Privacy Policy
Smart Study Games Co., Ltd. (hereinafter referred to as the “Company” or the “Smart Study Games”) complies with the personal information protection provisions under the relevant laws to be observed by information communication service providers, including the Communications Secret Protection Act, the Telecommunications Business Act, the Act Relating to Information Communications Network Use Promotion and Information Protection, etc., and does its best to protect the rights and interests of users by setting forth privacy policies pursuant to the relevant laws. 1. Items of Personal Information to be Collected and Collection Methods A. Items of Personal Information to be Collected Firstly, the Company collects the following information when users first subscribe to the membership in order to provide membership subscriptions, smooth customer consultation, and various services. Unique device numbers (device IDs or IMEI), local formats Secondly, in the process of using services, the following information may be automatically created and collected : Information on Users’ conditions, photos, cookies, visit dates and times, records of service uses, records of wrongful uses, Marketing inflow channel, Payment date and time, content name, payment unique number, payment method, payment card information, bank account, PayPal account, fingerprint information of the user device at the time of payment, Country of access, Clan information (only for some games), device language, installed software version, IP address, Facebook ID and profile. B. Personal Information Collection Methods The Company collects the personal information in the following ways : - Automatically collecting the personal information by implementing or using programs of the Smart Study Games - Collecting with the explicit consent of the user - Collecting the personal information by voluntary provisions of the personal information by users while users subscribe to or use the services C. Location information The company may collect geolocation data such as states and cities with your consent. In addition, some Smart Study Games services, which include advertising banners, can temporarily utilize location information without collecting and storing location information with hereactual location information (e.g., GPS signals sent from mobile devices) or sensor data from devices that can provide information on nearby Wi-Fi access points and base stations. D. EEA and UK Smart Study Games utilizes a consent flow that is registered with the IAB Europe Transparency & Consent Framework (TCF). TCF is a voluntary standard that facilitates compliance with the European ePrivacy Directive and the GDPR. Therefore, in Europe and the EEA, Smart Study Games use the Google Consent Management Platform (CMP). When Smart Study Games launch any games, users over the age of 16 in the EEA and The UK are presented with Google’s standard user consent options. There you can provide consent to targeted marketing and profiling, decline all options, or manage your privacy preferences by selecting specific data-sharing options. 2. Purpose of Collection and Use of Personal Information A. Performance of agreements on provisions of services, and payments of costs for provisions of services Provisions of content, provisions of specific customized services, delivery of goods, or sending invoices, verifications of IDs, purchases or payments of costs, collection of costs B. Control of members To verify identifications for uses of membership services or according to the restricted verification system, to identify individuals, to prevent wrongful uses of undesirable members or unauthorized uses, to verify intents for subscriptions, to limit subscriptions and subscription frequencies, to verify consent by a legal representative to collect the personal information of a child of not more than sixteen (16) years old, to verify the identification of a legal representative afterwards, to retain records for dispute resolutions, to handle civil complaints including handling grievances, to convey notifications C. Developing new services, Application thereof to marketing and advertisements To develop new services and provide customized services, to provide services and publish advertisements according to demographic features, to verify the validity of services, to provide information for events or advertisements and provide opportunities to participate, to figure out access frequencies or obtain statistics on the service uses by members D. Personalized Marketing Consent All users over the age of 16 are asked if they want to consent to targeted marketing and personalized advertising. (Users under the age of 16 are not subject to targeted marketing.) Smart Study Games are supported by ads. To make these ads more relevant, we would like to analyze and combine your data [advertising identifier, usage information, and consumption data] to learn more about the game and our users. If you consent, we may also share this data with our ad partners for the purposes of targeted advertising. A full list of our advertising partners can be found below. - Firebase : https://firebase.google.com/support/privacy?hl=en - Google AdMob : https://policies.google.com/privacy?hl=en - Adjust : https://www.adjust.com/terms/privacy-policy/ - Apple Search Ads : https://searchads.apple.com/privacy - TikTok Ads : https://ads.tiktok.com/i18n/official/policy/privacy?hl=en - MOLOCO : https://www.moloco.com/privacy-policy?hl=en - Google Ads : https://policies.google.com/privacy?hl=en Choosing not to consent, will not remove ads – instead you may see ads that may be less relevant to your interests. You can change your marketing preferences at any time in the settings of our Games. 3. Matters concerning the installation and operation of devices that collect personal information and the refusal thereof A. Cookies - A cookie is a small amount of information that a website server sends to a user's computer browser. Cookies identify the user's computer, but not the user personally. - Purpose of using cookies : It is intended to provide target marketing and personalized services by analyzing the frequency of access and visit time of members and non-members, identifying users' tastes and interests, tracking their trace, and identifying the degree of participation in various events and the number of visits. : Users have the option to install cookies. Therefore, users can allow all cookies by setting options in the web browser, go through confirmation every time they are saved, or refuse to save all cookies. : However, if you refuse to install cookies, some services may be difficult to use. - How to set up cookie creation : Tools menu at the top of Internet Explorer > Internet Options > Privacy > Settings : On the right side of Chrome, Settings menu > Display Advanced Settings at the bottom of the screen > Content Settings button for Privacy > Cookies B. Device identification unique number In order to generate account information, the company will automatically collect the device identification unique number (device ID or IMEI) when the user runs the smart study game service. If the user refuses to automatically collect the device identification unique number, the smart study game service may not be available. C. Advertising identifier (IDFA or GAID) We often feature advertising in our Services by showing third-party advertisements in our Services and by advertising our own Services via third parties. If you are over the age of 16 and provide consent, then Smart Study Games may disclose your personal information to advertising networks for the purpose of their direct marketing. We may send your advertising ID and IP address to ad networks to enable our partners to serve appropriate ads in accordance with GDPR Article 6(1)(f). "Advertising ID" means the Apple Identifier for Advertisers (“IDFA”) on Apple, and Google Advertising Identity (“GAID”). These are unique identifiers for mobile devices that Smart Study Games and our advertising network partners use for interest-based advertising (targeted). They are consistent across all apps and thus allow cross-app tracking. These identifiers are used by ad networks for a number of purposes, in addition to targeted advertisement, thus we encourage you to check the Privacy Policies of our partners. Ad Networks may use information about you, such as your advertising ID, to identify users who are likely to have an interest in our services and display advertising to them. They may also use this information to identify whether you are an existing user of our services and exclude you from further advertising of our services. You can find a list of Smart Study Games’s existing advertising network partners and other third-party service providers by looking at the list provided below. - Ironsource : https://www.is.com/privacy-policy/ - Unity : https://unity.com/en/legal/privacy-policy - Applovin : https://www.applovin.com/privacy/ - Google admob : https://policies.google.com/privacy?hl=en - Liftoff : https://liftoff.io/privacy-policy/ These advertising networks may be located in countries outside EU/EEA that have less restrictive data protection legislation. For such advertising networks in countries outside EU/EEA, the legal basis for the transfer is always in accordance with one of the lawful instruments set forth in data protection laws. You can opt out of all third-party targeted advertisements, for all apps, using the device-level opt-out settings on your device or in the settings screen of any of our games. We may allow third parties to provide analytics services in connection with our Services. These entities may use cookies, web beacons, and other tracking technologies to collect information about your use of our Services, including your IP address, MAC address, device identifiers, software and hardware information, browser information, time zone and usage information. This information may be used by Smart Study Games and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests and better understand your activity on our Services. Third-party ad serving and analytics technologies are integrated into our Services, so if you do not want to be subject to these technologies, do not use or access our Services. Our Services may also integrate third-party Application Program Interfaces (APIs) and/or SDK’s, which allow others to collect and process information about you, including but not limited to your geo-location information, to provide you with targeted advertisements, offers, and other content. You always can control the collection and use of your geo-location information. You may disable location-based services at any time by adjusting the settings of your mobile device. 4. Sharing and Provisions of Personal Information The Company uses personal information of users only within the scope as notified in the “2. Purpose of Collection and Use of Personal Information,” and shall not use or in principle disclose to a third party the personal information of users in excess of the scope without the prior consent of users : provided, however, that exceptions are made in the following cases: - In the event that users have given a prior consent to the disclosure ; or - In the event that the disclosure is required under the provisions of laws or requested by investigative agencies according to the procedures and methods prescribed under the laws for investigation purposes. 5. Delegation of Treatment of Personal Information A. The Company delegates personal information for improvements of services as follows, and provides the required matters to safely control personal information in entering into a delegation agreement under relevant laws. The Company’s personal information delegated agencies and the content of delegation are as follows : - Delegates : Smart Study Games’s delegated matters : establishing and operating systems to provide the services - Trustee: QRoad / www.qroad.net - Details of entrusted duties: Operation and customer consultation for the provision of game services - Trustee: xsolla / www.xsolla.com - Details of consignment work: Payment agency - Trustee: Thinking Data / www.thinkingdata.kr - Details of consignment work: Statistics and visualization of app usage data - Retention and Use Period for Personal Information : until the services are completed or members withdraw from their membership, or a delegation agreement is completed B. The services specify the obligations to comply with relevant laws relating to personal information protection, maintain secrets on personal information, prohibit personal information from being provided to a third party, assume responsibilities upon the occurrence of an accident, and return or destroy personal information after the delegation period or handling thereof is completed, and manage to ensure that the obligations are complied with. 6. Retention and Use Period for Personal Information In principle, once the purposes of collection and use of personal information have been fulfilled, the Company without delay destroys the personal information ; provided, however, that the Company retains the personal information during a specified period of time for the following reasons : A. Reasons for information retention under the Company’s internal policies - Records on wrongful uses Reason for retention : preventing wrongful uses Retention period : one (1) year B. Reasons for information retention under relevant laws In the event that it is necessary to preserve personal information under relevant laws including the Commercial Code, the Act Relating to Consumer Protection in Electronic Commercial Transactions, etc., the Company retains the information of members for a certain period of time prescribed under relevant laws. In this case, the Company uses the personal information it retains only for the purpose of preservation thereof, and the retention period are as follows: - Records on agreements or withdrawals of offers : Reason for retention : the Act Relating to Protection of Consumers in Electronic Commercial Transactions, etc. Retention period : five (5) years - Records on payments and supplies of goods, etc. : Reason for retention : the Act Relating to Protection of Consumers in Electronic Commercial Transactions, etc. Retention period : five (5) years - Records on complaints of consumers or dispute resolutions Reason for retention : the Act Relating to Protection of Consumers in Electronic Commercial Transactions, etc. Retention period : three (3) years - Records on verification of identification Reason for retention : the Act Relating to Promotion of Information Communications Network and Personal Information Protection Retention period : six (6) months - Records on visitations Reason for retention : the Communications Secret Protection Act Retention period : three (3) years Retention period : three (3) months
7. Destruction Procedures and Methods for Personal Information The Company in principle destroys the personal information of users without delay if the purposes of collection or use of personal information have been fulfilled. The Company’s destruction procedures and methods for personal information are as follows: A. Destruction Procedures - The information entered by users for membership subscription, etc. is to be moved to a separate database, after the purposes have been fulfilled (a separate document in the case of a sheet), and to be destroyed after the information has been saved for a certain period of time according to the information protection reasons under the internal policies or other relevant laws (see the retention and use period for reference). - The personal information is not used for purposes other than the purpose of being retained unless it is so required by laws. B. Destruction Methods - The personal information printed out in sheets is to be shredded by paper shredders or destroyed by way of incineration. - The personal information saved in an electronic file format is to be deleted with the use of technical methods in which records cannot be regenerated. 8. Rights to Personal Information of Users and Legal Representatives, and the Exercise Methods - Users or their legal representatives may at any time inquire or change their personal information or the personal information of children of not more than sixteen (16) years old, and may request terminations of subscriptions. - Users or their legal representatives may change changing the “My Profile” within the services in order to inquire or change their personal information or the personal information of children of not more than sixteen (16) years old, or may directly read, correct their personal information or withdraw from membership by clicking on the “Delete Account” within the services in order to terminate the subscriptions (withdraw their consents). - Or if users contact the personal information control manager in writing, by telephone or e-mail, the Company will take measures without delay. - Where a user has requested corrections of errors in the personal information, the Company does not use or provide the personal information until the corrections are completed. Also where the wrong personal information has been already provided to a third party, the Company will make the corrections by giving the third party the correction handling results without delay. - The Company handles the personal information terminated or deleted upon request of users or their legal representatives as specified in the “5. Retention and Use Period of Personal Information,” and take measures to ensure that the personal information is not read or used for any other purposes. 9. Technical and Managerial Protection Measures for Personal Information The Company takes the following technical and/or managerial protection measures to establish security in treating the personal information of users, in order to ensure that the personal information is not lost, stolen. Leaked, altered, or damaged. A. Measures in preparation of hacking or viruses The Company uses its best effort to prevent members’ personal information being disclosed or damaged by hackings, computer viruses, etc. The Company frequently backs up materials in preparation of damages of personal information and prevents personal information or materials of users from being leaked or harmed by using the latest vaccine programs, and enables personal information to be safely transmitted on the networks through encoded communications, etc. And the Company controls unauthorized access from the outside by using firewall systems, and makes efforts to have all possible technical equipment to obtain security systematically. B. Minimizing Treating Employees and Providing Education The Company allows only authorized persons to treat personal information and for this purpose grants and regularly renews separate passwords, and at all times stresses out their compliance with Smart Study Games’s privacy policies by frequently providing education to authorized persons. C. Operation of Exclusive Organization for Protection of Personal Information And the Company verifies performances of the privacy policies of Smart Study Games and compliance therewith by authorized persons through its internal organization for protection of personal information, etc., and if it a problem is found out, the Company makes efforts to immediately solve and correct the problem(s); provided, however, that the Company will not take any liabilities for problems that have occurred as personal information has been disclosed due to the members’ own carelessness or problems on the Internet. 10. Third-party links The Company’s website or services may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. The Company does not control these third-party websites and are not responsible for their privacy statements. When you leave our website or services, The Company encourages you to read the privacy notice of every website you visit. 11. Contact Information of Personal Information Control Manager and Authorized Manager You may report to the personal information control manager or the relevant department any complaints relating to all personal information protection incurred in using services of the Company. The Company will promptly give sufficient replies as to reports of users. Personal Information Control Manager Name: Dongjin Lee Affiliation: Smart Study Games Position: CEO Mail: support@smartstudygames.com Authorized Person for Personal Information Control Name: Dongjin Lee Affiliation: Smart Study Games Phone: 02-3486-6173 Mail: support@smartstudygames.com If you need reports or consultations related to personal information infringements, please ask questions to the following institutions: - Personal Information Infringement Reporting Center (www.kisa.or.kr/cyberhelper118) - Information Protection Mark Certification Committee (www.eprivacy.or.kr/ 02-580-0533~4) - Internet Crime Investigation Center of Supreme Prosecutors’ Office (http://www.spo.go.kr / 02-3480-2000) - Cyber Crime Investigative Service of National Police Agency (ecrm.police.go.kr) 12. Duty to Notify In the event that there is a change in the content of the current privacy policies, the Company will notify the change(s) through the popup screen for notification and follow the designated implementation date. Date of Notification : May 29, 2024 Date of Implementation : May 29, 2024