Before amendmentAfter amendment
Privacy
VCNC Privacy Policy Revision

VCNC (Hereafter the “Company” or called as "Between") complies with privacy policies stipulated in relevant laws including Information Communication Network Promotion and Protection of Information Laws, Privacy Laws, Protection of Communications Secrets Act, Telecommunications Business Act which required to be observed by information communication service providers, and we take the security of your personal information very seriously by enacting a policy for handling personal information based on relevant laws.
Privacy
VCNC Privacy Policy Revision

VCNC
Inc. (Hereafter the “Company” or called as "Between") complies with privacy policies stipulated in relevant laws including Information Communication Network Promotion and Protection of Information Laws, Privacy Laws, Protection of Communications Secrets Act, Telecommunications Business Act which required to be observed by information communication service providers, and we take the security of your personal information very seriously by enacting a policy for handling personal information based on relevant laws.
1. Personal information collected
The company collects the following personal information when you use the service of Between for the first time for subscribing to a membership (or subscribing for service), customer service and to provide services.

■ Essential: Email address, name (or nickname), date of birth, cell phone number, sex, cell phone information

○Personal information collected The company collects the following personal information when you use the service of Between for the first time for subscribing to a membership (or subscribing for service), customer service and to provide services. ■Essential: Email address, name (or nickname), date of birth, cell phone number, sex, cell phone information(including model name, mobile operator, OS, device identification number, advertisement ID, etc.) Location information(subject to agreement to the Location based service Agreement) connected partner information, etc.

1. Personal information collected

You can enter account information to connect to external services selected by you including Facebook accounts for service.

Lastly, the following information can be automatically generated and collected while using service or while conducting businesses.
■ IP Address, date of access, service log, cookie, access log

○Personal information collected ■ You can enter account information to connect to external services selected by you including Facebook accounts for service. Lastly, the following information can be automatically generated and collected while using service or while conducting businesses. ■ IP Address, date of access, service log, cookie, access log, bad usage history, application installation information, network location information, inquiry history, payment history, other information collected in the process of using the services, text and information that users voluntarily enter to use the service,etc.

2. Collection and use of personal information

(New)
2. Collection and use of personal information

○Develop customized member service
Development and socialization of new services(products), improvement of advertising information such as events, satisfaction surveys, provision of services and advertisements according to demographic characteristics, identify the frequency of access or statistical data extraction of users’ service usage, develop and provide the discount service for each payment type.
○Process of pseudonym information for statistics preparation, scientific research, and record preservation for the public interest
2. Collection and use of personal information


3. Use for developing new service and marketing·advertisements
Develop new service and provide customized service, provide service according to statistical features and advertisements, checking validity of service, provide opportunities to participate in promotions or provide advertisements, examining access frequency, statistics on service usage by members

2. Collection and use of personal information

○Marketing·advertisements(Upon consent to receive marketing information)
Provide opportunities to participate in promotions or provide advertisements.
3. Sharing and providing personal information

The company uses personal information of users within the scope disclosed from "2. Collection and use of Personal Information” in principle, and the following information can be disclosed while using our service.
3. Sharing and providing personal information

The company uses personal information of users within the scope disclosed from "2. Collection and use of Personal Information” in principle,
the member's personal information shall not be used beyond the scope of terms, disclosed or provided to a third party, except in cases where the user's prior consent or stipulated by laws and regulations. However, in the following cases
Before amendment

4. Commissioning of personal information

The agents for treating personal information and business of agents for the company are as shown below.

Consignment companyConsigned contentProvided informationRetention and use period from the recipient
AWSInfrastructure management for service provision and analysisInformation necessary to provide servicesUntil membership withdrawal or consignment contract termination
After amendment

4. Commissioning of personal information

1) When to entrust the processing of personal information to a domestic company for service use.

Consignment companyConsigned contentProvided informationRetention and use period from the recipient
AWSInfrastructure management for service provision and analysisInformation necessary to provide servicesUntil membership withdrawal or consignment contract termination


2) When to entrust the processing of personal information to an overseas company for service use.

Consignment companyPurposeCountry
Transfer date and method

Transferred information

Retention and use period
AWS
Infrastructure management for service provision and analysis


United States of America, Japan, Singapore


Personal information is transmitted when business is needed through the network

Information necessary to provide services
Until membership withdrawal or consignment contract termination

Zendesk
Customer service process and guidance


United States of America


When entering the customer center, personal information is transmitted through the network


Email

Until membership withdrawal or consignment contract termination

QuickEmailVerification
Email validation service

United States of America
Personal information is transmitted when business is needed through the network

Email
Destroy without delay upon the completion of work


Google LLC, Microsoft


Document creation and collaboration tool

United States of America
Personal information is transmitted when business is needed through the network


Information contained in the documents


Destroy without delay upon the completion of work

Before amendmentAfter amendment
5. Period of keeping and using personal information
The company will keep and use personal information while service is provided from the day when you apply for a membership. Personal information will be destroyed without delay in principle when the account is deleted or when the goal for collecting and using personal information is achieved. However, The Company keeps membership information for a certain period required by relevant laws if it is necessary to keep information according to regulations of relevant laws. In this case, the information is used for purpose of keeping only and the period is as shown below.
5. Period of keeping and using personal information

The company will keep and use personal information while service is provided from the day when you sign-up. Personal information will be destroyed without delay in principle after 30days(for the provision, in case of the account restoration request) when the account is withdrawn, deleted or when the goal for collecting and using personal information is completed. Also, regarding various destruction policies related to the connected opponent, the terms and conditions or the contents notified at the time of disconnection will be applied. However, records of illegal use are kept for one year (to prevent re-registration). The Company will keep and use user information for a period required by relevant laws if it is necessary to keep information according to regulations of relevant laws. As below.
5. Period of keeping and using personal information

○Records on withdrawal from a contract or an agreement: 5 years
○Records on payments and supply of goods: 5 years
○Records on customer complaints and dispute resolutions: 3 years
○Records on accesses: 3 months
○Records on electronic transactions: 5 years
○Records on identification: 6 months
○ID, password, name in English, security questions on password, answers on security questions, name, resident registration number, address, cell phone number, email address, I-Pin, personal identification information, sex, school, work, self-introduction, nickname, banking information, credit card, date and time of accesses, access locations, records on illegal access, PC specifications, service records, legal representatives: 30 days
○Records of illegal access: 1 year
5. Period of keeping and using personal information

○Records on withdrawal from a contract or an agreement: 5 years
○Records on payments and supply of goods: 5 years
○Records on customer complaints and dispute resolutions: 3 years
○Records on accesses: 3 months
○Records on electronic transactions: 5 years
○Records on identification: 6 months

7. Rights, obligations of users and legal representatives and its exercises

You or legal representative can personally view, change or withdraw to view, change personal information for self or child under the age of 14 by accessing ‘Setting> Change membership information’ from the application to make changes, click “Support Page (https://between-support.vcnc.co.kr/)> Manage Account> Delete Account” from the Between Homepage after accessing “Setting> Disconnect” to cancel subscription (withdraw consent). If the above site cannot be accessible then contact Privacy Officer by email and we will take necessary actions.
7.Rights, obligations of users and legal representatives and its exercises

○You or legal representative can personally view, change or withdraw to view, change personal information for self or child under the age of 14 by accessing ‘Setting> Change membership information’ from the application to make changes, click
“Support Page (https://help.between.us)> Account/Connect > Delete account contents” from the Between Homepage after accessing “Setting> Disconnect” to cancel subscription (withdraw consent). If the above site cannot be accessible then contact Privacy Officer by email and we will take necessary actions.
8.Installation/operation of devices to automatically collecting personal information and refusing this
1. What are Cookies?
8. Installation/operation of devices to automatically collecting personal information and refusing this
[Cookies]
○What are Cookies?
8. Installation/operation of devices to automatically collecting personal information and refusing this

(NEW)
8. Installation/operation of devices to automatically collecting personal information and refusing this

[Collection of advertisement identification when using mobile apps]
○Purpose of collecting advertisement identification when using mobile apps
The company can collect users' ADID/IDFA. ADID/IDFA is a mobile app user's advertisement identification value, which can be collected for measurement to provide a user's personalized service or advertisement in a better environment.
○Reject method
■Android: Setting> Google(Google Setting) > Ads > Opt out of Ads Personalisation
■iOS: Setting > Privacy > Advertising > Limit Ad Tracking

[
Gathering behavior information]
The company allows online customized advertising providers to collect advertising identifiers and behavior information as follows.
1) Advertising companies that collect and process behavioral information: Google, Facebook, Flurry, Kochava
2) Method of collecting behavioral information: Automatic collection and transmission when users run our app

9. Technical/administrative protection of personal information

(신설)
9. Technical/administrative protection of personal information

○ Minimizing the number of employees treating personal information and training
The company only authorizes a responsible employee to treat personal information and assigned with a separate password which is updated regularly, and emphasizes compliance of VCNC Privacy Policy through regular training.
10.Officer responsible for privacy and contact details

Officer responsible for Privacy
Name: Jae Wook Park
Dept: VCNC
Phone: 070-7728-8262
Position: CEO
Email: privacy@vcnc.co.kr

Officer responsible for personal information
Name: Young Mok Kim
Dept: VCNC
Phone: 070-7728-8262
Position: CTO
Email: privacy@vcnc.co.kr
10. Officer responsible for privacy and contact details

Officer responsible for Privacy

Name: JUNG HAENG LEE
Dept: VCNC
Phone: 070-7728-8262
Position: Director
Email: privacy@vcnc.co.kr