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: 

• Required Collection Information

The Company may collect the information directly provided by the users.

∘ Login ID (email), password, mobile phone number content, posting
∘ SNS ID, SNS name (nickname)
∘ [When using SSX withdrawal service] Real name, date of birth

• Information collected in the course of the user's use of the service
In addition to the required collection information, the company can also collect information directly provided or generated by the user in the process of using the company's services.

∘ Device identifier, operating system, hardware version, device settings, browser type and settings, app usage information

∘ IP address, log data, usage time, search term entered by user, Internet protocol address, cookie, file creation date

∘ URL of profile photo or photo, type of content viewed or used by members, people exchanged or shared by users, frequency or duration of activities of members, location of video shooting, payment record, SSX usage record, SNS friend list, national information

∘ Preference, advertisement environment, visited pages regarding service use of users

• Optional Collection Information
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

∘ Real name birth date, gender

∘ The reason for membership, interest category and SNS account information

∘ Contents and result of marketing activities and event participation

(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

2. Purpose of collecting and using information

The company collects information for the smooth provision and management of this service and uses the information of the collected user 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
• Use of information with prior consent of the users (for example, utilization of marketing 
advertisement)
• Provides customized services based on membership or social relationships 
• 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 

3. Lawful processing of personal information

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).

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. 

4. Disclosure of collected information

Except for the following cases, the Company will not disclose personal information with a 3rd 
party: 
• 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

5. Cookies and Similar Technologies

The Company may collect collective and impersonal information through 'cookies'.

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. 

The items of cookies to be collected by the Company and the purpose of such collection are as 
follows: 

This cookie is a kind of indispensable cookie for the users to use the functions /services of the Company. Unless the users allow this cookie, the services such as auto login cannot be provided. This cookie does not collect any information which may be used for marketing or memorizing the sites 
visited by the users 

∘ Check whether login is made
∘ Check whether the users are connected with correct services of the application while the Company changes the way of operating its application 
∘ Connect the users with certain application or server of the services

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/application 
∘ 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/application 
∘ Design testing: test other design of the website/application of Company

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

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.

6. 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:  
• 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 right, you, as an user, use the menu of 'amendment of member information of webpage/application 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. The above-mentioned exercise of rights may be conducted through the legal representative of the information subject or through the representative of the delegated person. In this case, you must submit a power of attorney. The company verifies whether the person who exercised the right is himself or a legitimate representative.

7. 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

8. 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.

9. Third party provision of personal information

• The company processes the user's personal information only to the extent prescribed by this personal information processing policy, and provides personal information to third parties only if there is a special regulation of the user's consent and law.

10. Personal information processing consignment

• The company entrusts personal information processing as follows for smooth personal information processing

• When signing a contract, the company specifies information prohibition, technical and managerial protection measures, restrictions on re-entrustment, management and supervision of the trustee, and compensation for damages. If the contents of the entrusted work or the trustee are changed, we will disclose it without delay through this personal information processing policy.

11. 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/application (or through individual notice such as written document, fax or e-mail) and obtain consent from the users if required by relevant laws.

12. Others

(1) Guide for the personal information obtained from the European Union or Switzerland
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.  
(2) 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. 
(3) 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:  • Period for retention and use of personal information 
The company shall destroy the user's personal information without delay if the user withdraws from this service, if the period of personal information retention has expired under the statute, or if the user requests it.
However, if it is necessary to preserve it under the provisions of the relevant statutes, the company shall keep the membership information for a certain period prescribed by the relevant statutes. Information to be kept under relevant laws and regulations is as follows: Provided, That where the contents of information to be kept and the period of storage are changed due to the revision of the relevant statutes, notwithstanding the provisions of these guidelines, the amended statutes shall apply.
∘ 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) • 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. 
• 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:

∘ Utilize security servers for transmitting encryption of personal information 
∘ Take measures of encryption for confidential information
∘ Install and operate of antivirus software
∘ Install and operate access control devices and equipments 
∘ Establish and execute internal management plan 

∘ 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

∘ 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

(4) Our service uses the YouTube API services. We also respect and adhere to Google's Privacy Policy for the protection of user data. To learn more about Google's Privacy Policy, please visit here.
Users can always revoke our service's access to their data on Google's security settings page. To visit the Google security settings page, please click here."
									

13. 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: HYUN KEUN Yoon
Dept. : EMEL Ventures Inc.,
Tel. : 070-4333-1812
Contact : cs@somesing.io

The latest update date: Nov, 2021