1. Items of Personal Information Collected and Methods of Collection
A. Items of Personal Information Collected
1) Information Necessary for Member Registration
[Required] Phone number, nickname (name), password
Social Media Account Registration
[Required] Google nickname
[Optional] Google account email
[Required] Apple nickname
[Optional] Apple account email
2) Information Necessary for Service Use
The Company collects the following personal information from users during their use of the Service.
Any photos, videos (including screen captures), voice information, short messages written by the user, text written by the user, geographic information according to the user's network access, log data, cookies, location information, access information, IP address, terminal performance, bandwidth, Service usage statistics, network type, device information (device type, model name, device ID, OS), when an error occurs, the date and time of the error, and the status of the function and application being used at the time of the error, advertisement identifiers, terminal time zone, version of applications used by users, locale country and language of the user's terminal, time and location (country, city) of the user's login, user purchase history on the App Store, the user's available language, golf swing photos, videos, driving force, flying distance, strokes, golf club, and preferred brand necessary for customized information provided, sent, streamed, and/or uploaded for use of the Service by the user.
The Company collects the following personal information from users applying to Golf Fix-Coach.
Copy of ID, real name, evidence of license, bank account information, and email address
3) The Company does not collect the personal information of children under the age of 14.
The Company does not allow children under the age of 14 to use the Service and does not collect the personal information of children that are not permitted to use the Service. If the Company confirms that it has received the personal information of children that are not permitted to use the Service, the Company will immediately dispose of such information.
B. Methods of Collection
The Company collects personal information directly inputted by the user during their member registration and use of the Service.
The Company collects personal information directly inputted by the user during their member registration and use of the Service through the webpage and Service application.
The Company receives personal information from third parties that are partnered or affiliated with the Service.
If users register to the Service through their Facebook or Google accounts or through another platform, the Company receives their public profile information uploaded on such platform. In such case, the relevant platform will provide the user’s personal information to the Company after obtaining the user’s consent.
The Company may collect user information automatically during their use of the Service.
The Company may collect user information generated through an automatic process during their use of the Service. Such information may or may not constitute personal information depending on their connection with personal information.
2. Purpose of Collection and Use of Personal Information
The personal information collected upon the member registration or use of the Service is used for the following purposes.
- Member Management: identity verification, user identification, registration intention confirmation, age confirmation, prevention of illegal and unauthorized use, imposing use restrictions for use that is fraudulent or in violation of law or the Terms of Service, and preventing and sanctioning improper use or other activity that interferes with the smooth operation of the Service
- Service Provision: connection between users through customized services, payment processing for use of the Service, delivery of all inquiries, complaints, and notices related to Service use, and providing customized services through presumptions based on demographic characteristics and user interests, preferences, and dispositions
- Service Improvements: error analysis through log analysis, Service function and performance improvement, development of new services and contents, sanctions against Service use that violate the Terms of Service and Service guidelines, monitoring to create a healthy Service environment, providing various services including customer benefit services, Service usage record, statistics on Service use, such as access frequency and interactions between users, and building the Service environment and improving the Service bases on such data
- Transmission of advertising and event information (for users who consented to receiving marketing information): providing information on various events and opportunities to participate, providing information on new Company products, new Service functions, and other advertising information, and use for marketing or promotion
In accordance with PIPA, the Company may use and provide personal information without the consent of the data subject in consideration of the following factors to the extent that it is reasonably related to the original purpose of collection.
- Whether it is reasonably related to the original purpose of collection
- Whether the additional use or provision of personal information was foreseeable in light of the circumstances in which the personal information was collected or customary information processing practices
- Whether it unfairly infringes on the interests of the data subject
- Whether necessary measures have been taken to ensure security, such as pseudonymization or encryption
3. Provision of Personal Information to Third Parties
In principle, the Company will not provide personal information to third parties, except under exceptional circumstances, such as when the user has given prior consent, when there are special regulations in the law or when it is unavoidable to comply with legal obligations, or when it is necessary for the settlement of fees for the provision of information and communication services. However, for the purpose of providing lessons or other services, the nickname and swing information of users registered on “Golf Fix-Coach” may be provided to third parties.
4. Personal Information Retention, Use Period, and Destruction
Personal Information Retention and Use Period
When the Company collects personal information from users, in principle, the Company uses and retains such personal information within the period consented to by the user and destroys the user's personal information when the purpose of use is achieved. However, if it is necessary to preserve personal information according to the provisions of relevant laws and regulations, the personal information will be retained for a certain period specified by law as follows.
- Act on the Consumer Protection in Electronic Commerce, Etc.
- Records regarding contracts or subscription withdrawal: 5 years
- Records regarding payment and supply of goods and services: 5 years
- Records regarding consumer complaints or dispute resolution: 3 years
- Records regarding labeling and advertising: 6 months
- Commercial Act
- Information contained in commercial ledgers and important documents related to business: 10 years
- Information contained in a slip or similar document: 5 years
- Protection of Communications Secrets Act
- Log records such as user's service use and access point tracking data: 3 months
- Other communication confirmation data: 12 months
- Electronic Financial Transactions Act
- Records regarding electronic financial transactions: 5 years
- If an investigation regarding a violation of related laws is in progress, then until the end of such investigation
- If any credit/debt remain outstanding arising from the use of the Service, then until the settlement of the corresponding credit/debt
Personal Information Destruction Procedure and Method
In principle, Members’ personal information is destroyed without delay when the purpose of processing such personal information is achieved. However, information that must be retained according to other laws is separately retained for the period specified by law and then destroyed, and the procedure, deadline, and method of destruction are as follows.
A. Destruction Procedure
Once the purpose of the information inputted by the Member is achieved, the information is deleted without delay. If retention of such information is required by relevant law, such information will be transferred to a separate database (if on paper, then a separate filing cabinet), securely retained for the period pursuant to Company policy and applicable law, and subsequently destroyed. In such case, any personal information transferred to the separate database will not be used for any purposes other than as permitted by law.
B. Destruction Method
① Personal information stored in electronic file format will be destroyed by using technical methods so that such information cannot be restored or regenerated.
② Personal information printed on paper will be destroyed by shredding or incineration.
C. Destruction Deadline
The Company destroys Members’ personal information immediately after the retention period of personal information has lapsed, or when the personal information is deemed to be no longer necessary due to the achievement of the purpose of processing personal information, the termination of the Service, or the closing of the Company’s business.
5. User Rights and How to Exercise Them
A user may exercise any of the following rights against the Company regarding personal information processed by the Company: (1) demand access to personal information, (2) demand correction of errors, (3) demand deletion, and (4) demand the ceasing of processing (collectively, “Privacy Rights”). Privacy Rights can be exercised via writing, email, or fax according to the forms set forth in Annex 8 of the Enforcement Regulations of the PIPA, and the Company shall take measures to respond to such demands without delay. Privacy Rights may be exercised by the legal representative or other agent of the data subject. In such case, a Power of Attorney in the form set forth in Annex 11 of the Enforcement Regulations of the PIPA must be submitted.
If the data subject requests correction or deletion of errors in personal information, the Company will not use or provide such personal information until the correction or deletion is complete.
A Member may use the functions on the homepage to view, edit, or delete his/her personal information.
6. Installation/Operation and Refusal of Operation of Automatic Personal Information Collection Tools
A. Purpose of Cookies
Cookies are used to provide users with customized services and to make Service improvements through user behavior analysis based on login and recent visitation records.
B. Installation/Operation of Cookies and Refusing Cookies
Users have options regarding the installation cookies. Users may set their browser options on their web/mobile device to allow all cookies, confirm each time a cookie is saved, or refuse to save all cookies. However, refusing to save cookies may cause difficulties in using the Service.
7. Measures to Protect Personal Information
When processing personal information of users, the Company prohibits unauthorized access from outsiders, keeps records of access to the personal information processing system, conducts regular in-house training for personal information processing staff, and takes other security measures determined in the PIPA to ensure that personal information is not lost, stolen, leaked, falsified, or damaged.
8. Personal Information Manager
The Company has appointed the following personal information manager to handle users' personal information protection tasks and related grievances. If you have any inquiries, complaints, opinions, or other matters related to personal information protection while using the Service, please contact the personal information manager and the relevant department. The Company will do its best to listen to the voices of its users and provide prompt and sufficient answers.
Personal Information Manager
Department: Personal Information Protection Team