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PRIVACY POLICY

1. Purpose
NXD Corp. (hereinafter referred to as the "Company") establishes the following Privacy Policy (hereinafter referred to as the "Policy") to protect the information (hereinafter referred to as "Personal Information") of individuals (hereinafter referred to as "Users" or "Individuals") who use the ReelChat service (hereinafter referred to as the "Company Service") provided by the Company, to comply with relevant laws such as the Personal Information Protection Act, the Act on Promotion of Information and Communications Network Utilization and Information Protection (hereinafter referred to as the "Information and Communications Network Act"), and to promptly and efficiently handle complaints related to the protection of Users' personal information.
2. Principles of Personal Information Processing
In accordance with relevant laws on personal information and this Policy, the Company may collect Users' personal information, and the collected personal information may be provided to third parties only with the individual's consent. However, in cases where it is legally enforced by legal provisions, the Company may provide the collected User's personal information to third parties without the individual's prior consent.
3. Disclosure of the Policy
1.
The Company discloses this Policy through the Company's homepage first screen or a screen connected to the first screen so that Users can easily check this Policy at any time.
2.
When disclosing this Policy in accordance with Paragraph 1, the Company uses font size, color, etc., to make it easy for Users to check this Policy.
4. Changes to the Policy
1.
This Policy may be revised in accordance with changes in laws, guidelines, notifications related to personal information, or changes in government or Company service policies or contents.
2.
When revising this Policy according to Paragraph 1, the Company will announce it through one or more of the following methods:
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Announcement through the notice section on the first screen of the Company's internet homepage or through a separate window
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Notification to Users by document, facsimile, email, or similar methods
3.
The Company will announce the notice under Paragraph 2 at least 7 days prior to the effective date of the revision of this Policy. However, in case of significant changes to User rights, the notice will be announced at least 30 days in advance.
5. Information for Member Registration
The Company collects the following information for Users' membership registration for the Company Service:
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Required information: Nickname, date of birth, and mobile phone number
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Optional information: SNS ID when logging in through social media, email address used
6. Information for Company Service Provision
The Company collects the following information to provide the Company Service to Users:
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Required information: ID, email address, date of birth, and contact information
7. Information for Service Use and Verification of Improper Use
The Company collects the following information for statistics and analysis of Users' service use and verification and analysis of improper use. (Improper use refers to actions such as repeatedly withdrawing membership and rejoining, repeatedly purchasing and canceling products, improperly obtaining economic benefits such as discount coupons and event benefits provided by the Company, actions prohibited in the terms of service, identity theft, etc.)
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Required information: Service usage records, access location information, and device information
8. Methods of Personal Information Collection
The Company collects Users' personal information through the following methods:
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Users entering their personal information through services other than the homepage provided by the Company, such as applications
9. Use of Personal Information
The Company uses personal information in the following cases:
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When necessary for Company operations, such as delivering notices
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For service improvement for Users, such as responding to inquiries, handling complaints, etc.
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To provide the Company's services
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For restriction measures against members who violate laws and Company terms, prevention and sanctions against actions that interfere with the smooth operation of the service, including improper use
10. Delegation of Personal Information Processing
The Company delegates the processing of personal information as follows for smooth service provision and effective business processing:
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Personal information processing is delegated to Google Cloud for server infrastructure construction and provision until member withdrawal or the end of the delegation contract
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Personal information processing is delegated to Neptun Inc. for chat messaging services until member withdrawal or the end of the delegation contract
11. Retention and Use Period of Personal Information
The Company retains and uses Users' personal information for the period required to achieve the purpose of collecting and using personal information. Despite the above, in accordance with internal policies, the Company may keep records of service misuse for up to 1 year from the time of member withdrawal to prevent fraudulent registration and use.
12. Retention and Use Period of Personal Information According to Laws
The Company retains and uses personal information in accordance with relevant laws as follows:
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Information and retention periods in accordance with the Act on Consumer Protection in Electronic Commerce, etc.
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Records of contracts or subscription withdrawals: 5 years
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Records of payment and supply of goods: 5 years
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Records of consumer complaints or dispute resolution: 3 years
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Records of labeling and advertising: 6 months
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Information and retention periods in accordance with the Protection of Communications Secrets Act
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Website log records: 3 months
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Information and retention periods in accordance with the Electronic Financial Transactions Act
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Records of electronic financial transactions: 5 years
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Act on the Protection and Use of Location Information
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Records of personal location information: 6 months
13. Principles of Personal Information Destruction
In principle, the Company promptly destroys the information when personal information is no longer needed, such as when the purpose of processing the User's personal information is achieved or the retention and use period has elapsed.
14. Personal Information Destruction Procedure
Information entered by Users for member registration, etc., is moved to a separate DB (separate file cabinet in the case of paper) after the personal information processing purpose is achieved, stored for a certain period according to internal policies and other relevant laws on information protection (refer to retention and use period), and then destroyed.
The Company destroys personal information that has a destruction reason through an approval procedure by the personal information protection officer.
15. Personal Information Destruction Method
The Company deletes personal information stored in electronic file format using technical methods that cannot reproduce the records, and personal information printed on paper is destroyed by shredding or incineration.
16. Measures for Transmission of Commercial Information
The Company receives explicit prior consent from Users when transmitting commercial information for profit-making purposes using electronic transmission media. However, prior consent is not required in any of the following cases:
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When the Company directly collected contact information from the recipient through a transaction of goods, etc., and intends to transmit commercial information for profit-making purposes regarding goods of the same kind as those processed by the Company and traded with the recipient within 6 months after the transaction was completed
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When a telemarketing seller under the "Door-to-Door Sales Act" conducts telemarketing by verbally notifying the recipient of the source of personal information collection
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Despite the above, the Company does not transmit commercial information for profit-making purposes if the recipient expresses a refusal or withdraws prior consent, and notifies the result of processing the refusal and withdrawal of consent
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When the Company transmits commercial information for profit-making purposes using electronic transmission media between 9 PM and 8 AM the next day, separate prior consent is obtained from the recipient despite Paragraph 1
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When transmitting commercial information for profit-making purposes using electronic transmission media, the Company clearly indicates the following in the commercial information:
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Company name and contact information
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Indication of matters related to expressing refusal of reception or withdrawal of consent to reception
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When transmitting commercial information for profit-making purposes using electronic transmission media, the Company does not take any of the following measures:
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Measures to avoid or interfere with the recipient's refusal of reception or withdrawal of consent to reception
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Measures to automatically create the recipient's contact information, such as phone numbers or email addresses, by combining numbers, codes, or characters
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Measures to automatically register phone numbers or email addresses for the purpose of transmitting commercial information for profit-making purposes
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Various measures to hide the identity of the commercial information sender or the source of transmission
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Various measures to induce a response by deceiving the recipient for the purpose of transmitting commercial information for profit-making purposes
17. Protection of Children's Personal Information
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The Company allows membership registration only to Users aged 14 or older to protect the personal information of children under the age of 14.
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Despite Paragraph 1, if a User is a child under the age of 14, the Company receives consent for the collection, use, and provision of the child's personal information from the child's legal representative.
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In the case of Paragraph 2, the Company additionally collects the legal representative's name, date of birth, gender, duplicate registration confirmation information (ID), mobile phone number, etc.
18. Viewing Personal Information and Withdrawing Collection Consent
1.
Users and legal representatives can view or modify their registered personal information at any time and request withdrawal of personal information collection consent.
2.
To withdraw consent for the collection of registration information, etc., Users and legal representatives can contact the personal information protection officer or person in charge in writing, by phone, or by email, and the Company will take action without delay.
19. Changing Personal Information
1.
Users can request correction of errors in personal information from the Company through the method in the previous article.
2.
In the case of the preceding paragraph, the Company will not use or provide personal information until the correction of personal information is completed, and if incorrect personal information has already been provided to a third party, the Company will promptly notify the third party of the correction result so that the correction can be made.
20. Purpose and Processing of TrueDepth API
We use Apple’s TrueDepth API to capture your facial image for liveness checks (verifying that you are a real person) and user authentication.
The captured image is securely processed through an external analysis service and deleted immediately after analysis.
The original facial image is not stored on our servers and is not used for advertising, marketing, or any other purpose.
All data is processed based solely on your consent, with the highest priority given to the protection and security of personal data.
1.
We use Apple’s TrueDepth API to capture your facial image for liveness checks (verifying that you are a real person) and user authentication.
2.
The captured image is securely processed through an external analysis service and deleted immediately after analysis.
3.
The original facial image is not stored on our servers and is not used for advertising, marketing, or any other purpose.
4.
All data is processed based solely on your consent, with the highest priority given to the protection and security of personal data.
21. Users' Obligations
1.
Users must keep their personal information up to date, and Users themselves are responsible for problems arising from inaccurate information input.
2.
Membership registration using another person's personal information may result in loss of User qualification or punishment under relevant personal information protection laws.
3.
Users are responsible for maintaining the security of their email addresses, passwords, etc., and cannot transfer or lend them to third parties.
22. Designation of the Company's Personal Information Protection Officer
1.
The Company designates the following departments and personal information protection officers to protect Users' personal information and handle complaints related to personal information:
2.
Personal Information Protection Officer
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Name: Kihoon Shin
23. Remedies for Rights Infringement
1.
Information subjects can apply for dispute resolution or consultation with the Personal Information Dispute Mediation Committee, Korea Internet & Security Agency Personal Information Infringement Report Center, etc., to receive remedies for personal information infringement. For other reports and consultations on personal information infringement, please contact the following institutions:
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Personal Information Dispute Mediation Committee: (no area code) 1833-6972 (www.kopico.go.kr)
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Korea Internet & Security Agency Personal Information Infringement Report Center: (no area code) 118 (privacy.kisa.or.kr)
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Supreme Prosecutors' Office: (no area code) 1301 (www.spo.go.kr)
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National Police Agency: (no area code) 182 (ecrm.cyber.go.kr)
2.
The Company guarantees the information subject's right to self-determination of personal information and strives for consultation and remedies for personal information infringement. If reporting or consultation is needed, please contact the department in charge mentioned in Paragraph 1.
3.
Those who have had their rights or interests infringed due to dispositions or non-actions taken by the head of a public institution regarding requests under Article 35 (Viewing Personal Information), Article 36 (Correction and Deletion of Personal Information), and Article 37 (Suspension of Processing Personal Information, etc.) of the Personal Information Protection Act may request administrative appeals according to the Administrative Appeals Act.
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Central Administrative Appeals Commission: (no area code) 110 (www.simpan.go.kr)
Supplementary Provisions
This Policy will be effective from July 22, 2024.
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