Privacy Policy

1. Purposes and Items of Personal Information Processed

The Company processes the minimum personal information for the following purposes:

• Service Provision and Management: Email, nickname, service usage records, access logs.
• Error Improvement and Analysis: Device information (model name, OS version), usage logs.
• Marketing and Advertising: Advertisement identifiers (ADID/IDFA).

2. Criteria for Additional Use and Provision

In accordance with Article 15(3) and 17(4) of the Personal Information Protection Act, the Company may use or provide personal information without the consent of the information subject, considering:

• Whether the purpose is reasonably related to the original purpose of collection.
• Whether the additional use/provision was foreseeable in light of the circumstances of collection or processing practices.
• Whether it unfairly infringes on the interests of the information subject.
• Whether necessary security measures, such as pseudonymization or encryption, have been implemented.

3. Period of Processing and Retention

• Service Usage Information: Until account withdrawal. Data is kept for 30 days after withdrawal to prevent fraudulent use.
• Statutory Retention: Records of contracts/cancellations (5 years), records of consumer complaints/disputes (3 years) as per the Electronic Commerce Act.

4. Destruction Procedures and Methods

The Company destroys personal information without delay when it becomes unnecessary.

Procedure: The Company selects the information to be destroyed, and destroys it under the approval of the Privacy Officer.

Method: Electronic files are permanently deleted using technical methods that prevent restoration. Non-electronic documents (if any) are shredded or incinerated.

5. Automatic Collection Devices (Cookies)

The Company uses cookies to store and retrieve usage information. You can refuse cookie storage through your web browser or mobile OS settings.

6. Behavioral Information (Ads)

The Company collects behavioral information to provide optimized personalized services through Google AdMob.

Refusal Method:

• Android: Settings -> Google -> Ads -> Reset/Delete Advertising ID
• iOS: Settings -> Privacy & Security -> Tracking -> Allow Apps to Request to Track (Off)

7. Third-Party Provision and Entrustment

The Company entrusts the following tasks for smooth service:

• Entrustee: Google LLC (Firebase, AdMob)
• Task: Data storage, infrastructure operation, usage analysis, and ad serving.

8. Overseas Transfer of Personal Information

The Company transfers personal information to the USA (Google, Apple) for cloud infrastructure.

• Items Transferred: Email, nickname, device info, usage logs, ad identifiers.
• Method/Timing: Real-time transmission via network during service use.

9. Rights of Information Subjects

Information subjects may exercise their rights to access, correct, delete, suspend processing, or request data portability at any time.

10. Protection of Children under 14

The Company requires consent from legal representatives to process the personal information of children under 14.

11. Rights regarding Automated Decisions

The Company does not make automated decisions using AI that significantly affect the rights or obligations of information subjects.

12. Measures to Ensure Security

The Company implements technical (encryption, antivirus) and administrative (access control, internal management plan) measures.

13. Privacy Officer

• Name/Department: BUXUAN COMPANY Privacy Management Team
• Contact: manager@eclamo.com / [Insert Phone Number if available]

14. Priority and Changes

In case of any discrepancy between the English and Korean versions of this Privacy Policy, the Korean version shall prevail.