Nuttycode Inc. (the “Company”) establishes and discloses the following privacy policy in accordance with the Personal Information Protection Act of the Republic of Korea to protect users’ personal information and to ensure the prompt and smooth handling of related grievances.
Purpose of processing personal information
The Company processes personal information for the following purposes. The personal information processed will not be used for any purpose other than the following, and if the purpose of use is changed, we will take necessary measures, such as obtaining separate consent in accordance with the Personal Information Protection Act.
1. Sign up and manage members
Personal information is processed for the purpose of confirming membership intentions, maintaining and managing membership in accordance with the provision of membership services, preventing unauthorized use of services, providing various notices and notifications, and handling grievances.
2. Provide goods or services
We process personal information for the purpose of providing the Services and in-app purchases, content, and personalized services.
3. Grievances
We process personal information for the purpose of identifying users, confirming inquiries, contacting them for fact-finding, notifying them, and notifying them of processing results.
Processing and retention period of personal information
The Company shall process and retain personal information within the period of retention and use specified in laws and regulations or agreed upon when collecting personal information from users.
The respective personal information processing and retention periods are as follows
1. Sign up and manage members: until they leave
However, in cases corresponding to the following reasons, until the end of the respective reason
1) If there is an ongoing investigation or inquiry into a violation of a related party law, etc.
2) If a debt-debt relationship exists due to the use of the service, the debt-debt relationship shall be settled.
2. Provide goods or services: until completion of the supply of goods or services or termination of use of the service.
However, in cases corresponding to the following reasons, until the end of the respective reason
1) Records of transactions such as display and advertisement, contract contents and performance in accordance with the Act on Consumer Protection in Electronic Commerce, etc.
– Records on display and advertisement: 6 months
– Records of contract or subscription withdrawal, payment, and supply of goods: 5 years
– Records on consumer complaints or dispute handling: 3 years
2) Retention of telecommunications fact verification data under the Telecommunications Secrecy Protection Act
– Subscriber telecommunication date, start and end time, other party’s subscriber number, usage
3. Grievance: Until the grievance is completed
Items of personal data we process
1. The company processes the following personal information items
1) Sign up and manage
– Required: User identifier, service ID, nickname
2) Provide goods or services
– Required: User identifier, service ID, nickname, user message, user photo, user voice
3) Grievances
– Required: Email address
2. In the process of using the service, the following personal information items may be automatically generated and collected.
– IP address, cookies, service usage records, metadata
3. In the process of using the Service, the following information, which is not personal information, may be generated and collected.
– Ad identifiers, browsing history, device information (device type, model name, OS version, device identifier, language, country), purchase information provided by in-app purchases (subscription items, subscription start and end dates, receipt ID, etc.)
Disclosure of Personal Information to Third Parties
1. The Company shall use the personal information of the information subject to the extent specified in the purpose of processing personal information. Only in accordance with Articles 17 and 18 of the Personal Information Protection Act, including the consent of the information subject and special provisions of the law. We will only provide personal information to third parties if we are authorized to do so, and otherwise we will not provide personal information of data subjects to third parties.
2. We do not provide personal information to third parties, and if we do, we will obtain your consent.
Entrustment of Personal Data Processing
1. The Company may entrust certain personal data processing tasks to third-party service providers in accordance with the Personal Information Protection Act of the Republic of Korea.
The Company specifies in written agreements that service providers must not process data beyond the scope of the entrusted tasks, must implement appropriate technical and organizational safeguards, are restricted from subcontracting without consent, and are held liable for any damages.
The Company also supervises these providers to ensure they handle personal data securely.
2. For analytics and advertising performance measurement, the Company also entrusts certain data processing to the following overseas service providers:
– Service providers: Google, Meta Platforms
– Purpose: Log analysis and advertising performance tracking
– Data transmitted: Advertising identifier, IP address, and other related data
– Retention period: Until the end of the contract or 12 months from the date of collection, whichever comes first
3. To provide services, the Company transmits certain data to external API service providers located overseas.
The details of this entrustment are as follows:
– Service providers: Google, OpenAI, Anthropic
– Purpose: Natural language processing for AI functionality
– Data transmitted: User message, user photo
– Retention period: Processed temporarily during API calls only
These providers are contractually prohibited from using this data for training purposes.
For more information, please refer to each provider’s privacy policy.
4. If there are any changes to the service providers or the scope of entrusted processing, the Company will promptly disclose such changes through this Privacy Policy.
About the process and methods for destroying personal information
1. The Company shall destroy the personal information without delay when the personal information becomes unnecessary, such as the expiration of the personal information retention period or the achievement of the purpose of processing.
3. The procedure and method for destroying personal information is as follows
1) Destruction Process
The Company selects the personal information for which the reason for destruction has occurred and destroys the personal information with the approval of the Company’s personal information protection officer.
2) Destruction method
The Company destroys personal information recorded and stored in electronic files so that the records cannot be reproduced, and destroys personal information recorded and stored in paper documents by shredding or incineration.
Rights and obligations of information subjects and legal representatives and how to exercise them
1. Users may exercise their rights to view, correct, delete, or request suspension of processing of personal information at any time against the Company.
1) View personal information: Settings > Account
2) Delete Account: Settings > Account > Delete Account
3) How to opt out of the transfer of your personal data: (Android) Delete your ad ID, (iOS) Disallow apps to request tracking
4) In addition, you may request the suspension of processing and deletion of personal information in writing, by e-mail, etc.
5) If the Company requests correction or deletion of errors in personal information, the Company will not use or provide such personal information until the correction or deletion is completed.
6) A request for the correction and deletion of personal information cannot be made if the personal information is specified as the subject of collection in another law.
7) The Company shall verify that the person who made the request is the person who made the request, such as viewing in accordance with the user’s rights, requesting correction or deletion, or requesting suspension of processing.
2. Rights of legal representatives and how to exercise them
1) If an agent, such as the user’s legal representative or a person authorized by the user, exercises the user’s rights (access, correction, suspension of processing, deletion), a power of attorney in the form of Appendix No. 11 to the Enforcement Rules of the Personal Information Protection Act must be submitted.
2) The Company shall confirm whether the person making the request is a legitimate representative when requesting access, correction, deletion, or suspension of processing in accordance with user rights.
Measures to ensure the safety of personal information
The Company takes the following measures to ensure the safety of personal information.
1) Administrative measures: Establishment and implementation of internal management plans, regular employee training, and regular checks of access records.
2) Technical measures: management of access rights to personal information processing systems, installation of access control systems, encryption of personal information, installation and update of security programs, etc.
3) Physical measures: Access control to computer rooms, archives, etc.
About the Privacy Officer
The Company designates a personal information protection officer as follows to oversee the processing of personal information and to handle user complaints and damage relief related to the processing of personal information.
Name: Juwon Jeong
Position: CTO
Contact: support@nuttyco.de
Users may contact the person in charge of personal information protection for all personal information protection-related inquiries, complaints, and damage relief arising from the use of the Company’s services. Inquiries will be answered and handled as soon as possible.
Scope of the Privacy Policy
This Privacy Policy applies to all Services provided by the Company, but where the nature of the Services differs, a Service-specific Privacy Policy may apply. This Privacy Policy does not apply if you visit other companies’ websites that are linked to the Company Services, or if the websites you visit collect personal information.
Changes and notices to the Privacy Policy
1. If there is any addition, deletion, or modification of the contents of this Privacy Policy, we will notify you in advance through ‘Notice’ at least 7 days before the revision. In addition, we may obtain your consent again if there is a significant change in your rights, such as changes in the items of personal information collected or the purpose of use.
2. This Privacy Policy is effective as of January 1, 2024.