Pinkfong Integrated Services Privacy Policies

November 15, 2022

Privacy Policy (November 15, 2022)

The Pinkfong Integrated Services(the “Pinkfong Services”), including the Pinkfong Store website/mobile application services, Pinkfong TV mobile application services, Pinkfong Homeschool Play mobile application services, Pinkfong Homeschool services and Pinkfong interactive mobile application services Pinkfong official website and Pinkfong business help center services operated by The Pinkfong Company, Inc.(the “Company”) value users’ personal information and do their best to ensure users have their personal information provided to the Pinkfong Services protected while using the services.

Article 1 General Provisions

1. The Pinkfong Services inform, via the Privacy Policy, users of the purpose and method of the use of their personal information and measures taken to protect their personal information.

2. Users are advised to check this Privacy Policy as they access the Pinkfong Services as this policy is subject to change according to amendment to laws or guidelines on the protection of personal information or the Company’s policy.

Article 2 Consent to Processing of Personal Information

The Pinkfong Services operate procedures enabling users to click the ‘consent’ or ‘withdrawal’ button on the Company’s processing of Personal Information. The user is deemed to have consented to the processing of his/her personal information upon clicking the ‘consent’ button. If the user does not consent to the processing of Personal Information, he/she may be restricted from using any part of the Pinkfong Services.

Article 3 Collected Personal information; Method of Collection

1. The Pinkfong Services are provided with information required to provide services for users’ application for membership registration or use of mobile application services as follows.

a. Collected personal information

1) Registration for integrated membership

[Required Items]: ID(email address as ID), password, contact information(telephone/mobile-phone number), Country
[Optional Items]: Children’s nicknames and birth year and month

2) Scope of personal information that may be collected during the use of services and business operation

a) Pinkfong Store

- Name, address, contact information
- Records of use/suspension of services, access log, cookie, access IP information
- (Product purchase, payment and delivery, refund service) Payment information on bank account/credit card, point-card number, transaction history, whether a cash receipt is issued, etc.
- (Product purchase, payment and delivery, refund service) Delivery information, including the address/name/contact information of the recipient
- (Mobile device) Device identification number, OS information, advertising identifier, telecommunications company, whether ‘PUSH’ is received
- (Purchase of overseas delivered product) Customs ID number
- (Questionnaire and event) Other selective personal information

b) Pinkfong TV Mobile Application Services

- Initial service device identification number(device ID or IMEI), region format
- Information on the user’s status(account name, nickname, store name in use)
- Photograph, cookie, date of visit, service use log, improper use log
- (KakaoTalk-/Facebook-linked service) KakaoTalk/Facebook ID

c) Pinkfong Homeschool Mobile Application Services
- Name, address, contact information
- Records of use/suspension of services, access log, cookie, access IP information
- Delivery information, including the address/name/contact information of the recipient
- (Mobile device) Device identification number, OS information, advertising identifier, telecommunications company, whether ‘PUSH’ notification is received
- (Purchase of overseas delivered product) Customs ID number
- (Survey and event) Other selective personal information

d) Pinkfong Interactive Mobile Application Services
- Initial service device identification number(device ID or IMEI), region format
- Device information(model, device type, OS version)
- Photograph, cookie, date of visit, service use log, improper use log
- (KakaoTalk-/Instagram/Facebook-linked service) KakaoTalk/Instagram/Facebook ID

d) Pinkfong Business Help Center
- (Submitting a request) email, name, contact information

b. Method of collection

- Website, bulletin board, telephone, fax, event, delivery request
- Collection of information generated via log-analysis programs and by cookies
- Provision from affiliates and purchasers
- Collection via smartphone applications
- Voluntary supply from users upon their registration for, or use of, services or customer counselling

c. Location information

The Company does not collect, store or use information with which an individual’s location can be identified. However, certain advertisement banners operated by third parties, may collect, without storage, via location-recognition advertisements of advertising-service providers as such third parties, and temporarily use, location information with a device’s censor data, etc. that may provide actual location information (including GPS signals from mobile devices) or information on nearby Wi-Fi access points and base stations. However, such use of location information is unrelated to the Company.

2. Users’ personal information collected is destroyed immediately after the purpose of its collection is achieved. The Company does not collect sensitive personal information that may infringe users’ basic human rights or use for any purpose other than that notified in advance to users, or divulge to third parties, personal information provided from them.

3. Measure taken by the Company for the member’s provision of false information
The member must guarantee the accuracy and legitimacy of his/her information. If the member submits false information in various ways, including the stealing of another person’s information, in violation of the provision above, the Company may report such member under applicable laws and deprive him/her of his/her membership.

4. The user shall be solely liable for losses or problems suffered by him/her due to personal information he/she voluntarily disclosed. The user is advised to recognize that personal information made public can be collected and used, without his/her permission, by another person, and that he/she may suffer unwanted damage caused thereby.

5. The Company may access and use information within the customer’s mobile communication device as follows for its mobile application services. The Company explains, and obtains consent to, access to required items upon the installation, or first execution, of a mobile application, and obtains separate consent to access to optional items upon the first use of such mobile application. The method of obtaining consent to access to optional items may vary depending on the OS version, however, there is no restriction on the use of basic services by a member refusing to give consent.

[Pinkfong TV Application]

Required or Optional	Item	Purpose
Required	Device ID, application record	Examination of application status(version) upon initial execution
Required	Communication record, WIFI connection information	Optimization of application use, examination of network connection
Optional	Camera	Use of QR code scanning within the application

[Pinkfong Store Application]

Required or Optional	Item	Purpose
Required	Device and application record right	Examination of application status(version)
Required	Communication record, WIFI connection information	Optimization of application use, examination of network connection
Optional	Photograph/media/file	Storage or loading of photograph, vide or contents(product review with photograph)
Optional	Camera	Use of photography function within the application

* The user may use basic services without giving consent to access to optional items.

[Pinkfong Interactive Application]

Required or Optional	Item	Purpose
Required	Device and application record right	Examination of application status(version)
Required	Communication record, WIFI connection information	Optimization of application use, examination of network connection upon initial execution
Optional	Photograph/media/file	Storage or loading of photograph, video or contents
Optional	Camera	Use of photography function or QR code scanning

* The user may use basic services without giving consent to access to optional items.

Article 4 Purpose of Collection/Use of Personal Information

1. The purpose of the Company’s collection of personal information is to identify users and confirm their intention of using the Pinkfong Services to provide them with optimized services. The Pinkfong Services collect personal information for the following purposes to a minimum extent necessary to provide various services, including e-commerce services, tailored for users’ characters and preferences and to resolve problems arising from users’ use of the Pinkfong Services.

a. Membership management

- Identification for membership-based services, restriction of use by members violating the Terms of Use, regulation of unfair uses of services
- Securing of a channel for efficient communication for notification/handling of complaints
- Confirmation of the intention of registration/withdrawal, restriction of registration/number of registration
- Confirmation of whether the legal representative of a child younger than 14 years or equivalent minimum age in the relevant jurisdiction consents to the collection of such child’s personal information, subsequent identification of the legal representative
- Preservation of records for mediation, handling of complaints, etc., giving of notice

b. Performance of agreements on the provision of services, and settlement of payments for services

- Accumulation, use and settlement of mileage
- Confirmation of orders for products and services and receipt of such orders, payment, collection, etc.
- Provision of contents/customized services, delivery, sending of invoices, identification

c. Customer counselling

- Operation of a customer center for the Identification of the customer, examination of the counselling subject, communication/notification for investigation of facts, notification of the results, etc.

d. Utilization for the development of new services and marketing

- Provision of services and placement of advertisements according to statistical characteristics, confirmation of the validity of services
- Provision of customized services to integrated-service members, development of various new services and provision of customized services
- Provision of marketing information on, and opportunities to participate in, events, examination of access frequency
- Use for marketing purposes, including events with partners and service promotion, analysis of customer information and service development for marketing purposes, statistics on members’ uses of services

2. If the user uses the Pinkfong Services as a non-member, information on the payer and receiver provided by such user is not used for any purpose other than that for payment and delivery.

3. The Company may collect and use the following behavioral information in order to provide optimized services and benefits, such as online customized advertisements, by using user’s behavioral information such as the user’s visit history, collected when the user uses the Pinkfong Services.

Items of behavioral information collected	- User’s visit history, search history and purchase history - User’s other behavioral information regarding the use of website/application
Methods of collection	- Automatic collection through user’s visit and use of the website or application - Collecting user’s behavioral information by installing Facebook or Instagram’s pixels or SDK - Other methods that are permitted by law or guidelines
Purpose of collection	- To provide personalized product recommendation service(including advertisements) based on user’s interest and disposition - To utilize user’s behavioral information for new product development and service reform
Period of retention/use	2 years from date of collection
Exercise of control by users	- Web browser : Internet Explorer, Chrome, Firefox, Safari - Smartphone: iPhone, Android
Remedies for users	Please refer to Article 14

Article 5 Provision/Sharing of Personal Information

1. The integrated-service member becomes the member of the Pinkfong Store website/mobile application and Pinkfong TV mobile application and can use the Pinkfong Services with one ID.

2. The Pinkfong Services do not use for any purpose other than services provided by the Pinkfong Services, or provide to a third party without the user’s consent, personal information on the user except information disclosed via the service screen; provided, however, that the foregoing shall not apply to the following:

a. If there are extraordinary provisions in the applicable Act;

b. If necessary for the settlement of charges for the provision of services;

c. If necessary for statistics, academic research or market survey with the information provided with which a specified individual cannot be identified;

d. If users give prior consent to disclosure;

e. If the terms of use published on the Pinkfong Services and those on other membership services or operation rules are violated;

f. If demanded by investigation authorities for investigation purposes under statutory procedures; or

g. If legal measures are taken against a person who uses the Pinkfong Services which causes psychological or physical damage to others

3. The Pinkfong Services may provide third parties including its partners with personal information or share it with them to provide users with better services. If personal information is provided or shared, prior notice of the identity of partners, etc., items of personal information to be provided or shared, reasons for the provision or sharing and the period and method of the protection/management thereof shall be given to each user to obtain his/her consent thereto. If the user refuses to consent to the provision or sharing of his/her personal information, it shall not be provided to, or shared with, the partners, etc. Furthermore, after giving his/her consent to the provision of personal information, the user may withdraw such consent anytime.

Article 6 Entrustment of Processing of Collected Personal Information

The Company may entrust an outsourcing company with the collection, handling, management, etc. of personal information on users to provide its services and shall ensure that personal information is managed safely under relevant laws when the entrustment agreement is concluded.

Entrusted Task	Company
Payment Gateway	INICIS Co., Ltd.
Payment Gateway	NAVER FINANCIAL Corp.
Delivery of ordered products	DUKYUN WAVE
Delivery of ordered products	CJ Logistics Corporation
Delivery of ordered products	Corporation ELE GLS
Delivery of ordered products	ebut co.ltd
Response to customers’ questions and telephone counselling	The White Communication Co., Ltd
Short Message Service	SEJONG Telecom Co., Ltd.
Short Message Service and Kakaotalk Application Info-talk Service	KT Hitel Co., Ltd.
To provide customer support	Zendesk

Article 7 Period of Retention/Use, and Destruction, of Personal Information

1. The Company processes/retains personal information within the period of retention/use thereof under the law or such period to which consent is obtained when such information is collected.

2. The Company destroys personal information on users immediately after the purpose of the collection or provision thereof is achieved. However, records of unlawful uses such as unlawful registration, sanction, etc. are destroyed after they are kept for one year after the termination of the member’s user agreement to prevent unlawful registration and use, and membership registration information is destroyed after it is retained for 30 days after the user’s withdrawal as member(such grace period of 30 days is for the recovery of data, including prior Rewards Points, upon re-registration due to the change of mind within 30 days).

3. Pursuant to Article 6 of the Act on the Consumer Protection in Electronic Commerce, Etc. and Article 15-2 of the Protection of Communications Secrets Act which are enforced in Korea, only information with which the subject of transaction can be identified, including ID, name and email address, and computer communication/website log records, etc. may be retained after the consent to the use of services is withdrawn. If relevant laws require the retention of the following items for a specified period for the confirmation of transaction-related management obligations, etc., such items are retained for such specified period:

a. Records of indication/advertisement: Six months;
b. Records of the withdrawal of agreement/application: Five years;
c. Records of price payment/supply of goods, etc.: Five years;
d. Records of the processing of consumers’ complaints or disputes: Three years; and
e. Records of website access: Three months.

4. Personal information is destroyed in the following process and ways:

a. Process
The company selects the personal information for which the reason for destruction occurred, and destroys the personal information with the approval of the CPO.

b. Ways
1) Printed personal information: Pulverized by pulverizer or incinerated; or
2) Personal information in electronic file: Deleted with a technical method that makes the reproduction thereof impossible.

5. Introduction of the effective period of personal information

a. The Company protects personal information on those who do not use services for long(one year or longer) by storing and managing such personal information separately from personal information on other users after December 2016.
b. The non-use period is calculated based on the dates of final log-in/contact with the Company’s customer division, and information on non-users of services are separately retained and managed under a period specified in the law.
c. The Company shall give one-month prior notice of the details on the separation/storage of personal information on non-users to the relevant users by email, etc.
d. Personal information on non-users separately stored is retained for a specified period under relevant laws and destroyed after the expiration of such period. Undestroyed personal information is provided again upon the resumption of the relevant user’s use of services at his/her request.

Article 8 Matters on User’s Management of His/Her Personal Information(Inspection, Correction, Deletion, Withdrawal of Consent, Etc.)

1. The member may access/inspect, correct, delete, restrict or oppose the processing of, and withdraw, his/her personal information registered by the below methods.

1) Website/application service: Inspection, correction or withdrawal of personal information is possible by clicking the ‘Correction of Personal Information’ button after log-in.

2) The Company will forthwith respond to the user’s request to its Chief Privacy Officer or customer center by telephone, fax or email.

2. Upon the member’s request for the correction of an error in his/her personal information, the Company will not use or provide such information. If the Company has already provided a third party with erroneous personal information, it will forthwith notify such third party of the results of correction so that correction can be made.

3. The Company processes personal information withdrawn or deleted upon the member’s request according to the period of retention and use under Article 7 Paragraph 2 and it cannot be inspected or used for any other purposes.

4. The rights under Paragraphs 1 through 3 above may be exercised via a proxy of the member such as his/her legal representative or delegated person. In this case, a power of attorney shall be submitted.

Article 9 Operation/Utilization of Cookie

1. The Company uses cookies that store, and frequently find, information on users to provide them with various and unique Pinkfong Services. The cookie means a small amount of information in the form of a small text file stored on your computer by websites and services you visit or access, and is transmitted from website servers to users’ computer browsers.

Cookies are widely used to help websites and services operate and function more efficiently and to provide information about your experience when using or interacting with our websites, products, services and advertisements. Some cookies only last for the duration of the web session and expire when you close your browser. Other cookies may last longer than your web session, including after you exit your browser, remembering you when you return to our website. There are four types of cookies used on our website.

a.Essential Cookies
Essential cookies are used to enable basic functionality of the website, including page navigation, access to the secure area of the website, and search. Our website cannot perform optimized functions without essential cookies, so these cookies are activated without your consent.

Cookies in use
- csrftoken
- refresh_token
- sessionid
- token

b. Performance Cookies
Performance cookies help website operators understand the interaction between users and websites through anonymous collection and reporting of information, and by providing statistics on how users interact with the website. Performance cookies help contribute to the development of an optimized website. Performance cookies include information about which pages are most visited by visitors, and whether you received an error message from a web page. Some of these cookies are analytics cookies that have been set up to use third party web analytics software, which allows us to learn more about how our website is used. For example, alike other companies, we use Google Analytics to monitor our website traffic. These cookies do not collect information that identifies users. All the information collected by these cookies is comprehensive and anonymous and does not affect your privacy. It is used solely to improve the way your website works.

Cookies in use
- _ga
- _gid
- ajs_anonymous_id
- ajs_group_id
- ajs_user_id

c. Functional Cookies
Functional cookies allow websites to store users’ settings that may affect the behavior and appearance of the website, such as the user's location and language, and help the website to operate in accordance with users’ settings. For example, these cookies can be used to remember changes in font size, fonts, and other web page elements that you can set. It may also be used to provide services you have previously requested. The information collected by these cookies is anonymous and we cannot track your use of other websites.

Cookies in use
- pid_uid
- remember_me

d. Marketing Cookies(Pinkfong Store Affiliate)
Marketing cookies could be set by us or our affiliates through our website. They are used to build a profile of your interests so that other sites can show you ads related to our products and our affiliates. These cookies do not store your personal information directly, but are based on uniquely identifying each user's browser and internet device. If you do not accept these cookies, you will still see ads from us and our affiliates, but they will not personalize your interests.

Cookies in use
- _fbp
- AUCM3B41583018594
- CM3B41583018594_t_if
- CM3B41583018594_t_sst
- CM3B41583018594_t_uid
- __la_uid
- __la_uid_hst_1545130595862606451
- aid
- fr
- wcs_bt
- GsCK_UAC
- NWB
- _t_guid

2. The Company uses cookies for the following purposes:

a. To analyze the frequency/time, etc. of access of members and non-members and learn users’ tastes and interests to use such information as a yardstick for target marketing, service innovation, etc.; and

b. To provide members with differentiated opportunities to request participation in various events of the Company based on the degree of their previous participation and access frequency and unique information tailored to their interests.

* Installation of Cookie, and Refusal thereof

- The user may choose to install cookies. Therefore, users may permit all cookies by setting an option in their web browsers, go through verification procedures whenever cookies are stored, or refuse the storage of all cookies.

- To refuse the installation of cookies, the user may select an option in his/her web browser to permit all cookies, go through verification procedures whenever cookies are stored, or refuse the storage of all cookies.

- If a user refuses the installation of cookies, problems may occur in the provision of services to him/her.

- At any time, you may view the cookie management settings used by your web browser, and delete any cookies it has stored, which must be done one by one. To make your search easier, please find below a list of direct links for each of the main browsers in use:

- Google Chrome
- Firefox
- Edge
- Safari
- Opéra

Article 10 Matters on Technical and Managerial Measures for Protection of Personal Information

1. Technical safeguards
The Company prepares the following safeguards to ensure the safety of users’ personal information in processing it so that it cannot be lost, stolen, divulged, altered or damaged.

a. Users’ personal information is protected by passwords, and important data is protected by separate security functions with the encryption of files and data transmitted or lock-file function. However, it is imperative for the user to protect his/her password as it can be leaked to other persons for various reasons, including the use of the Internet in public places. Therefore, the user shall not divulge or provide his/her personal information to others and shall be responsible for the management of his/her personal information. The Pinkfong Services assume no responsibility for such leakage of passwords.

b. The Company takes measures to prevent damage from computer viruses with vaccine programs. Such programs are updated periodically and provided immediately upon the emergence of computer viruses to prevent breaches of personal information.

c. The Company uses security programs(SSL or SET) to safely transmit personal information on networks with encryption algorithms.

d. The Company endeavors to maintain security by applying firewalls, vulnerability-analysis systems, etc. to each server against external intrusion, including hacking attacks.

2. Managerial safeguards

a. The Pinkfong Services recognize the importance of the protection of users’ personal information and, for such purpose, limit its employees handling personal information to a minimum. The Company regularly examines matters to be implemented hereunder and whether they are implemented by relevant employees, and if there is any breach thereof, procures such breach is cured and other measures required or for improvement are taken.

b. The Company limits the number of its employees (e.g. Employees required to process personal information for their duties) having access to personal information on members to a minimum and takes the below measures for the employees.

- The Company provides its employees processing personal information with regular internal/external education and training on new security technologies, the obligation to protect personal information, etc.

- The Company operates internal procedures to prevent information leakage by persons through security undertakings of personal information processors submitted upon their joining the Company and to monitor whether its employees implement matters to be implemented under this Privacy Policy.

- The business handover and takeover of personal information processors is completed in a thoroughly secure manner, and their responsibilities for personal-information incidents after their joining and leaving the Company are specified.

Article 11 Matters about Protection of Information on Children

1. A child younger than 14 years or equivalent minimum age in the relevant jurisdiction may become a member of the Company’s website only if his/her legal representative submits a written consent thereto.

2. If the legal representative of a child younger than 14 years or equivalent minimum age in the relevant jurisdiction requests the inspection, correction, deletion, etc. of personal information collected from such child, the Company’s website shall immediately take necessary measures.

3. A request for such inspection, correction, deletion, etc. shall be made to the customer support division or the person in charge of the handling of complaints on personal information so that it can be granted after the legal representative is identified.

Article 12 Transmission of Advertising Information

The Company shall not transmit advertising information for profit to a member without his/her prior consent. The member may withdraw his/her consent to the transmission of advertising information for profit at anytime.

Article 13 Third-party Links

Pinkfong Services may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website or services, we encourage you to read the privacy notice of every website you visit.

Article 14 Automatic Decision-Making, including Profiling

The Company does not make any decision on the use of algorithm or profiling that may have material effects on its customers.

Article 15 Your California Privacy Rights

1. We do not sell or disclose customers’ personal information to other companies for those parties’ direct marketing use or business purpose unless a guest elects that we do so.

2. DO NOT TRACK
We do not track our customers over time and across third party websites to provide targeted advertising and therefore do not respond to Do Not Track (DNT) signals.

3. If you are a California resident, you have the right to request information from us about what kind of personal information has been collected and how we may share certain categories of your information with third parties, for the third parties' direct marketing purposes. To exercise this right, please contact us at cs@pinkfong.com with "California Privacy Rights" in the subject line.

4. If you are a California resident under the age of 18, and a registered user of any site where this policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to cs@pinkfong.com. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

Article 16 Obligation of Notification

If any part hereof is deleted or modified, or new provisions are added hereto, according to changes to the government’s policies or security technologies, the Company will notify such deletion, modification or addition via the websites and application services of the Pinkfong Services by no later than seven days prior to the relevant amendment.

Article 17 Division, Name and Contact Information of CPO and Personal Information Manager

1. The Company operates the following divisions-in-charge and managers responsible for the protection of personal information to protect users’ personal information and handle complaints and questions on personal information.

Chief Privacy Officer(CPO)	Name	CTO Dongwoo Son
	Division-in-charge	Tech Development Team
	Telephone	1670-2685
	Email	cs@pinkfong.com

2. The user is advised to contact the following agencies if he/she intends to report, or needs advice on, a violation of privacy.

- Privacy Call Center(http://privacy.kisa.or.kr / 118)
- Personal Information Dispute Mediation Committee(http://www.kopico.go.kr / 1833-6972)
- Supreme Prosecutors’ Office, Cyber Investigation Division(http://www.spo.go.kr / 02-3480-3570)
- National Police Agency, Cyber Security Bureau(http://cyberbureau.police.go.kr / Police Call Center 182)

Notification date : November 8, 2022
Effective date: November 15, 2022

January 6, 2022

Privacy Policy (January 6, 2022)

The Pinkfong Integrated Services(the “Pinkfong Services”), including the Pinkfong Store website/mobile application services, Pinkfong TV mobile application services, Pinkfong Homeschool Play mobile application services, Pinkfong Homeschool services and Pinkfong interactive mobile application services operated by The Pinkfong Company, Inc.(the “Company”) value users’ personal information and do their best to ensure users have their personal information provided to the Pinkfong Services protected while using the services.

Article 1 General Provisions

1. The Pinkfong Services inform, via the Privacy Policy, users of the purpose and method of the use of their personal information and measures taken to protect their personal information.

2. Users are advised to check this Privacy Policy as they access the Pinkfong Services as this policy is subject to change according to amendment to laws or guidelines on the protection of personal information or the Company’s policy.

Article 2 Consent to Processing of Personal Information

The Pinkfong Services operate procedures enabling users to click the ‘consent’ or ‘withdrawal’ button on the Company’s processing of Personal Information. The user is deemed to have consented to the processing of his/her personal information upon clicking the ‘consent’ button. If the user does not consent to the processing of Personal Information, he/she may be restricted from using any part of the Pinkfong Services.

Article 3 Collected Personal information; Method of Collection

1. The Pinkfong Services are provided with information required to provide services for users’ application for membership registration or use of mobile application services as follows.

a. Collected personal information

1) Registration for integrated membership

[Required Items]: ID(email address as ID), password, contact information(telephone/mobile-phone number), Country
[Optional Items]: Children’s nicknames and birth year and month

2) Scope of personal information that may be collected during the use of services and business operation

a) Pinkfong Store

- Name, address, contact information
- Records of use/suspension of services, access log, cookie, access IP information
- (Product purchase, payment and delivery, refund service) Payment information on bank account/credit card, point-card number, transaction history, whether a cash receipt is issued, etc.
- (Product purchase, payment and delivery, refund service) Delivery information, including the address/name/contact information of the recipient
- (Mobile device) Device identification number, OS information, advertising identifier, telecommunications company, whether ‘PUSH’ is received
- (Purchase of overseas delivered product) Customs ID number
- (Questionnaire and event) Other selective personal information

b) Pinkfong TV Mobile Application Services

- Initial service device identification number(device ID or IMEI), region format
- Information on the user’s status(account name, nickname, store name in use)
- Photograph, cookie, date of visit, service use log, improper use log
- (KakaoTalk-/Facebook-linked service) KakaoTalk/Facebook ID

c) Pinkfong Homeschool Mobile Application Services
- Name, address, contact information
- Records of use/suspension of services, access log, cookie, access IP information
- Delivery information, including the address/name/contact information of the recipient
- (Mobile device) Device identification number, OS information, advertising identifier, telecommunications company, whether ‘PUSH’ notification is received
- (Purchase of overseas delivered product) Customs ID number
- (Survey and event) Other selective personal information

d) Pinkfong Interactive Mobile Application Services
- Initial service device identification number(device ID or IMEI), region format
- Device information(model, device type, OS version)
- Photograph, cookie, date of visit, service use log, improper use log
- (KakaoTalk-/Instagram/Facebook-linked service) KakaoTalk/Instagram/Facebook ID

b. Method of collection

- Website, bulletin board, telephone, fax, event, delivery request
- Collection of information generated via log-analysis programs and by cookies
- Provision from affiliates and purchasers
- Collection via smartphone applications
- Voluntary supply from users upon their registration for, or use of, services or customer counselling

c. Location information

The Company does not collect, store or use information with which an individual’s location can be identified. However, certain advertisement banners operated by third parties, may collect, without storage, via location-recognition advertisements of advertising-service providers as such third parties, and temporarily use, location information with a device’s censor data, etc. that may provide actual location information (including GPS signals from mobile devices) or information on nearby Wi-Fi access points and base stations. However, such use of location information is unrelated to the Company.

2. Users’ personal information collected is destroyed immediately after the purpose of its collection is achieved. The Company does not collect sensitive personal information that may infringe users’ basic human rights or use for any purpose other than that notified in advance to users, or divulge to third parties, personal information provided from them.

3. Measure taken by the Company for the member’s provision of false information
The member must guarantee the accuracy and legitimacy of his/her information. If the member submits false information in various ways, including the stealing of another person’s information, in violation of the provision above, the Company may report such member under applicable laws and deprive him/her of his/her membership.

4. The user shall be solely liable for losses or problems suffered by him/her due to personal information he/she voluntarily disclosed. The user is advised to recognize that personal information made public can be collected and used, without his/her permission, by another person, and that he/she may suffer unwanted damage caused thereby.

5. The Company may access and use information within the customer’s mobile communication device as follows for its mobile application services. The Company explains, and obtains consent to, access to required items upon the installation, or first execution, of a mobile application, and obtains separate consent to access to optional items upon the first use of such mobile application. The method of obtaining consent to access to optional items may vary depending on the OS version, however, there is no restriction on the use of basic services by a member refusing to give consent.

[Pinkfong TV Application]

Required or Optional	Item	Purpose
Required	Device ID, application record	Examination of application status(version) upon initial execution
Required	Communication record, WIFI connection information	Optimization of application use, examination of network connection
Optional	Camera	Use of QR code scanning within the application

[Pinkfong Store Application]

Required or Optional	Item	Purpose
Required	Device and application record right	Examination of application status(version)
Required	Communication record, WIFI connection information	Optimization of application use, examination of network connection
Optional	Photograph/media/file	Storage or loading of photograph, vide or contents(product review with photograph)
Optional	Camera	Use of photography function within the application

* The user may use basic services without giving consent to access to optional items.

[Pinkfong Interactive Application]

Required or Optional	Item	Purpose
Required	Device and application record right	Examination of application status(version)
Required	Communication record, WIFI connection information	Optimization of application use, examination of network connection upon initial execution
Optional	Photograph/media/file	Storage or loading of photograph, video or contents
Optional	Camera	Use of photography function or QR code scanning

* The user may use basic services without giving consent to access to optional items.

Article 4 Purpose of Collection/Use of Personal Information

1. The purpose of the Company’s collection of personal information is to identify users and confirm their intention of using the Pinkfong Services to provide them with optimized services. The Pinkfong Services collect personal information for the following purposes to a minimum extent necessary to provide various services, including e-commerce services, tailored for users’ characters and preferences and to resolve problems arising from users’ use of the Pinkfong Services.

a. Membership management

- Identification for membership-based services, restriction of use by members violating the Terms of Use, regulation of unfair uses of services
- Securing of a channel for efficient communication for notification/handling of complaints
- Confirmation of the intention of registration/withdrawal, restriction of registration/number of registration
- Confirmation of whether the legal representative of a child younger than 14 years or equivalent minimum age in the relevant jurisdiction consents to the collection of such child’s personal information, subsequent identification of the legal representative
- Preservation of records for mediation, handling of complaints, etc., giving of notice

b. Performance of agreements on the provision of services, and settlement of payments for services

- Accumulation, use and settlement of mileage
- Confirmation of orders for products and services and receipt of such orders, payment, collection, etc.
- Provision of contents/customized services, delivery, sending of invoices, identification

c. Customer counselling

- Operation of a customer center for the Identification of the customer, examination of the counselling subject, communication/notification for investigation of facts, notification of the results, etc.

d. Utilization for the development of new services and marketing

- Provision of services and placement of advertisements according to statistical characteristics, confirmation of the validity of services
- Provision of customized services to integrated-service members, development of various new services and provision of customized services
- Provision of marketing information on, and opportunities to participate in, events, examination of access frequency
- Use for marketing purposes, including events with partners and service promotion, analysis of customer information and service development for marketing purposes, statistics on members’ uses of services

2. If the user uses the Pinkfong Services as a non-member, information on the payer and receiver provided by such user is not used for any purpose other than that for payment and delivery.

3. The Company may collect and use the following behavioral information in order to provide optimized services and benefits, such as online customized advertisements, by using user’s behavioral information such as the user’s visit history, collected when the user uses the Pinkfong Services.

Items of behavioral information collected	- User’s visit history, search history and purchase history - User’s other behavioral information regarding the use of website/application
Methods of collection	- Automatic collection through user’s visit and use of the website or application - Collecting user’s behavioral information by installing Facebook or Instagram’s pixels or SDK - Other methods that are permitted by law or guidelines
Purpose of collection	- To provide personalized product recommendation service(including advertisements) based on user’s interest and disposition - To utilize user’s behavioral information for new product development and service reform
Period of retention/use	2 years from date of collection
Exercise of control by users	- Web browser : Internet Explorer, Chrome, Firefox, Safari - Smartphone: iPhone, Android
Remedies for users	Please refer to Article 14

Article 5 Provision/Sharing of Personal Information

1. The integrated-service member becomes the member of the Pinkfong Store website/mobile application and Pinkfong TV mobile application and can use the Pinkfong Services with one ID.

2. The Pinkfong Services do not use for any purpose other than services provided by the Pinkfong Services, or provide to a third party without the user’s consent, personal information on the user except information disclosed via the service screen; provided, however, that the foregoing shall not apply to the following:

a. If there are extraordinary provisions in the applicable Act;

b. If necessary for the settlement of charges for the provision of services;

c. If necessary for statistics, academic research or market survey with the information provided with which a specified individual cannot be identified;

d. If users give prior consent to disclosure;

e. If the terms of use published on the Pinkfong Services and those on other membership services or operation rules are violated;

f. If demanded by investigation authorities for investigation purposes under statutory procedures; or

g. If legal measures are taken against a person who uses the Pinkfong Services which causes psychological or physical damage to others

3. The Pinkfong Services may provide third parties including its partners with personal information or share it with them to provide users with better services. If personal information is provided or shared, prior notice of the identity of partners, etc., items of personal information to be provided or shared, reasons for the provision or sharing and the period and method of the protection/management thereof shall be given to each user to obtain his/her consent thereto. If the user refuses to consent to the provision or sharing of his/her personal information, it shall not be provided to, or shared with, the partners, etc. Furthermore, after giving his/her consent to the provision of personal information, the user may withdraw such consent anytime.

Article 6 Entrustment of Processing of Collected Personal Information

The Company may entrust an outsourcing company with the collection, handling, management, etc. of personal information on users to provide its services and shall ensure that personal information is managed safely under relevant laws when the entrustment agreement is concluded.

[Pinkfong Store Service]

Entrusted Task	Company
Delivery of ordered products	Logen Co., Ltd.
Agency for card payment and virtual account	INICIS Co., Ltd.
Response to customers’ questions and telephone counselling	The White Communication Co., Ltd
Delivery of ordered products	Jella Blue Korea Co., Ltd.
Delivery of ordered products	SP Logis Co., Ltd.
Short Message Service	SEJONG Telecom Co., Ltd.
Short Message Service and Kakaotalk Application Info-talk Service	KT Hitel Co., Ltd.

Article 7 Period of Retention/Use, and Destruction, of Personal Information

1. The Company processes/retains personal information within the period of retention/use thereof under the law or such period to which consent is obtained when such information is collected.

2. The Company destroys personal information on users immediately after the purpose of the collection or provision thereof is achieved. However, records of unlawful uses such as unlawful registration, sanction, etc. are destroyed after they are kept for one year after the termination of the member’s user agreement to prevent unlawful registration and use, and membership registration information is destroyed after it is retained for 30 days after the user’s withdrawal as member(such grace period of 30 days is for the recovery of data, including prior Rewards Points, upon re-registration due to the change of mind within 30 days).

3. Pursuant to Article 6 of the Act on the Consumer Protection in Electronic Commerce, Etc. and Article 15-2 of the Protection of Communications Secrets Act which are enforced in Korea, only information with which the subject of transaction can be identified, including ID, name and email address, and computer communication/website log records, etc. may be retained after the consent to the use of services is withdrawn. If relevant laws require the retention of the following items for a specified period for the confirmation of transaction-related management obligations, etc., such items are retained for such specified period:

a. Records of indication/advertisement: Six months;
b. Records of the withdrawal of agreement/application: Five years;
c. Records of price payment/supply of goods, etc.: Five years;
d. Records of the processing of consumers’ complaints or disputes: Three years; and
e. Records of website access: Three months.

4. Personal information is destroyed in the following ways:

a. Printed personal information: Pulverized by pulverizer or incinerated; or
b. Personal information in electronic file: Deleted with a technical method that makes the reproduction thereof impossible.