Privacy Policy

This is the privacy policy for managers who conduct friend invitation events for customers using the Somoon (SOMOON) service.

Wugle Inc. (hereinafter “Company”), as an information and communications service provider, complies with relevant Korean laws and regulations and privacy protection regulations regarding the collection, use, and provision of personal information, and actively guarantees the right to self-determination of personal information and other rights related to personal information of managers and customers.

This Privacy Policy applies to the Somoon service (hereinafter “Service”) provided by the Company.

Users, who are the actual personal information subjects using the Company’s service, including managers and customers (hereinafter “Users”), are deemed to have agreed to the Company’s collection, use, and provision of personal information in accordance with this Privacy Policy by clicking the “Start” button after confirming the contents of this Privacy Policy during registration, or by clicking the “Agree” button in other situations.

1. Definition of Terms

1. “Business” means an individual or corporate business operator who enters into a service use agreement under these terms and uses the service provided by the Company.
2. “Manager” means an individual who is an employee or agent of the business with legitimate authority to directly use the platform on behalf of the business to perform event creation and operation tasks for customers. Under these terms, the manager’s actions are legally attributed to the business.
3. “Customer” means the counterparty participating in events created and operated by the manager through the platform.

2. Personal Information Collected

Purpose of Collection

The Company collects the minimum personal information necessary for service use, and may collect the manager’s personal information for marketing information provision according to the manager’s choice. If the above personal information is collected for other purposes, separate consent is obtained from the user.

Items of Personal Information Collected

1. For the manager’s “registration,” email (e-mail), password, name, and mobile phone number are collected and used as required items. If consent for collection and use of personal information is refused for required items, Somoon service application and use will be restricted.
2. For the business’s “business verification,” required items include a copy of the representative’s ID (with major personal information such as resident registration number made unidentifiable) or a copy of the proxy applicant’s ID (with major personal information such as resident registration number made unidentifiable) and employment certificate within one month of the verification application date. However, if consent for collection and use of personal information is refused for these required items, “business verification” application and use will be restricted, and accordingly, some service applications and use may be restricted.
3. During service use, users’ IP addresses, cookies, device information, and service usage records may be generated and collected. Information collected in this way may or may not constitute personal information depending on whether it can be linked to personal information.

Cookies are small amounts of information sent by the server (HTTP) used to operate the website to the user’s computer browser and may be stored on the user’s PC hard disk. Visit records (IP, access time), cookies, browser type, and terminal information are automatically collected. When the Company uses cookies to provide quality services, users can choose whether to use cookies. At this time, users can check each time cookies are stored or refuse to store all cookies through web browser options. However, refusing cookie installation may make web use inconvenient and may cause difficulties in using some services.

3. Use of Collected Personal Information

The Company uses the collected personal information for the following purposes:

1. Contract fulfillment for service provision and fee settlement for service provision
2. Member management
3. New service development and marketing/advertising utilization
4. Customer consultation and complaint handling

4. Provision of Personal Information

The Company does not provide users’ personal information to external parties in principle. However, exceptions are made in the following cases:

1. When users have given prior consent
2. When required by law or when requested by investigative agencies in accordance with procedures and methods prescribed by law for investigative purposes

5. Destruction of Personal Information

The Company destroys the information without delay after the purpose of personal information collection and use is achieved. The destruction procedure and method are as follows:

1. Destruction procedure: Information entered by users is moved to a separate DB (or separate document box in case of paper) after the purpose is achieved and stored for a certain period or destroyed immediately according to internal policies and related laws.
2. Destruction method: Personal information stored in electronic file format is deleted using technical methods that cannot reproduce the records.

6. Entrustment and Overseas Transfer of Personal Information Processing

The Company entrusts personal information as follows for service improvement and stipulates necessary matters in the entrustment contract to ensure safe management of personal information in accordance with relevant laws.

The Company does not provide personal information to other businesses overseas. However, personal information processing tasks are entrusted overseas as follows for contract fulfillment related to information and communications service provision and user convenience enhancement.

Entrusted Company: MailChimp

• Information Management Officer: [email protected]
• Transfer Purpose: Email sending
• Entrusted (Transferred) Personal Information Items: Email, name (nickname)
• Country of Transfer: United States
• Transfer Time and Method: Transferred through network each time service is used
• Personal Information Retention and Use Period: Until member withdrawal, service termination, or entrustment contract termination

Entrusted Company: Brevo

• Information Management Officer: [email protected]
• Transfer Purpose: Email sending
• Entrusted (Transferred) Personal Information Items: Email, name (nickname)
• Country of Transfer: France
• Transfer Time and Method: Transferred through network each time service is used
• Personal Information Retention and Use Period: Until member withdrawal, service termination, or entrustment contract termination

7. Rights, Obligations, and Exercise Methods of Information Subjects and Legal Representatives

Information subjects can exercise rights such as requesting access, correction, deletion, and suspension of processing of personal information to the Company at any time. These rights can be exercised through the Company’s email, chat consultation, etc., and the Company will promptly handle related requests accordingly. However, deletion cannot be requested if the personal information is specified as a collection target in other laws.

These rights can also be exercised through legal representatives or agents of the information subject, but a power of attorney in accordance with the format of Appendix 11 of the “Notice on Personal Information Processing Methods (No. 2020-7)” must be submitted.

8. Technical and Administrative Measures for Personal Information Protection

The Company strives to prevent users’ personal information from being leaked or damaged by hacking, computer viruses, etc.

The Company backs up data regularly to prepare for personal information damage, prevents users’ personal information or data from being leaked or damaged using the latest antivirus programs, and enables safe transmission of personal information over the network through encrypted communications. In addition, intrusion prevention systems are used to control unauthorized access from outside, and efforts are made to equip all possible technical devices to ensure systematic security.

The Company’s employees who process personal information are limited to those in charge and are given separate passwords for this purpose, which are regularly renewed, and compliance with the Company’s privacy protection policy is emphasized through regular training for those in charge.

However, the Company is not responsible for personal information leaks due to user carelessness. Therefore, users are requested to make efforts to protect their own personal information.

9. Others

Remedies for Infringement of Information Subject Rights

The Company collects user opinions regarding privacy protection and prepares all procedures and methods to handle complaints. Users can report complaints to the Company’s personal information management officer and person in charge, and the Company will provide prompt and sufficient answers to user reports. Complaints can also be handled at the following institutions established and operated by the government:

1. Personal Information Dispute Mediation Committee: 1833-6972 (www.kopico.go.kr)
2. Personal Information Infringement Report Center: 118 (privacy.kisa.or.kr)
3. Supreme Prosecutors’ Office: 1301 (www.spo.go.kr)
4. National Police Agency: 182 (ecrm.police.go.kr)

Personal Information Protection Officer

The Company strives to safely manage users’ valuable information. If an incident occurs that violates the matters notified to you regarding personal information protection, the personal information management officer will perform necessary tasks including follow-up processing.

Personal Information Protection Officer

• Department: Headquarters
• Name: Woo Jung-im
• Contact: [email protected]

Personal Information Protection Department

• Department: Information Security Team
• Contact: [email protected]

If there are additions, deletions, or changes to the contents of this Privacy Policy due to changes in laws, policies, or security technology, or other changes to the supplementary provisions of this Privacy Policy, notice will be given through the Company’s service 7 days before the effective date of the changes.

These terms apply from June 1, 2023.