Privacy Policy

[General Rules]
① Personal information refers to information about a person who is alive and can identify the person based on an email address or other information contained in that information (including information that can be easily identified in combination with other information, even if the information cannot be identified by itself).
② Rinasoft (hereinafter referred to as a 'company') considers your personal information protection very important and complies with the Privacy Regulations under the 'Act on Promotion of Information and Communication Network Utilization and Information Protection' and the Privacy Guidelines enacted by the Ministry of Information and Communication. Through the Privacy Policy, the company informs you of the purpose and method of using the personal information provided by you and what actions are taken to protect your personal information.
③ The company releases its Privacy Policy on the 'Help' screen so that you can always see it.
④ The company sets out the necessary procedures for revising the personal information handling policy for continuous improvement of the personal information handling policy. In addition, if the privacy policy is revised, the revision number is assigned to make it easier for you to recognize the revised information.

[Information to be Collected]
If you want to use the company's service, the company will collect the following information. If you do not agree with, you will be restricted from using the service.
1) The information collected when an application runs.
- Collect item: device name, manufacturer, operating system(ex: Android or iOS), advertisement ID(ADID), iOS Identifier for Advertising (IDFA), geo-location (when user has enabled location service), advertising usage data
- Information provided by the users: nickname, email address, country

[Agreement to the Collection of Personal Information]
The company considers that you have agreed to the company's Privacy Policy or the terms and conditions of use if you run the application after entering the user's information. If you don't agree, simply exit the application.

[Purpose of Collecting and Using Personal Information]
① The company collects personal information for the following purposes in order to provide optimized and customized services to its members as much as possible:
- E-mail address: Ensuring smooth communication paths such as delivery of notification, identification of the person using the service, and handling of complaints, and verifying the history of paid purchases.
- Nickname: Personal identification for service use
- Name of device: Identify data storage devices when backing up data
- ADID, IDFA, geo-location, advertising usage data : Personal identification for service use, checking validity of the service, checking the access frequency, or statistics on the user’s service use
- Other choices: Data to provide personalized service
② However, sensitive personal information (race and ethnicity, thought and creed, place of origin and origin, political orientation and criminal records, health status, and sexual life) that may be feared to violate users' basic human rights are not collected.

[Apps Permission Requirements]
BILLING: for the use of premium service
SYSTEM_ALERT_WINDOW: for displaying mini-window
VIBRATE: for using vibrations when notifying apps
REECEIVE_BOOT_COMPLETED: to register target start time notifications when the instrument boots
INTERNET: to provide help (notified, frequently asked, inquired) and ranking information
WAKE_LOCK: for turning on the screen of the device
READ_PHONE_STATE: to detect phon calls during measuring time
READ_EXTERNAL_STORAGE: to select photo images from device storage.
WRITE_EXTERNAL_STORAGE: to download, save, and share images.
PACKAGE_USAGE_STATS: to provide an app lock function during measurement

[Collection of advertisement ID when using mobile apps]
The company may collect users' ADID/IDFA. ADID/IDFA is a mobile app user's advertisement identification value, which may be collected for measurement to provide a user's personalized service or advertisement in a better environment.
① Rejection method
- Android: Home > Settings > Google Settings > Ads > Opt out of Ads Personalization
- iOS: Home > Settings > Privacy > Advertising and turn on Limit Ad Tracking

[Guarantee of Users' Rights in EU Countries]
The company is committed to protecting your privacy. In accordance with applicable laws including GDPR, a user may request that his or her personal information be transferred to another manager, and refuse the processing of his or her information. In addition, a user has a right to file a complaint with data privacy protection authorities.
The company may also use personal information for marketing purposes such as event promotion or advertisements, for which the company obtains a prior agreement. A user may withdraw the agreement at any time if he or she doesn't want it.
A user may inquire the foregoing matters to the company. The request will be handled according to the [Withdraw an Agreement on the Collection, Utilization, and Provision of Personal Information].

[Provide and Share with Third Parties]
① The Company uses your personal information to the extent specified in "Purpose of Collecting and Using Personal Information" and does not use it beyond that scope or provide it to others, other companies or institutions.
In particular, we will use and provide personal information with caution in the following cases:
- Affiliate/business partner: The company can provide or share your personal information with its affiliates/business partner for better service delivery.
- Consignment processing: When a user's personal information is consigned to a smooth operation, the user's personal information must be notified in detail of the name of the consigned company, the scope of personal information that is consigned, the purpose of consignment, the process of consignment processing, and the duration of consignment relations.
- Selling, merger, and acquisition: If the rights and obligations of the service providers are fully inherited or transferred, details of the legitimate reasons and procedures will be notified in advance and the option of withdrawal of consent to the users' personal information is given.
- Analytics. Our affiliates/business partners will use your Personal Data to understand and analyse how you use our services; and
- Aggregate Information on Market Trends. Our affiliates/business partners may use your Personal Data, including information about the apps you have installed, the websites you visit, and your interactions with those apps and websites, to analyse trends about app usage, mobile web and demographic groups;
② Notification and consent method shall be notified at least 10 days prior through the notification in the app.
③ Exceptions include:
- In the event of a request from the relevant agency for investigation purposes according to the relevant statutes
- In case certain individuals are provided to advertisers, business partners or research organizations in an unidentifiable form for statistical production, academic research or market research;
- In case of a request in accordance with the procedures set forth in the relevant statutes;
- However, in principle, the company shall notify the parties of any exceptions provided under the related statutes or at the request of the investigation agency. It may be inevitable that legal grounds will not be able to make a notice. We will do our best to prevent information from being provided indiscriminately against the original purpose of collection and use.

[International Data Transfers]
We operate globally and so it may be necessary to transfer your Personal Data to our affiliate/business partners located in countries outside of your country for the purposes outlined in [Provide and Share with Third Parties] section ① above.
- Purpose of providing: to analyse trends about app usage, mobile web and demographic groups
- Period of use of the provided information: When the affiliate service ends

[Access and Correction of Personal Information]
① You may access or correct your registered personal information at any time. To access and correct personal information, click the "Settings" item of the application to view or correct it directly, or contact the person in charge, calling or e-mail, and we will take action without delay.
② If you request correction of personal information errors, the company will not use or provide the personal information until the correction is completed.
③ If wrong personal information has already been provided to a third party, we will inform the third party the correction result that shall be corrected without delay.

[Withdraw an Agreement on the Collection, Utilization, and Provision of Personal Information]
① You may withdraw at any time your consent to the collection, use, and provision of personal information. If you contact the person in charge of personal information management by writing, calling, or e-mail, we will take necessary measures such as the deletion of personal information immediately. If you withdraw your consent and take steps such as destroying your personal information, we will notify you immediately.
② The company will take necessary measures to make the withdrawal of consent for the collection of personal information easier than the method for collection of personal information.

[Retention Period and Period of Use of Personal Information]
① Your personal information will be destroyed when the purpose of personal information collection or the purpose provided has been achieved as follows: However, if it is necessary to retain the relevant statutes, such as the commercial law, for a certain period of time, for the purposes of checking the relationship between the rights and obligations related to the transaction, as follows:
- Records of contract or withdrawal of subscription: 5 years
- Record on payment and supply of goods: 5 years
- Records on consumer complaints or dispute settlement: 3 years
② If you require access to the transaction information you have with your consent, the company will take steps to check the transaction information without delay.

[The Destruction Procedure and Method of Personal Information]
In principle, the company destroys the information without delay after the purpose of personal information collection and utilization has been achieved.
The demolition procedure and method are as follows.
① Destruction Procedure
The information you enter is moved to a separate DB after the purpose has been achieved (a separate document box for paper) and is stored for a certain period of time (see retention and service period) depending on internal policies and other reasons for information protection under relevant statutes. Personal information transferred to a separate DB shall not be used for any other purpose than to be held by law.
② Destruction Method
Personal information printed on paper is shredded or destroyed through incineration, and personal information stored in electronic file types is deleted using a technical method that cannot be played back.

[Technical and Managed Measures for Personal Information Protection]
① Administrative measures
- The company limits access to your personal information to a minimum number of people. The minimum number of people is as follows:
· Person who perform marketing tasks directly against users
· Personal information managers and personnel who perform personal information management tasks
· Person who are required to handle personal information due to their work
- We provide regular in-house and external commissioned training for employees who handle personal information on the acquisition of new security technologies and obligations for personal information protection.
- The company prepares internal procedures to prevent the leakage of information by people through the security pledge of the personal information-related handlers when they enter the company and to audit the implementation of personal information handling policies and employees' compliance with the employees.
- Personal information-related handlers' job transfer is carried out in a thorough manner while security is maintained and the responsibilities for personal information accidents after entering or leaving the company are clarified.
- Personal information and general data are kept separately, not stored together.
- The access control is restricted by setting up a computer room and a data storage area as a special protected area.
- The company is not responsible for what happens because of the user's personal mistakes or the dangers of the underlying Internet. Each member shall properly manage and take responsibility for his/her ID and password in order to protect his/her personal information.
- In the event of loss of personal information, leakage, tampering, or damage caused by mistakes by internal managers or technical management, the company will immediately notify you of the facts and seek proper countermeasures and compensation.

[Consignment of Collected Personal Information]
The company does not consign your information to an external company without your consent.
If such a need arises in the future, we will notify you of the consignee and the details of the consignment and, if necessary, obtain prior consent.

[Feedback Collecting and Complaint Handling]
① The Company values your opinion and you have the right to receive a sincere answer from any question.
② The company operates a complaint processing center to communicate with you smoothly. The contact information is as follows:
Complaint Processing Center
- E-mail: support@rinasoft.co.kr
- Phone number: +82) 070-4220-9691
- Address: 708, Busan Digital Valley, 303, Daedong-ro, Sasang-gu, Busan
③ Telephone counseling is available from 10:00 a.m. to 6:00 p.m. on weekdays, and Saturdays, Sundays and holidays by e-mail.
④ If you have an e-mail or mail consultation, we will sincerely respond within 24 hours of receipt.
However, in principle, the mail after work hours or on weekends and holidays shall be handled next work day.
⑤ If you need counseling on other personal information, you can contact the Personal Information Violation Reporting Center, the Information Protection Marking Certification Committee, the Internet Crime Investigation Center of the Supreme Public Prosecutor's Office, and the Cyber Crime Investigation Unit of the National Police Agency.
* E-Commerce Mediation Committee
- URL: http://www.ecmc.or.kr
* Personal Information Breach Reporting Center
- Telephone: +82) 1336
- URL: https://privacy.kisa.or.kr/kor/main.jsp
* Information Protection Marking Certification Committee
- Phone: +82) 02-580-0533
- URL: http://www.eprivacy.or.kr/
* Internet Crime Investigation Center at the Supreme Public Prosecutor's Office
- Phone: +82) 02-3480-3571
- URL: http://www.spo.go.kr/
* Korean National Police Agency Cyber Bureau
- URL: http://www.police.go.kr/cybercenter

[Personal Information Management Officer and Personnel in Charge]
The company is committed to ensuring that you have safe access to good information. The person in charge of personal information management shall be responsible for any accidents that run counter to the information you have notified in protecting personal information.
However, despite technical remedial actions, the company shall not be responsible for the damages of information due to unexpected accidents caused by basic network hazards, such as hacking, and for disputes caused by postings made by visitors.
The directors and staff handling your personal information are as follows, and we are responding promptly and sincerely to your personal information inquiries.

Personal Information Management Officer
Name: Sung-kwan Kim
Department: Development Team
Position: CEO

Personnel in charge of personal information management
Name: Jae-won Lee
Department: Development Team
E-mail: support@rinasoft.co.kr
Phone number: +82) 070-4220-9691

[Duty to Notify]
The personal information handling policy will be notified through the notice section of the website at least three days prior to the revision if there is an additional, deletion or modification of the contents in accordance with the government's policy or security technology changes.
Personal information handling policy effective date: 2017-11-15
Personal information handling policy change date: 2021-01-26

[Attachment]
This English translation of the Terms of Use is for reference. Korean Term of Use has all legal effect.