Privacy Policy
Privacy Policy
[makeUstar Inc.] (the “Company”), the operator of the “[makeUstar]” service (the “Service”), has enacted this privacy policy (this “Privacy Policy”) in order to protect the users’ (including members and non-members) personal information and to comply with applicable law. Moreover, this Privacy Policy provides the users with detailed information on the purposes and methods of collecting their personal information and the measures that are taken to protect their personal information.
1. Items of Personal Information to be Collected and the Purpose of the Collection/Use
The Company collects and uses the user’s personal information only to the extent necessary to provide the Service.
1) Method of Collection
· Information collected through the user’s subscription to the Service and the user’s use of the Service
· Generated information collected through log-analysis program
· Information collected in the course of responding to customer support
2) Purpose and Items of Information Collected, and Retention Period
1. Consent to the collection and use of personal information for the use of the Service
· E-mail address, name, nick name, ID, password, credit card information, bank account information, phone number.
2. Information generated and collected during the use of the Service or the processing of business operations
The following information may be generated and collected to provide customized services during the use of the Service or processing of the business operations:
·
Frequency and times of use of the Service, and usage logs, time of access, use records, such as records of illegal or unauthorized use
· Connection logs, connection IP addresses, cookies
· Device information collected during the use of the PC web and mobile web (OS, screen size, device ID, model information
· Usage logs, etc.
1. Information collected by automatic collection devices during the use of the mobile service
The following information may be generated and collected by automatic collection devices during the use of the mobile services
·
Device model and device identification number (device ID)
· OS (Android / iOS) and version information
· Push Token and other token information
· Device connection log
· Session ID
· IP, country of access
· MAC Address
· Non identifiable behavioral information (advertisement identifiers)
※ However, the device information set forth above is in a form which does not allow any person to be identified. Moreover, the Company shall not use such information to identify any person.
2. Period of Retention and Use and the Destruction of Personal Information
1) Period of retention and use
The Company retains and uses the user’s personal information during the time it provides the Service to the user (the “Use Period”) or during the period of dispute resolution (the “Retention Period”).
a. Use Period: Date of subscription – Date of withdrawal
b. Retention Period:
30 days from the termination date of the Terms of Use Agreement that has been terminated to prevent the recurrence of a user’s illegal or unauthorized use of the Service, or to prevent the disruption of the Service.
2) Period of retention and preservation of personal information
If it is necessary to preserve any personal information after the period for which the user has given their consent, in accordance with relevant laws, the Company may retain such personal information for a period of time stipulated in the relevant laws and regulations. In such case, the Company shall use the retained information only for the purpose of such retention.
3) Process and method of destruction of personal information
a. Process of Destruction: Information provided by users for service subscription or other Service-related purposes is transferred to a separate database after the purpose of the provision is achieved, stored in the database for a certain period according to the Company’s internal policies and other relevant laws and regulations, and then destroyed by the method set forth below. Personal information transferred to a separate database will not be used for any other purpose unless it is retained under applicable law.
b. Subject of Destruction: Any personal information for which the retention period and preservation period prescribed in applicable laws have expired.
c. Method of Destruction
● Personal information written or printed: Shredded or incinerated
● Personal information stored in the form of an electronic file, such as DB, etc.: Deleted using a technical method that makes it impossible to reproduce the record.
3. Installation, Operation, and Rejection of Automatic Personal Information Collection Devices
This cookie notice provides a description of cookies, the content and methods of collection, reasons for using them, and the right of data subjects to refuse the installation of cookies when visiting a website. The Service may change its cookie notice at any time. Changes will take effect when the amended cookie notice is posted on the Service’s webpage or on the Company’s website.
- What are cookies?
Cookies are data files sent to the user’s web browser (Internet Explorer, Chrome, Firefox, etc.).
- What do cookies do?
When a user visits the Service, the Company reads the content of the cookies stored in the user’s PC/mobile device and uses it to authenticate the user while the customer is logged on. In addition, cookies allow the Company to customize its services and advertising to each user by analyzing the information of the Service visited, access time and frequency, as well as other information generated or provided (entered) in the course of using the Service.
- How to reject cookies
a) For Chrome
Settings menu on the right side of the web browser > Privacy and Security > Cookies and other site data
b) For Internet Explorer
Tools menu at the top of the web browser > Internet Options > Privacy > Settings > Advanced
c) For Microsoft Edge
Settings menu at the right side of the web browser > Settings > Cookies and Site Permissions > Manage and delete cookies and site data
- Contact information for cookie related inquiries
Contact us by email ([미정]) for any inquiries or problems.
4. Provision and Sharing of Personal Information to Third Parties
The Company uses each user’s personal information only within the scope specified in the “Terms of Service” or this “Privacy Policy,” and does not use personal information beyond the specified scope or provide such information to third parties unless the Company obtains the prior consent of the user or such information is requested or permitted according to the regulations and procedures set by applicable laws and regulations
.
1. Outsourcing of Personal Information Processing
The Company outsources the processing of personal information, such as management of Terms of Use agreements, provision of after-sales services, and performance of any other incidental tasks, for greater user convenience and better management. All outsourced processors of personal information are strictly bound to the obligations to (i) comply with applicable laws, regulations, and guidelines; (ii) protect and keep confidential information to which they have access, (iii) not disclose the personal information to any third party, (iv) be liable for any accident regarding that personal information, and (v) return or destroy the personal information immediately upon expiration of the outsourcing period.
The Company requires outsourced processors to take all mandatory or necessary measures to protect the personal information transferred to them and remains liable for any damage users may suffer attributable to the willful misconduct or negligence of the outsourced processor(s).
5. User’s Rights Regarding their Personal Information and the Means to Exercise those Rights
Service users may visit the Service to access or modify their personal information at any time. Moreover, they may request the withdrawal of their consent to the use, collection, outsourcing, and provision of their personal information and request the termination of their subscription.
1) Users may withdraw their consent to the collection, use, or provision of their personal information.
2) Users may request access to and proof of personal information through the customer service and the Company’s representative email, etc.
3) If a user requests access to or proof of their personal information, the user must provide a copy of their proof of identity, such as their resident registration card, passport, driver's license, etc., to verify their identity.
4) If the user’s representative requests access to or proof of the user’s personal information, the Company shall verify the validity of the representative authority by requiring a certificate of delegation of the user that shows the representative’s relationship with the user, a certificate of seal impression of the user, and identification of the representative.
5) If the user requests a correction of their personal information, the Company shall cease using or providing the respective personal information until it is corrected completely. Moreover, in the event the Company has provided incorrect information to a third party, the Company shall notify the third party of any correctional measures taken without delay to allow any corrections that must be made.
6) However, the Company may restrict the access to and correction of personal information in the following exceptional cases:
a. If there is a risk of harm to life, body or property of the user or another person, or if there is a high possibility that the rights or other interests of another person will be violated
b. If there is a risk of significant disruption to the Service provider’s work
c. If the access or correction is in violation of applicable law
6. Protection of personal information of children under the age of 14
The Service does not accept any membership subscription of children under the age of 16 who require their legal representative to consent to the collection and use of their personal information. Entering false birth dates to subscribe to the Service constitutes a violation of the Company’s Terms of Service for which the Company shall not be liable under any circumstances. Moreover, if a child under the aforementioned age has created an account, the Company requests that the child’s legal representative contact the Company’s customer service and request the deletion or temporary suspension of the account. Users may cancel any account deletion requests within 30 days by contacting customer service.
7. User complaints and customer services
The Company values your opinion very much. Accordingly, please contact Service Manager under the contact information set forth below if you have any questions, and we will respond as soon as possible with an accurate answer.
1)
Data Protection Officer
· Name:
· Affiliation:
· Contact/Email:
2)
Data Protection Personnel
· Name:
· Affiliation:
· Contact/Email:
8. Technical and managerial protection of personal information
The Company has implemented the following technical and managerial measures to protect users’ personal information from loss, theft, disclosure, modification, or damage.
1) Technical Measures
a. Personal information is protected by a password, and important data is protected through separate security functions, such as encryption of files and transmitted data or use of file lock functions.
b. Antivirus software is used to prevent damage from computer viruses. Antivirus software is updated periodically, and in the event of a sudden virus outbreak, the vaccine for the virus shall be applied as soon as it is released to prevent the infringement of personal information.
c. SSL, a security protocol, has been adopted to help ensure the safe transmission of personal information through the network.
d. In order to prevent unauthorized disclosure of users’ personal information by hacking or other unauthorized access, the system is maintained in an area where external access is restricted, and intrusion-blocking devices are used.
2) Managerial Measures
a. The Company has procedures in place needed for appropriate management of and access to users’ personal information. Company officers and employees are required to understand and comply with these procedures and compliance is monitored regularly.
b. The Company limits the number of persons who can process users’ personal information to a minimum, and controls their access rights, and educate such personnel to comply with applicable laws and policies. Persons who process users’ personal information means the following:
● Persons who deal directly or indirectly with users as they handle business
● The Data Protection Officer, Data Protection Personnel, and others persons engaged in personal information management and protection duties
● Others whose access to user’s personal information is necessary for their work duties
c. The Company requires new employees to sign an information protection pledge, reminds all of its employees from time to time of their duty to protect personal information, and has in place internal procedures to audit their compliance with such duties to prevent the unauthorized disclosure of information by its employees (including, personal information).
d. The transfer of duties for personal information managers takes place under strict security, and the Company prescribes the scope of liability of each personnel regarding any personal information incidents for both current and former employees.
9. Customer complaint services
Users may report any complaints regarding the protection of their personal information that arises from the use of the Company’s services to customer service or the System/Privacy Manager. The Company shall respond to our inquires quickly and efficiently.
10. Notice Obligations
If there are any changes, additions, or deletions to the content of this Privacy Policy due to changes in the applicable privacy laws, policies and security technologies, etc., the Company shall notify the users of the amendment by posting an announcement on the Notice Board prior to the amendment of the Privacy Policy
Current Version of the Privacy Policy: 1.1
- Date of Notice: [DATE]
- Enforcement Date: [DATE]
※ Additional Notice for California Consumers
1. Notice on the Collection and Use of Personal Information
1) Prior to the effective date of this Privacy Policy, the Company may have collected the following personal information about the users:
Information provided by the user directly
- Name, email address, country, town
- Personal information listed in the California Customer Records statute (Cal. Civ. Code §1798.80): Name, address, telephone number, credit card number, debit card number, or any other financial information. (Some personal information included in this category may overlap with other categories.)
- Protected Class Information under California and federal law: Age, national origin, citizenship, gender
- Commercial information: products or services purchased, obtained, or considered, or other purchase or consumption histories, and information of the user’s purchase consumption tendencies
Information the Company Collects Automatically
- Internet or other similar network activity: Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement, Internet Protocol address, or unique personal or online identifiers
- Inferences drawn from other personal information: refers to the profile that reflects a user's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
- We may also receive the categories of information described above from other sources, including from internet service providers and data analytics service providers.
2) The purpose of the collection of the above personal information is as follows:
- Subscription to membership and use of the product purchasing services
- Delivery of notices regarding the Service
- Prevention of improper use by delinquent members/unauthorized use of services
- Responding to inquiries/complaints related to services
- Statistical analysis and research for service improvement and optimization development
- Purchase/delivery of products
- Participation in events
- Delivery of notices related to user verification and events participations, and the processing of related complaints
- Award and delivery of gifts/prizes following an event, delivery of related notices and processing of related complaints
- Notices related to various events
- Customized advertisements and other incidental marketing activities
2. Disclosure of User’s Personal Information
1) Prior to the effective date of this Privacy Policy, the Company may have disclosed certain personal information of the users to a third party listed below:
- Consignees that provide services on our behalf (e.g. shipping company, payment company)
- Advertising networks
- Business partners
- Internet service providers
- Data analytics service providers
- Professional services providers
- Social networks
The categories of personal information disclosed are identical to the scope listed in 1.1) above.
- The Company does not sell the personal information of users residing in California that was collected through the www.makeUstar.com Website.
3. Privacy Rights for California Consumers
Pursuant to the CCPA, users who are California residents may exercise various rights related to their personal information that has been collected by the Company (makeUstar Inc.). Users will not be discriminated for exercising such rights when using the Site.
1) Right to Access
Users who are California residents may request access to their personal information collected via Website related to the matters described below. However, the Company may deny such request if permitted under the CCPA.
(i) Categories of personal information the Company has collected about the user over the past 12 months and categories of sources from which the personal information was collected
(ii) Business or commercial purpose(s) for which the Company collected the user’s personal information
(iii) Categories of personal information that the Company disclosed for business purposes, and categories of the third parties with whom the Company has shared the user’s personal information
(iv) Specific personal information collected by the Company
If a user wishes to exercise their rights to access, the user may request such access by clicking on the following link. [please insert link]. The Company will need to verify the user’s identity in order to fulfill such request. The Company will verify the user in accordance with applicable law. Moreover, users may request such access by mailing the following email address: [please insert email address].
2) Right to Delete
Users who are California residents may request deletion of their personal information. However, the Company may deny such deletion request if permitted under the CCPA. Upon the user’s request for deletion, the Company shall permanently delete all personal information of the users by withdrawing the user’s membership from the Service. Therefore, in order to reuse the www.makeUstar.com Website after deletion of personal information, the user must resubscribe to the Website. Please note that users will be prohibited from subscription for a period of 7days after withdrawal in order to prevent the improper use of the Company’s services.
If a user wishes to exercise their right to delete their personal information, the user may request such deletion by clicking on the following link. [please insert link]. The Company will need to verify the user’s identity in order to fulfill such request. The Company will verify the user in accordance with applicable law. Moreover, users may request such deletion by mailing the following email address: [please insert email address].
3) Opt-Out of Sale
The Company does not sell personal information of any users residing in California that was collected through the www.makeUstar.com Website. If the Company sells personal information in the future, the users will be notified in advance, and if the user resides in California, the user shall have the right to opt-out of (suspend) the sale of their personal information.
4) Shine the Light Request
The Company does not share personal information with third parties for the third party’s direct marketing purposes.
5) Eraser Law Request
If the user is a California resident under the age of 18 and are a registered user of the Website, then the user may request that the Company removes any submission the user publicly posted on or in the Website. To request removal of a submission, please email a detailed description of the submission to the customer service [please insert link]. The user may also be able to log into their account and delete their own submission. The Company reserves the right to ask the user to provide information that would enables the Company to confirm that the submission in question was created and posted by the specific user.
※ The user may appoint an authorized agent to exercise the user’s rights on their behalf. If a user wishes to exercise such rights through an agent, the user must submit proof that the user granted such authority to the agent in writing. The Company may also require the user to verify their identity in consistent with the verification procedures described above.
※ Additional Notice for European Consumers
The Company processes the user’s personal information in compliance with the European Union’s General Data Protection Regulation (GDPR) and applicable laws. The Company uses the user’s personal information for the following purposes:
● For user subscription and provision of the Service: The Company may use the user’s personal information in order to execute an agreement with the user and to fulfill its obligations under such agreement. The Company may also use the user’s identity, contact information, financial information, transactional information, marketing information, and communication data, etc. in the process of providing the Company’s Service to the user and for the operation of the Service, such as notifying users of the amendment to the Company’s Service and processing user’s requests, etc.
● To strengthen the security of the Company’s Service: The Company may use the user’s personal information to protect the legitimate rights of the users and the Company in relation to the strengthening of security and within the extent necessary to fulfill its contractual obligation under applicable law, use the personal information to verify the user’s account, investigate suspicious activities, and apply the Terms of Use Agreement.
● To improve the Service: The Company may analyze data, such as the user’s use records, in order to develop new businesses and use highly relevant contents and user experiences to improve the Service.
● To promote Service: The Company may use the user’s personal information to deliver promotional information to the user and to research the market. The user may withdraw their consent to receive marketing information by clicking “withdraw consent” or “unsubscribe” button that is included in all marketing information.
Pursuant to the GDPR and other applicable law, the user may request the transfer of their personal information to a different manager or request the Company to cease processing of their personal information. Moreover, the user reserves the right to file complaints with the competent data protection authority. The user may contact customer service for any inquiries regarding the foregoing, and the Company shall process such inquiries quickly in a lawful manner.
The Company’s Service is not for children. The Company does not collect the personal information of any children below the age of 16 that resides in the European Economic Area (EEA). If the personal information of children is collected unintentionally in relation to the provision of the Service, the Company shall immediately delete such information. Please contact customer service for any questions regarding the personal information of children below the age of 16.
In order to provide the Service to the users, the Company may transfer, store, and process personal information outside of the EEA, including in Korea. Moreover, personal information may be stored in the EEA area by being stored in the device that the user used to access the Service. If the Company transfers the user’s personal information outside of the EEA, the Company shall ensure that at least one of the safety measures listed below will be applied to ensure a similar level of protection as is ensured within the EEA.
● Ensure that the transfer of the personal information only takes place in countries that the European Commission (EC) has deemed to provide an appropriate level of protection.
● If the Company uses a particular service provider, execute an EC approved contract that ensures the same level of protection for personal information as is used in the EEA.
Please contact the Company for further information regarding the measures it takes to transfer personal information outside of the EEA.