Huvle corp. (huvle.com hereinafter referred to as the "Company" or “Service”) shall not be liable for any violation of the provisions of the relevant laws and regulations on personal information protection, such as the Communications Privacy Act, the Telecommunications Business Act, the Act on the Promotion of Information and Communication Network Utilization and Information Protection, We are committed to protecting the rights and interests of our users by establishing a privacy policy in accordance with relevant laws and regulations.

The company’s privacy policies can be amended by government laws and guidelines, the company’s terms and conditions, and internal policies. When if the company amends the privacy policies, it shall notify the changes for a considerable period after the date of application, 10 days before the date of application. In the case of an amendment to the terms and conditions unfavorable to the members, the company shall notify it clearly by posting it on the service website, or by using electronic means such as the notice window for the members’ approval when they are logging in, the e-mail, the electronic message within 30 days before the date of application and within the considerable period after the date.

1. Personal information items to be collected and collection methods

The items and methods of collecting personal information collected by the company may vary from each service provided by Huvle corp.

1. A. Items of personal information we collect

   • First, the company collects the following minimum personal information as mandatory items for the purpose of membership classification and smooth use of services.
     - Device ID, Mobile phone number, E-mail address
   • Second, the following information can be automatically generated and collected during the service use or business process.
     - IP Address, Service utilization record, Bad usage record, access log, information of game version, ADID, information of Device, etc.
   • Third, the following payment information can be collected during the process of using paid service.
     - Payment via mobile phone : Mobile phone number, Carrier, Payment approval number, etc.

2. B. Method of collecting personal information

   The company collects personal information by the following methods.
   - Automatically collect when you access app
   - Direct input by the user in the process of using the service

2. Purpose of collection and use of personal information

1. A. Implementing contracts for providing service and settling charges for providing service

   Providing content, providing specific customized service, Shipping goods or bill etc., Identity verification, purchase and payment of charges

2. B. Management member

   Providing membership service, Personal identification, Preventing the bad member(who has been banned due to the violation of the contents specified in subparagraph 1–25 of paragraph 1 of Article 18 of Huvle Terms and Condition of Use) from illegal usage and unauthorized usage, Confirming intention to join, limitation of joining and joining number of times, handling petition such as handling complaints, delivering notice, confirming intention of withdrawal from member

3. C. Utilization for developing new service and for marketing and advertising.

   The company processes personal information to develop new services and provide customized services, to provide services and place advertisements in accordance with statistical characteristics, to confirm validity of services, to provide information about events and advertisements, to provide an opportunity to participate, to place advertisements, to figure out access frequency or to gather statistics on members’use of services.

3. Sharing and providing personal information

The company must use the user’s personal information within the range specified in “2. Purpose of Processing Personal Information”, not exceed the said range without prior consent from the data subject, and as a principal rule, not disclose the said information externally. However, the following are exceptions.

1. A. When user has granted prior approval

2. B. When requested by an investigative agency, through procedures and methods defined by law, for investigative purposes, in accordance with legal regulations.

4. Entrusting the handling of personal information

Entrusting the handling of personal information

5. Retention and use period of personal information

In principle, the personal information of the member is destroyed without delay when the purpose of collecting and using the personal information is achieved.
However, the following information will be kept for the period specified below for the following reasons.

1. A. Reasons to retain information due to the internal policy of the company

   • - Records of dishonest use
   • • Retention Reason: Prevention of dishonest use
   • • Retention Period: 1 year

2. B. Reasons to Retain Information according to the Law

   If it is necessary to retain personal information collected in accordance with the law such as the Commercial Law and the Consumer Protection in the Electronic Commerce Transactions Act, the Company will retain the personal information collected during certain periods specified by the each law. In such cases, the Company shall use the retained personal information for the purpose of the retention only, and the retention periods are as the following.

   • - Records on Payment and Provision of Goods
   • • Retention Reason : Consumer Protection in the Electronic Commerce Transactions Act
   • • Retention Period : 5 years
   • - Records on Electronic Financial Transaction
   • • Retention Reason : Electronic Financial Transaction Act
   • • Retention Period : 5 years
   • - Records on Consumer Complaint and Dispute Mediation
   • • Retention Reason : Consumer Protection in the Electronic Commerce Transactions Act
   • • Retention Period : 3 years
   • - Records on Access to Website
   • • Retention Reason : Protection of Communications Secrets Act
   • • Retention Period : 3 months
   • - Record on sign/advertisement
   • • Retention Reason : The Act on Consumer Protection in Electronic Commerce
   • • Retention Period : 6 months
   • - Record regarding contract or withdrawal of subscription
   • • Retention Reason : The Act on Consumer Protection in Electronic Commerce
   • • Retention Period : 5 years

6. Procedures and methods of personal information destruction

In principle, the personal information of the user is destroyed without delay when the purpose of collecting and using the personal information is achieved. The procedure and method of destroying personal information of the company are as follows.

1. A. Destruction procedure

   • - The information entered by the user for customer inquiries is transferred to a separate DB(in case of paper, separate filing box) after the purpose is accomplished and stored for a certain period of time according to the internal policy and other relevant laws and regulations (see the period of possession and use).
   • - This personal information will not be used for any purpose other than those held by law unless otherwise provided by law.

2. B. Methods to destroy

   • - Personal information printed on paper is destroyed by crusher or incineration.
   • - Personal information stored in the form of electronic files is deleted using a technical method that cannot reproduce the record.

7. Rights of users and legal representatives and how to exercise them

1. - Users may view or modify their own registered personal information at any time. If a user does not agree to the processing of personal information by the Company, he/she can demand to withdraw his/her consent, or request to cancel the membership. However, in such cases, a user might not be able to use the entire or partial service.

2. - Users can click on ‘Modify Personal Information’ (or ‘Modify Member Information’) to view and/or modify their own registered personal after going through the identification procedure. Users can click on “Cancel Membership” to cancel their memberships (to withdraw consent) after going through the identification procedure.

3. - Or contact the person in charge of personal information in writing, by phone or email and we will take action without delay.

4. - If errors in personal information are requested to be corrected, the company will not use or provide the personal information until the requested correction has been completed. Also, if the wrong personal information has already been provided to a third party, the Company will immediately notify the results of any corrections to a third party so that the corrections can be made properly.

5. - The Company shall deal with personal information deleted at the request of the user or legal representative as described in "5. Retention and use period of personal information" and shall not be viewed or used for any other purpose.

8. Matters concerning installation/operation and refusal of automatic collector of personal information

1. First, the personal information of users collected by the company is the device ID, mobile number, and e-mail. If you refuse to collect it, you can immediately delete the application or cancel the registration (membership withdrawal)

2. Second, the company can collect your advertising identifier (ADID). The advertising identifier (ADID) is the advertising identification value of the user of the Android mobile app and may be collected for measurement to provide the personalized service to the user or to provide the advertisement in a better environment.

3. • Rejection method: Settings -> Google (Google Settings) -> Ad -> Turn off Ad Personalization

4. However, if you select the option to refuse ADID collection, you may experience inconvenience in using personalized services.

9. Technological and Administrative Protection Measures of Personal Information

In handling personal information of users, the Company takes the following technical and administrative measures to ensure that personal information is not lost, stolen, leaked, altered, or damaged.

1. A. Encryption of collected information

   Due to the handling of personal information and app characteristics, Huvle collects just minimal personal information.

2. B. Measures against hacking

   The company is doing its utmost to prevent leakage or damage of personal information of members by hacking or computer viruses. In order to prevent personal information from being affected, we regularly backup the data. We use the latest anti-virus software to prevent users' personal information or data from being leaked or damaged and to securely transmit personal information on the network through encrypted communication, etc. We use a firewall to control unauthorized access from the outside, and make efforts to have all possible technical devices able to ensure security systematically.

3. C. Minimize and train handling staff

   The company's personal information handling staff is limited to the person in charge and is given a separate password for this purpose and is being regularly updated. We constantly emphasize the importance of compliance with the privacy policy through regular training of the person in charge.

4. D. Operation of personal information protection organization

   Through the in-house personal information protection organization, we check the implementation of the personal information policy and whether the person in charge is complying it, and we are working to correct and rectify any problems that are found. However, the Company does not take any responsibility for any problems caused by leakage of personal information due to user negligence or problems on the Internet.

10. Contact of Management Officer and Person in charge related to Personal Information

You may file any complaints about the privacy of your personal information with the person in charge of personal information management or the relevant department using your company's services. The Company will respond promptly to all users' complaints.

1. Personal Information Management Manager
2. Name: Yoo Chang-Hoon
3. Tel. : 070-7008-0000
4. Position: Deputy Administrator
5. Dept. : Web service development team
6. E-mail : admin@huvle.com

11. Duty of Notification

If there is any addition, deletion, or amendment of the current Privacy Policy, we will notify you through an 'Announcement' on the corresponding app at least 10 days prior to the revision. However, notifications for amendments that affect significant rights of users, including changes to the collection and use of personal information, or providing it to 3rd party, will be notified at least 30 days prior to the scheduled amendment.

1. - Announcement date : January 21, 2021
2. - Enforcement date : January 21, 2021

The copyright of this privacy policy is in Huvle and will be punished by Korean law for unauthorized copying.