Privacy Policy

<HM Game> ('Trip9') has established and disclosed this Privacy Policy in accordance with Article 30 of the Personal Information Protection Act to protect the personal information of data subjects and to handle related complaints promptly and smoothly. ○ This Privacy Policy is effective from August 21, 2023.

1. (Purpose of Personal Information Processing)

<HM게임>('Trip9') processes personal information for the following purposes. The processed personal information will not be used for purposes other than the following, and if the purpose of use is changed, necessary measures, such as obtaining separate consent in accordance with Article 18 of the "Personal Information Protection Act," will be taken.

• App Membership Registration and Management Personal information is processed for the purposes of confirming the intention of membership registration, maintaining and managing membership qualifications, preventing fraudulent use of services, various notifications and announcements, and handling complaints.

• Handling of Public Complaints and Affairs Personal information is processed for the purposes of confirming the identity of complainants, verifying the details of complaints, contacting and notifying for factual investigations, and providing results of processing.

• Provision of Goods or Services Personal information is processed for the purpose of providing services and content.

• Utilization for Marketing and Advertising Personal information is processed for the purposes of developing new services (products), providing customized services, offering event and advertising-related information and participation opportunities, providing services and advertising based on demographic characteristics, verifying the effectiveness of services, assessing frequency of access, and generating statistics related to members' service usage.

2. (Processing and Retention Period of Personal Information)

① <HM게임> processes and retains personal information within the period of time required by law for personal information retention and use, or within the period of time consented to by the data subject upon collection of personal information.

② The processing and retention periods for each category of personal information are as follows:

• Utilization for Marketing and Advertising Personal information related to "Utilization for Marketing and Advertising" will be retained and used from the date of consent for collection and usage until <destruction of member information upon membership withdrawal> for the purpose of the aforementioned utilization. Retention Grounds: Smooth utilization of the app service Relevant Laws: Exceptional Cases: In the event of discovery of actions that seriously violate public morals or constitute significant criminal offenses, the user may be subject to forced withdrawal processing or separate management.

3. (Items of Processed Personal Information)

① <HM게임> processes the following personal information items:

• Utilization for Marketing and Advertising Essential Items: Email, Nickname 

• Optional Items:

4. (Procedures and Methods of Personal Information Destruction)

① <HM게임> promptly destroys personal information when it becomes unnecessary due to the expiration of the retention period of personal information, achievement of the processing purpose, and other reasons.

② Even if the retention period agreed upon by the data subject has expired or the processing purpose has been achieved, if the personal information must continue to be retained under other laws, <HM게임> stores the relevant personal information in a separate database (DB) or keeps it in a different location.

• Legal Grounds:

• Personal Information Items Being Retained: Email, Nickname

③ The procedures and methods of personal information destruction are as follows:

• Destruction Procedure: <HM게임> selects personal information for destruction when the reasons for destruction arise and obtains approval from the personal information protection manager of <HM게임>.

• Destruction Method: Electronic files are destroyed using technically irreversible methods that prevent the restoration of records.

5. (Rights and Obligations of Data Subjects and Legal Representatives, and Methods of Exercising Rights)

① Data subjects have the right to request <HM게임> to exercise their rights, such as accessing, correcting, deleting, or suspending the processing of personal information.

② The exercise of rights under paragraph 1 may be done through written, electronic mail, facsimile (FAX), etc., in accordance with Article 41(1) of the "Personal Information Protection Act" Enforcement Decree. <HM게임> will take immediate actions to respond to these requests.

③ The rights under paragraph 1 can be exercised through a legal representative of the data subject or a delegate who has been given authority. In this case, a letter of authorization according to the format of Annex No. 11 of the "Guidelines on Personal Information Processing Methods (No. 2020-7)" must be submitted.

④ The right to access and request processing suspension may be restricted under Article 35(4) and Article 37(2) of the "Personal Information Protection Act."

⑤ Requests for correction and deletion of personal information cannot be made if the personal information is explicitly specified as a collection target under other laws.

⑥ When <HM게임> receives requests for access, correction, deletion, or processing suspension based on the data subject's rights, <HM게임> confirms whether the requester is the data subject or a legitimate representative.

6. (Measures for Ensuring Security of Personal Information)

<HM게임> takes the following measures to ensure the security of personal information:

• Establishment and Implementation of Internal Management Plans <HM게임> establishes and implements internal management plans to ensure the secure processing of personal information.

• Access Restrictions to Personal Information Access to databases systems handling personal information is controlled by granting, changing, and revoking access rights. Intrusion prevention systems are used to control unauthorized access from external sources.

• Retention of Access Records and Prevention of Tampering Access records of the personal information processing system are retained and managed for at least 1 year. However, for cases involving information subjects exceeding 50,000 or the processing of unique identification information or sensitive information, access records are retained and managed for at least 2 years. Security features are utilized to prevent tampering, theft, and loss of access records.

• Encryption of Personal Information User's personal information, including passwords, is stored and managed in encrypted form so that only the individual concerned can access it. Important data is further protected using separate security features such as encryption of files and transmitted data, or file locking.

7. (Installation, Operation, and Rejection of Automatic Collection Devices for Personal Information)

<HM게임> does not use 'cookies' to store and retrieve user's usage information.

8. (Collection, Use, Provision, and Rejection of Behavioral Information)

① <개인정보처리자> collects and uses behavioral information in the course of providing optimized customized services, benefits, and online tailored advertising to the data subject.

② <개인정보처리자> collects behavioral information in the following manner:

• Items of collected behavioral information

• Method of collecting behavioral information

• Purpose of collecting behavioral information

• Retention and use period and subsequent information processing method

For the Purpose of Online Tailored Advertising, When Third Parties (Online Advertising Providers, etc.) are Permitted to Collect and Process Behavioral Information:

③ <개인정보처리자> permits online tailored advertising providers to collect and process behavioral information in the following manner:

• Advertising providers collecting and processing behavioral information: Google Analytics, AdMob

• Method of collecting behavioral information: Automatically collected and transmitted when the user runs the app

• Items of collected and processed behavioral information: User's app visit history, search history, service usage history

• Retention and use period: Stored until user withdrawal or service termination

④ <개인정보처리자> only collects the minimum necessary behavioral information required for online tailored advertising. It does not collect sensitive behavioral information that may clearly infringe upon an individual's rights, interests, or privacy, such as beliefs, family and kinship relationships, education and medical history, or other social activity records.

⑤ <개인정보처리자> does not collect behavioral information for online tailored advertising purposes from children under 14 years old or services primarily used by children under 14 years old, nor does it provide tailored advertising to such children.

⑥ <개인정보처리자> collects and uses advertising identifiers for online tailored advertising purposes in mobile apps. Data subjects can block or allow tailored advertising in apps by changing mobile device settings.

⑦ Data subjects can block or allow online tailored advertising collectively using methods such as changing browser settings. However, changing cookie settings may affect the use of some services like automatic website login.

⑧ Data subjects can contact the following email for inquiries about behavioral information, exercising refusal rights, and reporting damages related to such information:

• Contact Email: greencharon@gmail.com

9. (Criteria for Additional Use and Provision) <HM게임> can use and provide personal information without the consent of the data subject in accordance with Article 15(3) and Article 17(4) of the Personal Information Protection Act and Article 14-2 of the Enforcement Decree of the Personal Information Protection Act. Accordingly, in order to use and provide personal information additionally without the consent of the data subject, <HM게임> has considered the following factors:

• Whether the purpose of additional use and provision is relevant to the original purpose of collection.

• Whether there is predictability regarding additional use and provision based on the circumstances of collecting personal information or processing practices.

• Whether the additional use and provision of personal information unduly infringes upon the interests of the data subject.

• Whether measures for security, such as pseudonymization or encryption, have been taken.

※ The criteria for considering additional use and provision shall be determined and disclosed autonomously by the business/entity.

10. (Processing of Pseudonymous Information) <HM게임> processes pseudonymous information for the following purposes:

• [You can fill in the specific purpose of processing pseudonymous information]

• [You can fill in the processing and retention period of pseudonymous information]

• [You can fill in the details of providing pseudonymous information to third parties (if applicable)]

• [You can fill in the details of outsourcing pseudonymous information processing (if applicable)]

• [You can fill in the items of personal information processed pseudonymously]

• [You can fill in the security measures for ensuring the safety of pseudonymous information pursuant to Article 28-4 of the Act]

11. (Personal Information Protection Manager) ① <HM게임> takes overall responsibility for personal information processing, handles complaints and remedies related to personal information processing, and designates a personal information protection manager as follows:

• Personal Information Protection Manager:

  • Name: 강희명

  • Position: 대표 (Representative)

  • Email: greencharon@gmail.com

  • ※ Connects to the department responsible for personal information protection.

• Email of the Department Responsible for Personal Information Protection:

  • Email: greencharon@gmail.com

② Data subjects can inquire about all matters related to personal information protection, complaints, and remedies arising from using <HM게임>'s services (or business) by contacting the personal information protection manager and the department in charge. <HM게임> will promptly respond and address data subjects' inquiries.

12. (Department for Receiving and Processing Requests for Personal Information Access) Data subjects can request access to personal information in accordance with Article 35 of the Personal Information Protection Act to the following department:

• Department for Receiving and Processing Requests for Personal Information Access:

  • Email: greencharon@gmail.com <HM게임> will make efforts to promptly process data subjects' requests for accessing personal information.

13. (Remedies for Violation of Data Subject's Rights)

Data subjects who have experienced privacy infringements due to personal information breaches can seek remedies such as dispute resolution or counseling from institutions like the Personal Information Dispute Mediation Committee and the Korea Internet & Security Agency Personal Information Infringement Report Center. Additionally, for reporting or consulting about other privacy infringements, please contact the following agencies:

• Personal Information Dispute Mediation Committee: 1833-6972 (www.kopico.go.kr)

• Personal Information Infringement Report Center: 118 (privacy.kisa.or.kr)

• Supreme Prosecutor's Office: 1301 (www.spo.go.kr)

• National Police Agency: 182 (ecrm.cyber.go.kr)

Those who have suffered harm to their rights or interests due to actions of a public agency's head related to requests based on Article 35 (Access to Personal Information), Article 36 (Correction and Deletion of Personal Information), and Article 37 (Suspension of Personal Information Processing) of the Personal Information Protection Act can seek administrative litigation in accordance with the Administrative Adjudication Act.

※ For more details about administrative litigation, please refer to the Central Administrative Appeals Commission website (www.simpan.go.kr).

제14조 (Changes to the Privacy Policy)

① This privacy policy is effective from August 21, 2023. ② The previous version of the privacy policy can be accessed below.