Privacy Policy

Picture Soft Inc. (hereinafter referred to as the “Company”) complies with the personal information protection regulations in the relevant laws and regulations that information and communication service providers must comply with, such as the Communications Secret Protection Act, the Telecommunications Business Act, and the Act on Promotion of Information and Communications Network Utilization and Information Protection, etc. We are doing our best to protect the rights and interests of users by establishing a privacy policy in accordance with laws and regulations.
This privacy policy applies to the services and applications provided by the company and contains the following contents.
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Items of personal information to be collected and methods of collection
definition of the term
​Items of personal information to be collected and methods of collection
Purpose of collection and use of personal information
Sharing and providing personal information
Consignment of handling of personal information
Period of retention and use of personal information
Personal information destruction procedure and method
Rights of users and their legal representatives and how to exercise them
Matters concerning the installation / operation and rejection of the automatic personal information collection device
Technical / Administrative Protection Measures for Personal Information
Contact information of the person in charge of personal information management and the person in charge
duty of notice
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1. Definition of terms
The definitions of terms used in this privacy policy are as follows.
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‘Users’ refer to customers (including members and non-members) who use all games and services provided by the company.​
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‘Service’ refers to all contents digitally created in connection with the service, such as all games and network services, applications, game money, and game items provided by the company.
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‘Device’ refers to electronic devices such as PCs, smartphones, and tablets that can be used by downloading or installing applications to use the service.
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‘Application’ refers to all programs downloaded or installed through the device described in paragraph ③ above in order to use the services provided by the company.
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'Open Market Store' means all e-commerce providers (providing in-game payment), such as wireless internet, application stores, and online sites (portals, game sites, or our website) of mobile carriers that provide users with the ability to install and pay for our applications. business operators).
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‘Platform operator’ refers to the operator and all related services that provide services in partnership with the company in announcing or using our applications.
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Information such as ID and e-mail address for identification provided by the platform operator as described in paragraph ⑥ above of the term 'user account' is not directly specified and disclosed by the platform operator, but a unique identification number (special number or letter). done) is provided and used.
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‘Paid content’ means all online content purchased through the App Store operator described in paragraph ⑤ above in order for the user to enjoy a specific effect or efficacy in using the service.
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‘Free content’ means all online content that can be acquired for free while using gifts or services between users who have not purchased through the paid content described in paragraph ⑧ above.
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Definitions of terms used in this privacy policy are as stipulated in the relevant laws, except for those specified in the above.
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What is not stipulated in the relevant laws and regulations is subject to general commercial practices.
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2. Items of personal information to be collected and methods of collection

Items of personal information to be collected
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The company collects the following personal information at the time of initial service subscription in order to provide various services. The following information may be generated and collected in the process of using the service, such as the user's unique identification number, game version, game use record, user name or nickname, and device unique number (device ID or IMEI) provided by the service of the user's platform provider. User status information, visit date and time, service use record, bad use record, profile picture and nickname, etc. If it is unavoidably necessary for payment in the process of using free or paid services, credit card information, telecommunication company information, purchase history and gift certificate number, and other payments Relevant information may be collected, and when a customer requests recovery or refund of paid content, e-mail address and purchase details are checked for smooth customer consultation, and real name and family relationship proof, etc. We may collect additional personal information.
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How to collect personal information
- The company collects personal information in the following ways.
- Automatically collected through platforms that are affiliated with the Company for service provision
- Collection through voluntary provision of users during service subscription or use
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3. Purpose of collection and use of personal information
Provision of game basic functions
- The company provides services such as inviting, gifting, recommending, and viewing rankings to the user's friends provided by the platform operator through the unique identification number of the user account. In addition, the device identification number (device ID or IMEI) may be collected and stored at the time of user registration and used to identify whether the user account is normal.
- Implementation of the contract for service provision and settlement of fees for service provision
Provision of free or paid content, delivery of goods through purchase or sending of invoices, identity verification, purchase and payment, fee collection
Member Management
- Identification according to membership service use, user identification related to game service provision, personal identification, prevention of illegal use by bad members (members whose contract has been canceled due to violation of Article 13 of the Company's Terms of Use, etc.) Confirmation of intention to join, limit the number of subscriptions and subscriptions, retention of records for identity verification and dispute settlement, complaint handling, complaint handling, and delivery of notices
- New service development and use in marketing/advertising
- Development of new services and provision of customized services, provision of services and advertisements according to statistical characteristics, verification of service validity, provision of event and advertisement information and participation opportunities, identification of access frequency, statistics on member service use
- New service development and use in marketing/advertising
- Development of new services and provision of customized services, provision of services and advertisements according to statistical characteristics, verification of service validity, provision of event and advertisement information and participation opportunities, identification of access frequency, statistics on member service use

4. Sharing and Provision of Personal Information
The company uses users' personal information within the scope notified in "Purpose of collection and use of personal information", and does not use the user's personal information outside the scope without the user's prior consent or, in principle, do not disclose the user's personal information to the outside. . However, personal information may be used and provided with caution in the following cases.
If users have consented to disclosure in advance: Before collecting information, providing information, or entrusting handling, the user will be informed of who the company's affiliates are and how and for how long they will be protected/managed and go through a process to ask for consent. If you do not consent, we will not collect additional information or share it with our affiliates.

5. Consignment of handling of personal information
In accordance with the provisions of laws and regulations, or if there is a request from an investigative agency according to the procedures and methods stipulated in the laws for the purpose of investigation, the company may entrust personal information as follows to improve the service, and in accordance with the relevant laws and regulations, personal information in the consignment contract It stipulates necessary matters so that it can be safely managed.
The purpose and contents of the company's consignment of personal information are as follows.
Purpose of use: customer consultation processing, prevention of illegal use, delivery of goods according to event progress, etc.
Provided items: All information for business processing for the purpose of use, such as unique identification number, e-mail address handled through the customer center page, purchase payment history, etc.
Retention period: Until the application is used or the consignment contract ends

6. Retention and use period of personal information
In principle, users' personal information is destroyed without delay when the purpose of collection and use of personal information is achieved. However, the following information is retained for the period specified for the following reasons.
Reasons for information retention according to company internal policy Illegal use records (Reason for retention: prevention of illegal use, retention period: 1 year)
Reasons for information retention according to related laws
If it is necessary to preserve it in accordance with the provisions of related laws, such as the Commercial Act, the Consumer Protection Act in Electronic Commerce, etc., the company keeps member information for a certain period of time as stipulated by the related laws In this case, the company uses the stored information only for the purpose of storage, and the retention period is as follows. Records on contract or subscription withdrawal, etc. (Reason for retention: Act on Consumer Protection in Electronic Commerce, etc., Retention period: 5 years)
Records on payment and supply of goods (Reason for retention: Act on Consumer Protection in Electronic Commerce, etc., Retention period: 5 years)
Records on consumer complaints or dispute handling (Reason for retention: Act on Consumer Protection in Electronic Commerce, etc., Retention period: 3 years)
Records related to identification (Reason for retention: Act on Promotion of Information and Communications Network Utilization and Information Protection, etc., Retention Period: 6 months)
Records of visits (Reason for retention: Communications Secret Protection Act, retention period: 3 months)

7. Personal information destruction procedure and method
In principle, users' personal information is destroyed without delay when the purpose of collection and use of personal information is achieved. The company's personal information destruction procedures and methods are as follows.
Destruction procedure Information entered by users for service subscription, etc. is transferred to a separate DB after the purpose is achieved, stored for a certain period of time in accordance with internal policies and other related laws and regulations (refer to retention and use period), and then destroyed.
This personal information will not be used for any other purpose other than being retained unless it is required by law.
Destruction method Personal information printed on paper is shredded with a shredder or destroyed through incineration.
Personal information stored in the form of electronic files is deleted using a technical method that cannot reproduce the record.

8. Rights of users and their legal representatives and how to exercise them
And legal representatives can at any time inquire or modify the registered personal information of themselves or children under the age of 14 through the App Store or the platform operator, and can request the termination of the service by logging out and deleting the application.
To view or modify personal information of users or children under the age of 14, click “Delete Account” through the App Store or platform operator to directly view, correct, or withdraw. However, if you want to check personal information that the company does not have, check the registration details of the app store or platform operator that the company provides game services and provide personal information to the information recorded in the company.
You must be able to verify your identity against the information.
If a user requests correction of errors in personal information, the personal information will not be used or provided until the correction is completed. In addition, if incorrect personal information has already been provided to a third party, we will notify the third party of the result of the correction without delay so that the correction can be made.
The company shall provide personal information that has been canceled or deleted at the request of the user or legal representative in “5. Period of retention and use of personal information” and processing it so that it cannot be viewed or used for any other purpose.

9. Matters concerning the installation/operation and rejection of automatic personal information collection devices
To create account information, a device identification number (device ID or UDID, IMEI) may be automatically collected when a user runs an application for game service. In addition, in order to provide basic functions such as friend registration and friend recommendation, a unique identification number and a unique identification number related to the friend list may be automatically collected from platform users.
If the user does not automatically collect this unique identification number or device identification number, the company cannot normally provide game services such as friend invitations and gifts, and therefore cannot use our game services normally.

10. Technical/Administrative Protection Measures for Personal Information
In handling users' personal information, the company is taking the following technical/administrative measures to ensure safety so that personal information is not lost, stolen, leaked, altered or damaged.
Countermeasures against hacking, etc.
-​ The company is doing its best to prevent personal information from being leaked or damaged by hacking or computer viruses. In preparation for damage to personal information, we frequently back up data, prevent leakage or damage of users' personal information or data, and ensure that personal information can be safely transmitted over the network through encrypted communication, etc. In addition, an intrusion prevention system is used to control unauthorized access from the outside, and we are trying to equip all possible technical devices to secure other systemic security.
Minimization and training of handling staff
-​ The company's personal information handling staff is limited to the person in charge, and compliance with the personal information handling policy is always emphasized through frequent training for the staff.
Exceptions
-​ The company is not responsible for any problems caused by personal information leakage due to reasons not intentional or gross negligence of the company, or due to the user's negligence.

11. Contact information of the person in charge of personal information management and the person in charge
You can report complaints related to personal information protection that occur while using the company's services to the person in charge of personal information management or the department in charge. The company will promptly and sufficiently respond to users' reports.
Name of person in charge and person in charge: Kim Grimm
Person in charge Affiliation and Position: Representative
E-MAIL: info@picture-soft.com
If you need to report or consult on other personal information infringement, please contact the following organizations.
Personal Information Infringement Report Center (WWW.118.OR.KR/ 118)
Information Protection Mark Certification Committee (WWW.EPRIVACY.OR.KR/ 02-580-0533~4)
Advanced Crime Investigation Division, Supreme Prosecutors' Office (HTTP://WWW.SPO.GO.KR/ 02-3480-2000)
National Police Agency Cyber ​​Terror Response Center (WWW.CTRC.GO.KR / 02-392-0330)
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12. Duty of Notice
If the Privacy Policy is added, deleted, or modified in accordance with laws, policies or changes in security technology, the reason and content of the change will be notified through the website. However, if important matters such as provision of personal information to a third party, change of purpose of collection and use, change of retention period, etc. are changed, the consent of the user will be obtained.