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Privacy policy

Article 1 (Purpose of collection/use of personal information, items, retention period)

1.
In accordance with Article 15, Paragraph 1, Subparagraph 1 of the Personal Information Protection Act, the Company processes the following personal information items in order to take action at the request of members during the process of concluding a service use agreement (membership registration) or performing a contract concluded with a member.
Division
Collection and use items
Purpose of collection and use
Holding period
Membership registration and management
Member Common
Apple
Email
Google
Email
Confirmation of intent to join membership, identification and authentication for provision of membership services, maintenance and management of membership qualifications, prevention of unauthorized use of services, various notifications and notices, complaint handling, and record preservation for dispute resolution
When you cancel your membership
2.
The company processes personal information items as follows with the consent of members based on Article 15, Paragraph 1, Item 1 of the Personal Information Protection Act.
Division
Collection/Use Items
Purpose of collection/use
Holding period
Participate in the event
[Essential]
Name, contact information, address
Announcement of event winners and delivery of prizes
From the date of selection
2 months
Use for marketing and advertising
[Select]
Gender, Date of Birth, Contact Information
Providing customized recommendation services and providing benefit information for marketing purposes
When you withdraw your consent or
Destroy without delay upon withdrawal of membership
Customer Inquiry and Consultation
[Essential]
Name, Email, Contact Number
Inquiry reception and processing result reply
From the date of receipt
3 years
3.
Notwithstanding the retention period in Paragraphs 1 and 2 above, the Company may retain personal information for a certain period of time after the retention period has ended due to withdrawal of membership, etc., in order to confirm transaction-related rights and obligations in accordance with internal policies and provisions of the Commercial Act, the Act on Consumer Protection in Electronic Commerce, etc., the National Tax Basic Act, and the Value Added Tax Act. In this case, access to and use of the retained personal information will be limited to the relevant reason, and the purpose of retention, retention period, and personal information items retained will be clearly stated.
Holding information
Holding period
Legal basis or internal policy
Records of contracts or cancellations of subscriptions, etc.
5 years
Act on Consumer Protection in Electronic Commerce, etc.
Records of consumer complaints or dispute resolution
3 years
Act on Consumer Protection in Electronic Commerce, etc.
Service visit and usage history
3 months
Communications Secrets Protection Act
Records of display and advertising
6 months
Act on Consumer Protection in Electronic Commerce, etc.
Sign up email
1 month
Internal policy (preventing fraudulent registration and membership registration abuse, preventing duplicate benefits)

Article 2 (Provision of personal information to third parties)

1.
The company processes members' personal information only within the scope specified in the purpose of processing personal information, and provides personal information to third parties only in cases corresponding to Articles 17 and 18 of the Personal Information Protection Act, such as consent from members or special provisions of laws. In other cases, the company does not provide members' personal information to third parties.
2.
The company may provide personal information to relevant organizations without the consent of members if it is clearly deemed necessary for the urgent life, body, or property interests of members or third parties, or if it is urgently necessary for public safety and well-being, such as public health.

Article 3 (Entrustment of personal information processing)

In order to ensure smooth performance of business during the service provision process, the company entrusts personal information processing tasks to external specialized companies as follows.
The status of transferring personal information to overseas companies for service use is as follows.
Trustee
Location of the consignee
Date and method of consignment
Personal information items to be entrusted
Consignment work content
Retention and use period of personal information
Japan etc.
Transmission through the network at the time of service use
earsup All personal information items provided by the service infrastructure and members during the service use process
Operate and manage cloud servers where personal information is stored
Until the end of the consignment contract

Article 4 (Destruction of personal information, etc.)

1.
The company destroys personal information without delay when the personal information becomes unnecessary, such as when the retention period for personal information expires or the processing purpose is achieved.
2.
If the retention period for personal information agreed upon by the member has expired or the purpose of processing has been achieved, but the personal information must be retained in accordance with other laws and regulations, the personal information will be transferred to a separate database (DB) or stored in a different location.
3.
The procedures and methods for destroying personal information are as follows:
a.
Destruction Procedure
The company selects personal information for which a reason for destruction has arisen and destroys the personal information after receiving approval from the company's personal information protection officer.
However, for members who signed up using a SNS account, service unlinking is possible through the relevant registration method (Google, Apple). However, even if SNS unlinking is done, the member's information stored by the company will not be deleted. Therefore, please request deletion of personal information through the customer center or proceed with the membership withdrawal process directly within the service.
Also, even if you delete the earsup mobile app, your account (ID) including personal information will not be deleted. Therefore, if you wish to delete your account, please proceed with the membership withdrawal process directly within the service.
b.
How to destroy
The company destroys personal information recorded and stored in electronic files by making the records unrecoverable, and destroys personal information recorded and stored in paper documents by shredding or incinerating them.

Article 5 (Rights and obligations of members and legal representatives and methods of exercising them)

1.
Members may exercise their rights to view, correct, delete, or suspend the processing of their personal information at any time.
2.
The rights under Paragraph 1 may be exercised through a legal representative or an authorized agent of the member. In this case, a power of attorney in the format of Appendix 11 of the “Personal Information Processing Method Notice (No. 2020-7)” must be submitted.
3.
When requesting access, correction/deletion, or suspension of processing in accordance with the data subject's rights, the company verifies whether the person making the request is the data subject or a legitimate agent.
4.
Members may exercise their rights in accordance with Article 41, Paragraph 1 of the Enforcement Decree of the Personal Information Protection Act through written documents, email, etc., and the company will take action without delay.
5.
However, a member's request to view or suspend processing of personal information may be restricted under Article 35, Paragraph 4 and Article 37, Paragraph 2 of the Personal Information Protection Act.
6.
Requests for correction or deletion of a member's personal information cannot be made if the personal information is explicitly stated as a collection target in other laws.
7.
If a member requests correction of errors in personal information, the company will not use or provide the personal information to a third party from the time of receiving the request until the correction is completed. In addition, if incorrect personal information is provided to a third party, the results of the correction process will be notified to the third party without delay.
8.
If a member requests deletion of personal information, personal information will be destroyed in accordance with the personal information destruction procedures and methods.

Article 6 (Measures to ensure the security of personal information)

In processing members' personal information, the company implements the following technical, administrative, and physical measures to ensure the security of personal information and to prevent loss, theft, leakage, alteration, or damage to personal information. However, the company is not responsible for damages caused by the member's fault and not by the company's fault.
1.
Administrative measures: Establishment and implementation of internal management plan, operation of dedicated organization, regular employee training
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

Article 7 (Matters concerning installation, operation and refusal of automatic personal information collection devices)

1.
The company uses “cookies” to store and periodically retrieve usage information in order to provide personalized services to members.
2.
Cookies are small pieces of information that the server (http) that operates the website sends to the user's computer browser and may be stored on the hard disk of the user's PC computer.
3.
Members can disallow the creation of cookies in the following ways:
a.
IOS: Select the “Settings” application, then select “Safari” → In “Safari,” check the “Block all cookies” checkbox under “Privacy and security”

Article 8 (Link Site)

If you click on a link contained in the earsup service and move to another site, the privacy policy of that site is unrelated to earsup, so please be advised that this privacy policy does not apply to the collection of personal information by websites linked to earsup. If you click on a link and move to another site, please be sure to review the privacy policy of that site.

Article 9 (Personal Information Protection Manager)

1.
The company is responsible for overall management of personal information processing, and has designated a personal information protection officer as follows to handle complaints and damages from data subjects related to personal information processing, as well as requests to view personal information in accordance with Article 35 of the Personal Information Protection Act.
a.
Personal Information Protection Officer
Name: Kim Jae-cheon
Position: Representative
Contact: earsup-contact@sproutgrowlabs.com
b.
Personal Information Protection Department
Department Name: -
Contact Person: Jae-Cheon Kim
Contact: earsup-contact@sproutgrowlabs.com
2.
Members may inquire about all personal information protection-related matters, including complaints, damage relief, etc. that arise while using the earsup service, to the personal information protection officer and the department in charge. The company will respond to and process member inquiries without delay.

Article 11 (Methods of Redress for Infringement of Rights)

1.
The company guarantees the members’ right to self-determination of personal information and strives to provide consultation and relief for damages resulting from personal information infringement. If you need to report or consult about a personal information infringement, please contact the department in charge in Article 10.
2.
Members may apply for dispute resolution or consultation to the Personal Information Dispute Mediation Committee, the Personal Information Infringement Report Center of the Korea Internet & Security Agency, etc. to seek relief for personal information infringement. For other reports or consultations on personal information infringement, please contact the following organizations.
a.
Personal Information Dispute Mediation Committee: (without area code) 1833-6972 ( https://kopico.go.kr )
b.
Personal Information Infringement Report Center: (without area code) 118 ( https://privacy.kisa.or.kr )
c.
Supreme Prosecutors' Office Cyber Investigation Department: (without area code) 1301 ( https://spo.go.kr )
d.
National Police Agency Cyber Investigation Bureau: (without area code) 182 ( https://ecrm.police.go.kr )

Supplementary provisions

This Privacy Policy applies from March 13, 2025.