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Privacy Policy


GAGA MEMORY, GAGA THINGS, GAGA RING, G-CUBE Privacy Policy


Last Modified: Jan 2, 2017

Welcome to LINKgaga Co.,Ltd. ("LINKgaga" "we," "us" or "our"). Our Privacy Policy explains how we and some of the companies we work with collect, use, share and protect information in relation to our mobile services, and any other services we provide (collectively, the “Services” or “GAGA”).


By using our Service you understand and agree that we are providing a platform for you to post text, graphics, photos, videos or other materials (collectively referred to as "Content"), to the Service and to share Content publicly. This means that other users may search for, see, use, or share any of your Content that you make publicly available through the Service, consistent with the terms and conditions of this Privacy Policy and our Terms of Use.


1. Information We collect

1) Information you directly provide us


Your username, password, an email address we can contact you at, a phone number, and your name. We do not require that you provide us with your user profile (e.g., Real name, picture).

Your activity and the messages you send and receive through our Services. For example, we collect information such as the time, date, sender, recipient of a message, the number of messages you exchange with your friends, which friends you exchange messages with the most, and your interactions with messages (such as when you open a message or capture a screenshot).


2) Information you provide us when you use our services

Because GAGA is about sharing moments with people, there is some information we collect when you access our Services, which we use to facilitate the broad range of communications offered through our Services, to provide you cool features and functionality, and to enable all the other purposes described in this privacy policy. We explain all this below:


Usage Information. We collect information about your activity and the messages you send and receive through our Services. For example, we collect information such as the time, date, sender, recipient of a message, the number of messages you exchange with your friends, which friends you exchange messages with the most, and your interactions with messages (such as when you open a message or capture a screenshot). We may collect that same basic information when you use messagecash, along with the dollar amounts sent and received.


Content Information. Please check out the “Message Deletion” section in this privacy policy; it gives you more information about the message content we collect, how long we keep it, and how long third parties may have access to it.


Device Information. We collect information about your device, including the hardware model, operating system and version, unique device identifiers (including MAC address and IMEI), browser type and language, mobile device phone number, and mobile network information. We also collect certain device information that will help us diagnose problems in the (hopefully rare) event you experience any crash or other problem while using our Services. So, for example, if we detect a crash or other problematic event, we may collect the list of apps on your device and other information about your device’s performance at the time of the event for troubleshooting purposes.


Device Phonebook. Because GAGA is originated for communications with friends, we may—with your consent—collect information from your device’s phonebook. We do this so that we can connect you to your friends quickly and intuitively, enhance the Services with additional functionality, and for any other purpose described in this privacy policy. You can always revoke your consent to our ongoing ability to collect information from your device’s phonebook by changing the settings on your device if your device offers that option.


Camera and Photos. Many of our services require us to collect images and other information from your device’s camera and photos. We’ll access your camera and photos only after you give us your consent..


Location Information. When you use our services we may collect information about your location. With your consent, we may also collect information about your precise location using methods that include GPS, wireless networks, cell towers, Wi-Fi access points, and other sensors, such as gyroscopes, accelerometers, and compasses.


Information Collected by Cookies and Other Tracking Technologies. Like most online services, we use cookies, web beacons, and other technologies. Cookies are small data files stored on your hard drive or in device memory that store information about your use of the Services, which can, among other things, help us see which areas and features of the Services are popular and let us count visits. Web beacons are small pieces of software on a webpage or email that help us see how you interact with that webpage or email. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Keep in mind, though, that removing or rejecting cookies could affect the availability and functionality of our Services. To learn more about how third parties use such technologies on our Services, be sure to read the “Analytics and Advertising Services Provided by Others” section of our privacy policy.


3) Analytics information. We use third-party analytics tools to help us measure traffic and usage trends for the Service. These tools collect information sent by your device or our Service, including the web pages you visit, add-ons, and other information that assists us in improving the Service. We collect and use this analytics information with analytics information from other users so that it cannot reasonably be used to identify any particular individual User.


2. Information We Collect From Other Sources

If another user allows us to collect information from his or her device phonebook and you’re one of that user’s contacts we may combine the information we collect from that user’s phonebook with other information we have collected about you. We may also obtain information from other sources and combine that with the information we collect through GAGA.


3. How We Store Your Information


1) Your account information (e.g., email address, password, and phone number) will be encrypted as soon as you register for the Service, and we store and process such encrypted information in the United States or any other country in which we maintain facilities.

We will use commercially reasonable safeguards and take reasonable steps to keep the information encrypted at all times, so that the information will not be decrypted and accessible.


2) You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to the service at all times as we are not able to decrypt and access your encrypted account information.


4. How We Use Information

We provide you with an amazing set of Services that we improve with the information we collect. But we do a lot more as well, such as:


Provide and deliver the products, services, and functionality that you request, process transactions, and send you related information;


Communicate with you. That means just what it says; we may send you marketing communications on behalf of us or other companies; respond to your comments and questions; provide customer service; and send you technical notices, security alerts, and other informational messages;


Monitor and analyze trends and usage;


Develop, improve, and refine products, services, and functionality;


Personalize the Services by providing advertisements, content, or features that match user profiles or interests. For instance, when you set up an account we may pre-populate certain account information based on the information we collect about you from other users;

Verify your identity and prevent fraud or other unauthorized or illegal activity; and

Carry out any other purpose for which the information was collected.


5. How We Share Information

Here’s the type of information we may share about you with others and how we do so:


When you send a message, your recipients will see your name and, of course, whatever your message says or shows (whether that’s a photo, video, text, or transaction). When you view content that another GAGA user has sent you, we will let the sender know that you saw it, and if we detect that you captured a screenshot of the message, we will try to let the sender know that. But you’re always able to tell us whether you’d like to receive messages only from users you have added to your friends list or whether you’d prefer to receive messages from all GAGA users. We let you do that as well through various settings.

When you let us access your device phonebook, we may share information about you with other users who have your phone number in their device phonebook. For instance, when you use Find Friends, we may share your username and name with other users who use Find Friends and have your phone number in their device phonebook. In these cases, we will not display your phone number to these users, but we will share the fact that your username and name are associated with your phone number.


When other users view your profile, they will be able to view profile information, including your username and name.


We may share information about you with service providers who perform services on our behalf.


With respect to jointly offered Services or functionality or services offered separately by other companies through our Services, we may share information about you with business partners to provide the Services and functionality you request and to communicate with you about those Services;


We may share information about you in response to legal process or a request for information if we believe disclosure is consistent with, or required by, any applicable law, rule, or regulation; to investigate or remedy potential violations of our user agreements or policies, or to protect the rights, property, and safety of us, our users, or others; or in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.


We may share information about you with your consent or at your direction, or as otherwise provided in this privacy policy.


We may also share aggregated or de-identified information, which cannot reasonably be used to identify you. Here’s just one example of how this could work: Because it’s not always clear whether a new friend request comes from someone you actually know, we may share whether you and the requestor have GAGA friends in common without disclosing the usernames of those common friends.

The Services may also contain third-party links or be a co-branded or third-party-branded Service that’s being provided jointly with or by another company. By going to those links or by using a co-branded or third-party-branded Service, you may be providing personal information directly to the third party, us, or both. You acknowledge and agree that we are not responsible for how those third parties collect or use your information. As always, we encourage you to review the privacy policies of every third-party website or service that you visit or use, including those third parties you interact with through our Services.


6. Message Deletion

Delet is our default. That means that most messages sent through our Services will be automatically deleted once they have been viewed or have expired. But -and this is important- you should understand that users who see your messages can always save them, either by taking a screenshot or by using some other image-capture technology (whether that be software or even something as old-fashioned as a camera to take a photo of your device’s screen). If we’re able to detect that a recipient took a screenshot of a message you sent, we’ll try to notify you. But the same common sense that applies to the Internet at large applies to GAGA as well: Don’t send messages that you wouldn’t want someone to save or share.


In most cases, once we detect that all recipients have viewed a message, we automatically delete it from our servers. And again in most cases, the Services are programmed to delete the message from the recipients’ device as well. There is, however, an exception to this general rule:

Infinity timer: Senders can choose an infinity timer option to prevent deleting their messages from recipient’s device.


A few final words on deletion: We can’t guarantee that messages will be deleted within a specific timeframe. And even after we’ve deleted message data from our servers, that same data may remain in backup for a limited period of time. We also sometimes receive requests from law enforcement requiring us by law to suspend our ordinary server-deletion practices for specific information. Finally, of course, as with any digital information, there may be ways to access messages while still in temporary storage on recipients’ devices or, forensically, even after they are deleted.


7. Children’s Privacy

LINKgaga CO.,Ltd. respect the privacy of children under the terms of COPPA. We do not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to register for the Service. The Service and its content are not directed at children under the age of 13. In the event that we learn that we have collected personal information from a child under age 13 without parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us via helpdesk@linkgaga.com.


8. Change to Our Privacy


LINKgaga CO.,Ltd. may modify or update this Privacy Policy from time to time, so please review it periodically. We may provide you additional forms of notice of modifications or updates as appropriate under the circumstances. Your continued use of LINKgaga or the Service after any modification to this Privacy Policy will constitute your acceptance of such modification.








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** Provided to assist with the management of online shopping malls, this sample template may require amendments depending on the type of business. Before applying the following content to your shopping mall, check the management details of your mall and use and apply with discretion. **

_____________Corporation (herein after referred to as “the Company”) regards the privacy of users as highly important and complies with all regulations concerning the “Act on Protection of Information and Promotion of Utilization of Information and Communications Network.”
By stating its privacy policy as shown below, the Company hereby informs users of the purpose and use of personal information provided by the user to the Company, and the measures taken for the protection of their personal information.

■ Personal information collected and the means of collection
A. Information we collect
• The Company collects the following data for the purpose of membership sign-ups, consultations, and service applications.
o When signing up for membership: Name, birthday, gender, ID, password, home phone number, mobile number, e-mail, legal representative information for subscribers under the age of 14.
o When applying for services: Address, payment information
• Information collected through use of online services or the processing process: use record, access log, cookies, connecting IP information, payment record, unruly use, and others.

B. Means of collecting personal information
• Personal information is collected through the website, letter, message boards, e-mail, event entries, delivery request forms, phone, fax, and generated data collection tool.

■ Purpose of collection and use of personal information
The Company collects personal information for the following purposes and use.
• Provision of services obligated by fulfillment of contract and the payment that follows
Supply content, purchase and payment, delivery of goods, billing statements and others, user verifications for financial transactions and financial services.
• Member management
Identify user to access members-only services, verify user, prevent unauthorized use, check membership subscription, validate age, confirm consent/agreement from legal representative for users under the age of 14, handle complaints and civil affairs, and deliver notices.
• Marketing and promotional use
Delivery of events and unsolicited advertisements; gain a statistical understanding of the members’ frequency of access to and use of site.

■ Period of possession and utilization of personal information
As a general rule, once the personal data has fulfilled the purposes for which they were collected, they are to be immediately discarded. Except for the following that will be retained for certain periods for reasons noted below.

A. Information held according to the Company’s internal policies
Even when a member has canceled his/her membership, the member’s personal information may be retained for 00 years from the date of cancelation in order to resolve future disputes, to cooperate with the requests of law enforcement agencies, and to prevent the recurrence of fraudulent uses by unruly members.

B. Grounds for holding personal information according to applicable statutes
If retention of personal information is deemed necessary to operate in accordance to the provisions of relevant laws and regulations, including the Act on Consumer Protection in Electronic Commerce, then they will be held in possession by the Company for a certain period of time set by the relevant laws as noted below.
• Records related to contracts or withdrawal of subscription:
o Purpose of possession: Act on Consumer Protection in Electronic Commerce
o Possession period: 5 years
• Records related to payment and supply of goods
o Purpose of possession: Act on Consumer Protection in Electronic Commerce
o Possession period: 5 years
• Records related to consumer complaints or dispute settlement
o Purpose of possession: Act on Consumer Protection in Electronic Commerce
o Possession period: 3 years
• Records of log
o Purpose of possession: Protection of Communications Secrets Act
o Possession period: 3 months

■ Procedures and methods of discarding personal information
As a general rule, once the personal data has fulfilled the purposes for which they were collected, they are immediately discarded. The procedure and method to discard is detailed below.
• Discarding procedure
Following the cause for information protection according to the internal policies or related statutes, once the personal data has fulfilled the purposes they will be transferred to a separate database(DB) (or filed separately in a folder if in paper form), then it will be discarded after a certain period of time. Personal information that is transferred to a separate DB will not be used for any other purposes except in the case of the law. 
• Discarding method
Use technical method to stop reproduction of personal information saved in electronic form.
■ Disclosing personal information
As a general rule, the Company shall not disclose user’s personal information to any external party except for the cases below. 
• Prior consent from user
• Following the legislation rule or when law enforcement agencies require such information for investigative purposes during the process as prescribed by the law.

■ Consignment of collected personal information
For the provision of services, the Company consigns collected personal information to specialized companies detailed below.
• Consignee: [Name of delivery company]
• Details of consignment: [Delivery company’s consignment details]

• Consignee: [Name of payment gateway provider]
• Details of consignment: [Payment gateway provider’s consignment details]
 
■ The rights of users and legal representatives and methods of exercising those rights
• The user may view or edit his/her personal information and request to terminate membership at any time.
• To view or edit a user’s personal information, click on ‘Edit Personal Information’ (or ‘Edit Member Information’) and to cancel subscription (terminate membership) click on ‘Terminate Membership.’ Upon clicking, you’ll be directed to an identification process before you can directly access, correct, or cancel membership.
• User may contact the chief privacy officer by letter, telephone or email, and necessary actions will be taken.
• Should a user request corrections on errors of personal information, the Company shall not use or provide any personal information until a correction is made. In addition, if the wrong personal information has already been provided to a third party, the Company shall immediately notify them so that a proper correction can be made.
• If personal information is canceled or deleted upon request of user, the Company will comply with the terms specified under “Period of possession and utilization of personal information,” and prohibit disclosure or use for any other purposes.

■ Install, manage and deny operation of device for automatic collection of personal information
The Company uses ‘cookies’ that frequently save and retrieve your information. A cookie is a very small text file that the server, used to operate the Company’s website, sends to your browser. The file is saved in the hard disk of your computer.
The Company uses cookies for the following purposes:
• Use and purpose of cookies
o To analyze the frequencies of a member and non-member’s visit, understand user’s preferences and interests and track user’s footprints, and carry out target marketing and provide customized service by checking level of participation in various events and number of visits.
o You have the right of choice in regards to the installation of cookies. Accordingly, you may allow all cookies by modifying your cookie settings, go through a confirmation process whenever a cookie is saved, or refuse to have all cookies saved.
• Settings to reject establishment of cookies
o To reject establishment of cookies, select options on your web browser and change your settings to allow all cookies, go through a verification process before saving cookies, or reject to save all cookies.
o Example (For Internet Explorer)
- Go to ‘Tools’ located on the top of Web Browser > Internet Options > Privacy
o However, there may be certain difficulties in using the services if you reject the installment of cookies.

■ Civil services with respect to personal information
To protect your personal information and deal with complaints related to personal information, the Company has appointed the following department and chief privacy officer.
• Principal Privacy Officer
Name:
Department:
Phone Number:
E-mail:

• Chief Privacy Officer
Name:
Department:
Phone Number:
E-mail:

• You may report all complaints related to privacy protection, in using the Company’s service, to the chief privacy officer or the department in charge.
• The Company shall provide prompt and sufficient answers to your report.
• For further consultation or report on other privacy infringements, contact the following the following agencies.
o Privacy Rights Violation Complaint Center (privacy.kisa.or.kr / 118)
o Cybercrime Investigation Department, Supreme Prosecutor’s Office (www.spo.go.kr / 02-3480-2000)
o Cyber Bureau, National Police Agency (www.ctrc.go.kr/ 182)

■ Duty to notify
The Company shall notify users of any changes to this privacy policy through the website (or through individual notifications). 
• This privacy policy will be enforced starting 0000Y, 00M 00D.