Privacy Polity

Wonderful Platform Co., Ltd (hereinafter referred to as ‘Company’ or ‘Wonderful Platform’) shall comply with the Privacy Regulations specified on the Related Statue, including but not limited to the Protection of Communications Secrets Act, the Telecommunications Business Act, and the Laws related to the Promotion of the Utilization of Information and Communication Networks and Protection of Personal Information, that the provider of information and communication service, and is committed to protecting the rights and interests of users by establishing a privacy policy in accordance with Applicable Laws and Regulations.

1. Personal Information Items to be Collected

The ‘Company’ collects personal information items as below, when using the service in the initial stage, for the purpose of using the service, performing favorable customer consultation and providing various services.

1) User’s e-mail, password and name
2) Device identification number (ID of smartphone device, e-mail, and ID of AVADIN device)
3) User location data (the app collects location data that enables tracking of users in the background state and is used by the guardian to verify it)

The following information shall be generated and collected during the process of using the service.

1) User’s phone number

2. Method of Collecting Personal Information

The ‘Company’ shall collect personal information by the following methods

1) Information voluntarily provided by the users

3. Purpose of Collecting Personal Information

a. Providing Basic Functions of AVADIN(alias)

The ‘Company’ remotely controls AVADIN Devices purchased by users or provides services to run and update software of AVADIN. When verifying the actual use of users by sending the temporary authentication method to e-mail address entered by users, the ‘Company’ shall approve the use, and user shall use the e-mail address entered as one’s account. The serial number of the AVADIN Device purchased by the user other than the user’s phone number, shall be used for remotely controlling the AVADIN Device and updating and running the software.

b. Used for Development of New Services, Marketing and Advertisement

1) To develop new services and provide customized services
2) To provide services according to statistical features
3) To confirm validity of services
4) To collect statistics for the use of user’s services and to give participation opportunities, and identify access frequency

4. Period of Retention and Use of Personal Information

In principle, the personal information of users shall be destroyed without delay, provided that the purpose of collecting and using the personal information is accomplished. Provided, however, the following information shall be kept for the specified period for the following reasons

a. Reason for Retention of Information Under Internal Company Policy

1) Records of fraudulent use
2) Reason for retention : Prevention of fraudulent use
3) Period of retention : 5 years

b. Retention of Information Under Applicable Laws

In cases it is deemed necessary, under the Relevant Act and Subordinate Statute, including but not limited to Commercial Law and E-commerce, to retain the personal information, the ‘Company’ keeps the information of users for a certain period specified in the Relevant Act and Subordinate Statue. In this case, the ‘Company’ shall use the information only for the purpose of keeping it, and the retention period shall be as follows

1) Record of withdrawal of contract or subscription
   - Reason for retention : Act on Consumer Protection in E-commerce
   - Period of retention : 5 years
2) Record of payment and supply of goods
   - Reason for retention : Act on Consumer Protection in E-commerce
   - Period of retention : 5 years
3) Record of settling consumer complaints and disputes
   - Reason for retention : Act on Consumer Protection in E-commerce
   - Period of retention : 3 years
4) Record of personal identification
   - Reason for retention : Act on the Promotion of the Utilization of Information and Communication Networks and Protection of Personal Information
   - Period of retention : 6 months
5) Record of visits
   - Reason for retention : Protection of Communications Secrets Act
   - Period of retention : 3 months

5. Procedures and Method of Destroying Personal Information

In principle, the personal information of users shall be destroyed without delay, provided that the purpose of collecting and using the personal information is accomplished. The procedure and method of destroying personal information of the ‘Company’ are as follows.

a. Destroying Procedure

1) The information entered by users for registration, shall be transferred to a separate database after the purpose has been accomplished (separate document box in the case of paper), and shall be stored for a certain period pursuant to the internal company policies and reasons for protecting information under the Related Statue (Refer to Period of Retention and Use) and destroyed.
2) The personal information shall not be used for any other purposes other than the cases under the Law.

b. Destroying Method

1) Personal information printed on paper shall be crushed by crusher or incinerated.
2) Personal information stored in the form of an electronic file shall be deleted using a technical method that can not reproduce the record.

6. Matters Concerning the Installation / Operation and Refusal of Automatic Collection of Personal Information

For the purpose of generating account information, the ‘Company’ shall automatically collect the identification number (Serial number of AVADIN Device) of the device when the user takes a picture of the QR code using the AVADIN App.

7. Providing Personal Information to a Third Party

The ‘Company’ shall use the personal information of users within the scope specified in the Purpose of Collecting Personal Information in Paragraph 3, and shall not, without prior consent of users, use the personal information beyond the scope or not disclose the personal information to the public. Provide however that, in the case it is deemed necessary to provide or share the personal information with the Company’s affiliates for better service, the ‘Company’ shall seek for consent by specifying the items of personal information to be provided or shared, the name of affiliate, purpose and period to the user, and shall not provide nor share it with a third party.

In the following cases, the ‘Company’ may provide personal information to a third party without obtaining user’s consent.

1) If otherwise specified in other Laws
2) In cases where the information agent or legal representative is unable to express one’s intention or prior consent can not be obtained due to unknown address; in cases it is deemed necessary for the benefit of imminent life, body and property of the information agent or third parties.
3) In cases that personal information is required for the purpose of gathering statistics and for academic research; providing personal information that does not specify a particular individual.
4) If required for the settlement of charge as a result of providing information and communication services.

7.1 Transfering to Overseas

Personal information is entrusted to foreign companies, for the purpose of providing service and for convince of users.
- Name of company : QUICKBLOX Co., Ltd.
- Home Page : http://www.quickblox.com/

The information collected during the use of the service is transferred through the network at the time of using the service, stored in the cloud server, and kept until the purpose of collecting and using personal information is accomplished.

8. Technical and Administrative Measures to Protect Personal Information

For the purpose of preventing personal information from being lost, stolen, leaked, altered or damaged in handling personal information of users, the ‘Company’ shall take the following technical and administrative measures.

a. Measures Against Hacking

The ‘Company’ endeavors to prevent personal information from being leaked or damaged by hacking or computer viruses. The ‘Company’ is frequently backing up the data in preparation for the damage of personal information, uses the latest vaccine program to prevent personal information or data of user from being leaked or damaged, and securely transfers personal information over the network through encrypted communication. In addition, the ‘Company’ uses the firewall system to restrict unauthorized access from external sources and endeavors to have all possible technical devices to secure system security.

b. Minimizing and Training of Employees Handling Personal Information

Manager of the ‘Company’ is responsible for handling personal information and is given a separate password for this purpose, which is regularly updated; the ‘Company’ re-enforces the manager to comply with the Privacy Policy of ‘Wonderful Platform’ through regular trainings.

c. Operating Exclusive Organization for Protection of Personal Information

In addition, the ‘Company’ ensures that the manager complies with the Privacy Policy of ‘Wonderful Platform’ through the exclusive organization dealing with protection of personal information in the company, and strives to correct and rectify problems if any. Provided, however, the ‘Company’ shall not be held liable for any problems caused by leakage of personal information due to negligence of users or problems on the Internet.

9. User’s Rights and Execution Method

1) User may, at any time, view or modify one’s registered personal information, and request to cancel membership.
2) User may change one’s profile in the service to view and modify user’s personal information, and for cancellation of one’s membership (Withdrawal of consent), user may view, edit or delete one’s account by clicking ‘Delete Account.’
3) or may contact the chief privacy officer in writing, by phone or e-mail; the ‘Company’ shall take action immediately.
4) If the user requests correction of errors in personal information, the ‘’Company’ shall not use or provide the personal information until the errors are corrected. Furthermore, in the event incorrect personal information is already provided to a third party, the ‘Company’ shall notify the third party of corrected information.
5) The ‘Company’ shall handle the personal information that has been terminated or deleted upon the request of the user, as specified in the Period of Retention and Use in Paragraph 4, so that it can not be viewed or used for other purposes.

10. Withdrawal of Consent to Collection, Use and Provision of Personal Information

User may, at any time, withdraw one’s consent for the collection, use and provision of personal information, given at the time of joining membership. If user wishes to withdraw (cancellation of membership) one’s consent, user may contact the customer center or apply in the smartphone application.

11. Viewing and Correcting Personal Information

User may, at any time, view or edit one’s personal information registered with the Service. If user wishes to view or edit one’s personal information, user may contact the customer center of the ‘Company’, view the user’s profile information in the smartphone application, or contact the chief privacy officer in writing, by phone or e-mail, which shall be proceeded by the ‘Company’ without delay.

‘Wonderful Platform’ shall faithfully respond to user’s demands; in cases it is deemed necessary to to correct or delete the information due to errors are found in the personal information or elapsed retention period, the ‘Company’ shall correct or delete the personal information without delay.

12. Collection of Feedback and Handling Complaints

If you believe that the ‘Company’ does not comply with the Privacy Policy, please notify the chief privacy officer or the manager. The ‘Company’ shall review your feedback promptly and endeavor to correct the issues, if any, as soon as possible. ‘Wonderful Platform’ collects feedbacks of users regarding personal information of users and established all procedures and methods to deal with complaints.

In addition, if you need to report or consult about infringement of personal information, please contact the Personal Information Infringement Report Center of Korea Information Security Agency (KISA).

If you have suffered financial or mental damage by infringement of user’s personal information, you may apply for a relief to the Personal Information Dispute Resolution Committee.

- Personal Information Infringement Report Center of Korea Information Security Agency (KISA) : (No area code) 118
- Cyber Crime Investigation Division of Supreme (Public) Prosecutors' Office : 02-3480-3571
- Cyber Terror Response Center of the National Police Agency : 1566-0112

13. Other

The Privacy Policy of ‘Wonderful Platform’ shall not apply to the act of collecting personal information by the services, smartphone apps and websites affiliated with AVADIN.

14. Duty of Notification

If there are added, deleted or modified contents of the current Privacy Policy, user shall be notified on the service of ‘AVADIN’, at least seven (7) days prior to the enforcement date.

15. Contact Information of Chief privacy officer and Contact Person

You may report any complaints related to privacy policy arising from the use of the Service provided by the ‘Company’, to the chief privacy officer or department in charge. The ‘Company’ shall give prompt and sufficient response with respect to user’s complaints.

[Chief Privacy Officer]
- Name : Jang Yeong Ju
- Phone number : +82-2-2297-9384
- E-mail : jyj@1thefull.com

If you need to report or consult about privacy infringement, please contact the following organizations:

- Personal Information Infringement Report Center
   https://privacy.kisa.or.kr
   (No area code) 118
- Information Protection Marking Certification Committee
   http://www.eprivacy.or.kr/
   02-580-0533, 02-580-0534
- High-Tech and Financial Crimes Investigation Division of the Supreme (Public) Prosecutors' Office
   http://www.spo.go.kr/
   02-3480-2000
- National Police Agency Cyber Security Guard
   http://www.police.go.kr/www/security/cyber.jsp
   02-392-0330

16. Enforcement Date

- Date of notification : May 13, 2020
- Enforcement date : May 13, 2020

Other external service terms and Conditions

- Youtube Terms of Service Link : [Link]
- Youtube Privacy Policy Link : [Link]