EntreReality (hereinafter referred to as the “Company”) utilizes users’ personal information to provide some of its services, for the purpose of provision of the best possible services to users. In accordance with Article 30 of the 「Personal Information Protection Act」, in order to protect users’ personal information and handle grievances promptly and smoothly, the Company establishes and announces this Privacy Policy as follows.

Article 1 [Purpose of Processing of Personal Information]

The Company processes personal information for the following purpose and personal information processed by the Company will not be used for the purpose other than the purpose described as below. In the event that the purpose of use is changed, the Company will take necessary measures such as obtaining additional consent, etc. in accordance with Article 18 of the 「Personal Information Protection Act」.

(1) Signing up for membership and login and management

Personal information is processed for the purpose of confirmation of intention to sign up for membership, verification×certification of identity for provision of services, maintaining×management of member qualification, checking duplicate registration, management of faulty users, detection of abnormal users and restriction of their use, performance of agreements, handling disputes, prevention of wrongful use of services, confirmation of consent of legal representatives when processing personal information of children under the age of 14, and sending various information·notifications.

(2) Provision of services

Personal information is processed for the purpose of verification of identity, verification of age, provision of services, provision of content, provision of tailored services including advertisements, and payment·settlement of fees.

(3) Handling grievances

Personal information is processed for the purpose of verification of users’ identification, checking inquiries, contact·notification for investigation of fact, and notification of results.

(4) Partnership and proposal

Personal information is processed for the purpose of review details prepared by a user or businessperson when there is partnership or proposal, and of contact when necessary.

(5) Utilization for marketing and advertisement

Personal information is processed for the purpose of development of new services and provision of tailored services, provision of event or advertising information and provision of opportunities for participation, provision of services and displaying of advertisements according to demographic characteristics, checking validity of services, identification of frequency of access or statistics for use of services by members, etc.

Article 2 [Items of and retention period for personal information to be processed]

⓵ The Company processes·retains personal information within the period of retention and use of personal information as set forth in the statute or agreed by users at the time of collecting personal information.

⓶ Items of and retention period for personal information are as follows.

2. However, in the event of falling under any of following cases, until the end of such period

• Until the end of the period that restoration can be requested, after membership withdrawal (90 days from the date of membership withdrawal)
• Records regarding consumers’ complaints or dispute settlement: 3 years (Act on the Consumer Protection in Electronic Commerce, etc.) | | Provision of services | Name, mobile number, email address, bank account information (bank name, account holder’s name, account number), service use records, IP address, transaction history | 1. In principle: Until completion of provision of services and payment·settlement of fees

2. However, in the event of falling under any of following cases, until the end of such period

• Records regarding contracts or cancellation of an order: 5 years (Act on the Consumer Protection in Electronic Commerce, etc.)
• Records regarding payment for orders and supply of goods, etc.: 5 years (Act on the Consumer Protection in Electronic Commerce, etc.)
• Records regarding consumers’ complaints or dispute settlement: 3 years (Act on the Consumer Protection in Electronic Commerce, etc.)
• Records regarding collection, processing, use, etc. of credit information: 3 years (Credit Information Use And Protection Act)
• Records regarding indication/advertisement: 6 months (Act on the Consumer Protection in Electronic Commerce, etc.) | | Facial Avatar Synthesis | Photograph for Avatar Synthesis provided by user | 1. In principle: Until membership withdrawal | | Handling grievances | Name, mobile number, ID, email address, consultation history (There may be additional personal information to be collected depending on the type of an inquiry and content), payment information of a legal representative (name, date of birth) | 1. In principle: Until membership withdrawal

2. However, in the event of falling under any of following cases, until the end of such period

• Records regarding consumers’ complaints or dispute settlement: 3 years (Act on the Consumer Protection in Electronic Commerce, etc.) | | Items automatically created and collected in the course of use of services | IP address, cookies, MAC address, service use records, device information (unique device identifier, OS version, APP version, language and country, etc.) | Communication confirmation data in accordance with Article 41 of Enforcement Decree of Protection of Communications Secrets Act: 3 months (Protection of Communications Secrets Act) | | Partnership and proposal | Company(organization) name, name, email address, mobile number, consultation history | 1. In principle: Until 6months after completion of review of partnership and proposal

2. However, in the event of falling under any of following cases, until the end of such period

• Records regarding contracts or cancellation of an order: 5 years (Act on the Consumer Protection in Electronic Commerce, etc.) | | Utilization for marketing and advertisement | Service use records, payment records, mobile number, email address, identity verification information (name, date of birth, gender, mobile carrier name, mobile number, connecting information (CI), Duplicate registration verification information (DI), local/foreigner information), IP information, advertisement identifier including cookies | Until withdrawal of membership or consent |

Article 3 [Provision of personal information to a third party]

⓵ The Company processes users’ personal information solely to the extent that it is specified in Article 1 (Purpose of Processing of Personal Information) and provides a third party with users’ personal information only if it falls under Article 17 and Article 18 of 「Personal Information Protection Act」 including the case that users consent or special provisions are existed in other laws.

⓶ The Company will obtain additional consent from users in the event that it provides a third party with users’ personal information.

Article 4 [Outsourcing of processing of personal information]

⓵ For smooth operation of services, the Company outsources tasks of processing of personal information as follows.

⓶ In outsourcing of processing of personal information, outsourced tasks handled by overseas corporations are as follows.

(mailto:[email protected]) | Regions of AWS (USA, OO) | Transmission through networks whenever the services are used | Personal information collected·used in the course of using services | System operation for use of services | Until termination of an outsourcing contract or according to the retention period prescribed in this Privacy Policy | | Agora Lab, Inc (mailto:[email protected]) | USA | Transfer through networks whenever the services are used | Video information | Processing of video information | Destroy immediately after transmit video files |

⓷ The Company, in accordance with Article 26 of 「Personal Information Protection Act」, specifies matters regarding prevention of personal information processing for other purposes than the outsourced purpose, technical·managerial safeguards, restriction on sub-outsourcing, management·supervision for outsourcees, liabilities including compensation of damage in documents such as a contract, and supervises how the outsourcee processes such personal information safely.

⓸ In the event that there is any change in outsourced tasks or outsourcees, the Company will announce it through this Privacy Policy without delay.