct regular (quarterly) self-audits.

(3) Establishment and implementation of internal management plan

We have established and implemented an internal management plan for safe handling of personal information.

(4) Encryption of personal information

The user's personal information is stored and managed with an encrypted password, so only the user can know it. For important data, a separate security function is used, such as encrypting files and transmission data or using a file lock function.

(5) Technical measures against hacking, etc.

In order to prevent leakage and damage of personal information caused by hacking or computer viruses, security programs are installed, periodically updated and inspected, and the system is installed in an area where access is controlled from outside, and technical/physical monitoring and blocking are performed.

(6) Restriction of access to personal information

We take necessary measures to control access to personal information by granting, changing, and canceling access rights to the database system that processes personal information, and use an intrusion prevention system to control unauthorized access from outside.

(7) Storage of access records and prevention of forgery

The records of access to the personal information processing system are kept and managed for at least 6 months, and security functions are used to prevent forgery, theft, or loss of access records.

10. Personal Information Protection Officer

The company is responsible for overall handling of personal information, and designates and operates the person in charge of personal information protection and the department in charge as follows for handling complaints and damage relief from users related to personal information processing.

• Privacy Officer
Name: Kim Sunmin
Affiliation/Position: General Manager
Email: thekking.official@gmail.com Phone: 02-556-7741

• Person in charge of personal information processing
Name: Kang Yoonju
Affiliation/Position: Manager
Email: thekking.official@gmail.com Phone: 02-556-7741

You can contact the person in charge of personal information protection and the department in charge of all personal information protection related inquiries, complaint handling, damage relief, etc. The company will answer and handle users' inquiries.

11. Revision of Privacy Policy

If there are any additions, deletions, or modifications to the current personal information processing policy, we will notify you through a notice at least 7 days prior to the revision.

12. Handling of complaints and disputes related to personal information

Users who want to receive damage relief due to infringement of personal information, please contact the person in charge of personal information management or the person in charge. Alternatively, you can inquire about reporting or consulting about personal information infringement, remedying damages, and arbitrating disputes at the institutions below.

Personal Information Infringement Report Center (operated by Korea Internet & Security Agency)

Responsibilities: Report personal information infringement, apply for counseling

Homepage: privacy.kisa.or.kr

Phone: (without area code) 118

Address: (58324) 9 Jinheung-gil, Naju-si, Jeollanam-do (301-2 Bitgaram-dong), 3rd floor, Personal Information Infringement Report Center

Personal Information Dispute Mediation Committee

Responsibilities: Personal information dispute mediation application, collective dispute mediation (civil resolution)

Website: www.kopico.go.kr

Tel: (without area code) 1833-6972

Address: (03171) 4th floor of Government Complex Seoul, 209 Sejong-daero, Jongno-gu, Seoul

Supreme Prosecutor's Office Cyber Crime Investigation Team: 02-3480-3573 (www.spo.go.kr)

National Police Agency Cyber Terror Response Center: 1566-0112 (www.netan.go.kr)