1. HOW WE COLLECT AND USE YOUR PERSONAL INFORMATION

We collect certain Personal Information directly from you when you use the Services for example, to create an account:

• Contact Information, including name, postal address, email address, phone number, and other contact methods you provide to us.
• Employment Information, including employer.

Please note: When communicating with us (whether by text message, email, or through the Services or other means), please do not send us any sensitive information pertaining to yourself or others. We do not intend to collect or store sensitive information or special categories of information.

We may combine Personal Information that you provide to us with Personal Information that we collect from you, or about you from other sources, in some circumstances. This will include Personal Information collected in an online or offline context.

2. PURPOSE OF COLLECTION OF PERSONAL INFORMATION

We may process your Personal Information for the following purposes:

• To provide and administer the Services and any related or underlying services to you;
• To administer and provide our training program, rewards, including gift cards or other promotional items, and certificates offered via participation in the Services;
• To fulfill a service to you. For example, if you email us a question, we may use your email address to process your request and respond to your question;
• To market to you;
• To monitor and analyze trends and aggregate information;
• To protect and prevent against fraud and misuse of the Services;
• To send updates, newsletters and notifications to you relating to the Services and underlying services, special events, or contests;
• To fulfill any other purpose for which you provide it;
• To fulfill other purposes disclosed at time of collection;
• To fulfill any legal or regulatory requirements and any of our internal policies;
• As set forth in a separate agreement between you and us;
• For any other purpose with your consent; and
• As otherwise set forth in this Policy.

3. SHARING YOUR PERSONAL INFORMATION

We will not sell Personal Information that we collect from the Services to any third party for monetary consideration. We may share or disclose your Personal Information as described below:

• Subsidiaries and Affiliates. We disclose Personal Information about you to our subsidiaries and affiliates for business purposes to help us provide the Services, underlying services, and to support our internal and business operations, including marketing, analytics, security, and prize fulfillment. This may include cross-border transfers, conducted in accordance with applicable laws.
• Service Providers & Contractors. To help us provide superior service, your Personal Information will be shared with our service providers, contractors, and other third parties we use to support our business. Such third parties may help us with aspects of our business such as delivering and facilitating the services needed to support our business relationship with you, supporting and administering promotions, fraud prevention, providing customer service, maintaining and analyzing data, sending customer communications on our behalf, and promotions and prize fulfillment for contests, sweepstakes, and other promotions.
• Analytics & Marketing Partners. We share your Personal Information, including without limitation your contact information with entities that perform marketing or data aggregation services on our behalf.

Additionally, we share and disclose Personal Information under the following circumstances:

• In the Event of Merger, Sale, Divestitures, or Change of Control. We reserve the right to transfer Personal Information to a buyer or other successor in interest that acquires rights to that information as a result of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of us or substantially all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about you is among the assets transferred.
• With our Professional Advisors. We share your Personal Information with our lawyers, auditors, and other professional advisors, to comply with applicable legal and regulatory requirements, and to support us with the purposes described in this Policy.
• With your Authorized Representatives. If another individual is managing your relationship with us or your email account which the Services connects to on your behalf, as authorized by you or as a personal representative under applicable law, that person can view all Personal Information about you.
• With Your Consent. We share your Personal Information for other purposes pursuant to your consent or at your direction.
• Other Disclosures. We disclose your Personal Information if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) conform to legal requirements and comply with any court order, law, or legal process, including responding to any government, law enforcement, or regulatory request; (ii) enforce our Terms and Conditions, other agreements, including between you and us, and any other documents included or referenced therein (all of which are incorporated into and made a part of this Policy by reference); (iii) fulfill the purpose for which you provide it; (iv) detect, prevent, or otherwise address fraud or security issues; or (v) protect against harm to our, your, or third parties’ rights, property, or safety.

We may share and disclose de-identified and/or aggregate analytics with third-party partners for any legal purpose, including, when and where applicable, sharing and disclosing non-personally identifiable information combined with Personal Information.

4. YOUR CHOICES.

If you do not want us to use your email account to send you marketing emails or non-transactional promotional materials, please directly click on the unsubscribe link at the bottom of any of our email messages to you.

5. SECURITY PRECAUTIONS

We take information security very seriously and use reasonable administrative, technical, and physical measures to protect your Personal Information from unauthorized access. Unfortunately, no security system can be guaranteed to be 100% secure. Accordingly, we cannot guarantee the security of your information and cannot assume liability for improper access to it.

6. RETENTION

We may retain your Personal Information, including any correspondence you have with us, for as long as is necessary for the purposes set out in this Policy, including retaining Personal Information to comply with our legal obligations, to resolve disputes, for information security purposes, and to enforce our legal rights, terms, or policies.

7. THIRD-PARTY WEBSITES

The Services may contain links to third-party services, websites, mobile applications, and/or contain advertisements from third parties that are not affiliated with us – and which may link to other websites, services, or applications. While we endeavor to work with third parties that share our respect for user privacy, we are not responsible for the privacy policies or privacy practices of such third parties. Any information collected by third parties are not covered by this Policy. You are responsible for knowing when you are leaving the Services to visit a third-party website, service, or application and for reading and understanding the terms of use and privacy policy statements for each such third party.

8. CHILDREN

The Services and our other Services are not directed to, and we do not knowingly collect Personal Information from, children under the age of 18 or minors (as defined by applicable laws). If you are a minor, please do not attempt to fill out our forms or send any Personal Information about yourself to us. If a minor has provided us with Personal Information without parental or guardian consent, the parent or guardian should contact us immediately to remove the relevant Personal Information and unsubscribe the minor. If we become aware that a minor has provided us with Personal Information, we will take steps to promptly delete such Personal Information from our files.

9. EXTRATERRITORIAL TRANSFERS OF PERSONAL INFORMATION

The Services are hosted in the South Korea. Please also note that if you are providing data or using the Services from the U.S., your Personal Information will be accessed and transferred to South Korea, which may have data protection laws that are less protective than the laws of the jurisdiction in which you reside. For such data transfers, we rely on your consent. If you do not want your information transferred to, processed, accessed, or maintained in South Korea, then you should immediately cease accessing the Services and using the Services.

10. CALIFORNIA PRIVACY RIGHTS

This section explains how we collect, use, and disclose Personal Information about users, customers, and visitors who reside in California (“consumers” or “you”). It also explains certain rights afforded to consumers under California’s Shine the Light law and the California Consumer Privacy Act of 2018, as revised and updated by the California Privacy Rights Act (collectively, “CCPA”). This section uses certain terms that have the meaning given to them in the CCPA including Personal Information.

1. 10.1 Shine the Light: Under California Civil Code Section 1798.83 (“Shine the Light”), California residents have the right to request in writing from businesses with whom they have an established business relationship, (a) a list of the categories of Personal Information, such as name, e-mail and mailing address and the type of services provided to the customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes; and (b) the names and addresses of all such third parties. To request the above information, please contact us as directed in the Contact Us section below with a reference to California Disclosure Information.
2. 10.2 CCPA
   
   1. 10.2.1 Categories of Personal Information Collected: We may collect (and have collected during the 12-month period prior to the “Last Modified” date of this Policy) the above categories of Personal Information about you in the “How We Collect and Use Your Personal Information” section above.
   2. 10.2.2 Purpose of Collection: We may use (and may have used during the 12-month period prior to the “Last Modified” date of this Policy) your Personal Information for the business or commercial purposes described in the “Purpose of Collection of Personal Information” section above.
   3. 10.2.3 Sources of Personal Information: During the 12-month period prior to the “Last Modified” date of this Policy, we may obtain (and may have obtained) Personal Information about you from the sources identified in the “How We Collect and Use Your Personal Information” section above.
   4. 10.2.4 Selling and Sharing Personal Information: We do not sell or share your Personal Information in exchange for monetary consideration.
   5. 10.2.5 During the 12-month period prior to the “Last Modified” date of this Policy, we may have shared or disclosed the following categories of Personal Information about you for a business or commercial purpose with certain categories of third parties, as described below:

1. 1. 10.2.6 California Consumer Privacy Rights
      Under CCPA, consumers have certain rights regarding their Personal Information, as described below.
      • Right of Access. You have the right to request, twice in a 12-month period, that we disclose to you the following information about you, limited to the preceding twelve (12) months:
        • · The categories of Personal Information that we collected about you;
        • · The categories of sources from which the Personal Information is collected;
        • · The business or commercial purpose for collecting or selling Personal Information;
        • · The categories of third parties with whom we share Personal Information;
        • · The specific pieces of Personal Information that we have collected about you;
        • · The categories of Personal Information that we disclosed about you for a business purpose or sold to third-parties; and
        • · For each category of Personal Information identified, the categories of third parties to whom the information was disclosed or sold.
      • Right of Deletion. You have the right to request that we delete any Personal Information about you which we have collected from you, subject to exceptions within the law.
      • Right to Opt-Out. You have the right to opt-out of the disclosure of Personal Information about you for monetary or other valuable consideration. We do not sell any Personal Information for monetary value.
      • Right to Correction. You have the right to request that we maintain accurate Personal Information about you and correct any Personal Information about you which we have collected from you, subject to exceptions within the law.

2. If you would like to exercise your California privacy rights, please refer to the “Consumer Requests and Verification” section below.

3. 1. 10.2.7 Consumer Requests and Verification
      
      1. (i) Right to Non-Discrimination. We may not discriminate against you because you exercise any of your privacy rights contained in this Policy including, but not limited to:
         • Denying goods or services to you;
         • Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
         • Providing a different level or quality of goods or services to you; or
         • Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
         However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
      2. (ii) Verifying Requests. You may request to exercise your rights of access, deletion, or correction by contacting us as described in the “Contact Us” section below. To help protect your privacy and maintain security, we will take steps to verify your identity before processing your request. If you request access to or deletion of your Personal Information, we may require you to provide any of the following information: name, email address, telephone number, or postal address. When you make such a request, you can expect the following:
         • As required under applicable law, we will verify your identity. You will need to provide us with your email address and full name. We may ask for additional information if needed.
         • We will confirm that you want your information accessed, corrected, and/or deleted.
         • We will confirm our receipt of your request within 10 days. If you have not received a response within a few days after that, please let us know by contacting us at the email or phone number listed below.
         • We will respond to your request within 45 days upon receipt of your request. If necessary, we may need an additional period of time, up to another 45 days, but we will reply either way within the first 45-day period and, if we need an extension, we will explain why.
         • In certain cases, a request for access, correction, or deletion may be denied. For example, if we cannot verify your identity, the law requires that we maintain the information, or if we need the information for internal purposes such as providing services or completing an order. If we deny your request, we will explain why we denied it and delete any other information that is not protected and subject to denial.
      3. (iii) Authorized Agents. You may designate an authorized agent to request any of the above rights on your behalf. You may make such a designation by providing the agent with written permission, signed by you, to act on your behalf. Your agent may contact us as described in the “Contact Us” section below to make a request on your behalf. Even if you choose to use an agent, we may, as permitted by law, require:
         • The authorized agent to provide proof that you provided signed permission to the authorized agent to submit the request;
         • You to verify your identity directly with us; or
         • You to directly confirm with us that you provided the authorized agent permission to submit the request.

11. CONTACT

If you have any questions or concerns regarding any privacy-related information included in, or omitted from, this Policy, then please contact us. You may submit any privacy-related inquiries or complaints to us via the below: