Contact Information:

Email: lumencodegame@gmail.com

LUMENCODE CO Platform User Privacy Policy

LUMENCODE CO Platform (hereinafter referred to as the "Company") highly values the protection of its members' personal information and complies with relevant laws and regulations such as the "Act on Promotion of Information and Communications Network Utilization and Information Protection, etc.", the "Personal Information Protection Act", the "Act on the Protection, Use, etc. of Location Information", and guidelines established by relevant institutions.

Through this Personal Information Policy, the "Company" aims to inform members about the purposes and methods of using the personal information they provide, as well as the efforts the "Company" is making to protect members' personal information.

Article 1: Items of Personal Information Collected/Used and Collection Methods

The items of personal information collected/used by the Company and the collection methods are as follows:

Items of Personal Information Collected/Used:

① Member ID (Email Address), Password, Mobile Phone Number

② Name, Address, Telephone Number

③ Mobile Device Model, OS Information, OS Version, Device Identification Number (Device ID or IMEI, UUID, UDID, etc.), MAC Address, Mobile Carrier Information, IP Address

④ GPS Location Information, Cell Tower Location Information, WIFI-AP Information (Limited to games using location-based services)

⑤ Encrypted Personal Identification Information, Duplicate Registration Confirmation Information, Date of Birth, Gender Information, Information on Domestic/Foreigner Status (Limited to games equipped with identity verification services)

⑥ Payment Information

⑦ Credit Card Number

⑧ Phone Numbers (Mobile/Regular) in Phone Contacts, Names (Nicknames) in Contacts

⑨ Game Invitation ID (Limited to games equipped with game invitation functions)

⑩ Member's Facebook ID and Facebook Friend IDs (Limited to cases using Facebook linkage function)

Methods of Personal Information Collection: Obtained from partner companies such as identity verification agencies, or collected through mobile devices, 1:1 inquiries, and other methods of direct input by the customer.

Members may refuse to provide the aforementioned personal information. However, if personal information provision is refused, the use of part or all of the services may be restricted.

Article 2: Purposes of Collection/Use of Personal Information

For the personal information collected/obtained, the Company distinguishes between items requiring the data subject's consent and those not requiring consent. The purposes of use for each item are as follows:

Items Requiring Member Consent

① Member ID (Email Address), Facebook ID: For personal identification during service use, management of problematic members, handling complaints and other customer service provision, notification of matters

② Password: To confirm access rights during service use

③ Phone Numbers, Names in Member's Phone Contacts, Facebook Friend Information: For providing community services such as friend matching, game invitations, ranking information, gift functions

④ Mobile Phone Number: For identity verification, handling complaints and other customer service provision, notification of matters, provision of paid payment services

⑤ GPS Location Information, Cell Tower Information (cell-id), WIFI-AP (Limited to content equipped with location-based services): For providing coordinate measurement for location-based services

⑥ Device Identification Number, MAC Address: For notification of new services, event information (push notifications), personal identification, and management of problematic members

⑦ Mobile Device Model, OS Information, OS Version, Mobile Carrier Information: For improving service quality and processing statistical information

⑧ IP Address: For identifying abnormal users, restricting use, contract fulfillment, dispute resolution, etc.

⑨ Credit Card Number: For providing paid payment services

⑩ Address, Telephone Number: For delivering prizes during event promotions

Items Not Requiring Member Consent

① Access Records (Access Date and Time, etc.): For improving service quality, contract fulfillment, and dispute resolution

② Payment Information: For customer service related to fee settlement for paid service use

③ Game Invitation ID: For identifying the inviting member and awarding rewards during game invitations

Items Obtained and Used from Partner Companies

Limited to content separately equipped with identity verification services, when conducting identity verification, encrypted personal identification information/duplicate registration confirmation information/date of birth/gender information/domestic/foreigner status information, etc., are obtained from identity verification agencies and used for the following purposes:

① Name/Encrypted Personal Identification Information/Duplicate Registration Confirmation Information: For identity verification, confirmation of duplicate registration

② Date of Birth: For age verification

③ Gender Information: For gender verification

④ Domestic/Foreigner Status Information: For verification of domestic/foreigner status

Article 3: Retention and Use Period of Personal Information

Personal information collected with the member's consent will be retained and used during the existence of the membership. When a member requests termination (withdrawal), it will be completely deleted from the disk using non-recoverable methods and processed in a state where it cannot be viewed or used in the future.

However, to prevent damage, recovery, and protect victims due to personal information theft, etc., the Company may temporarily retain the Member ID (Email Address) for up to 14 days from the date of termination (withdrawal), after which it will be completely deleted using non-recoverable methods. Additionally, the following cases are excluded.

Cases requiring retention according to laws such as the Commercial Act

Records related to contracts or withdrawal of offers

Reason for Retention: "Act on the Consumer Protection in Electronic Commerce, etc."

Retention Period: 5 years

Records related to payment of fees and supply of goods, etc.

Reason for Retention: "Act on the Consumer Protection in Electronic Commerce, etc."

Retention Period: 5 years

Records related to consumer complaints or dispute resolution

Reason for Retention: "Act on the Consumer Protection in Electronic Commerce, etc."

Retention Period: 3 years

Access Logs, Access IP Information, Service Usage Records

Reason for Retention: "Protection of Communications Secrets Act"

Retention Period: 3 months

Cases where separate member consent has been obtained

Article 4: Sharing and Provision of Personal Information

When collecting members' personal information, the Company uses it within the scope of the announced purposes. In principle, members' personal information is not disclosed to external parties without prior member consent. However, the following cases are excluded.

First, cases where the member has consented to disclosure in advance.

Second, cases where the member violates the terms of service use posted on the website or other terms or policies for member service use.

Third, cases where there is sufficient grounds to believe that disclosure of personal information is necessary to take legal action because using the service causes mental or material damage to others.

Fourth, other cases required by law and judged to be in good faith.

For example: Cases where provision of information is mandated by relevant laws, or cases responding to legitimate requests from courts, investigative agencies, or other administrative agencies.

Article 5: Procedures and Methods for Destruction of Personal Information

Members' personal information will be destroyed immediately after the purposes of collection and use are achieved. The procedures and methods for destruction are managed according to the following standards:

Destruction Procedures

Information input by members for registration, etc., or information obtained from partner companies such as identity verification agencies, etc., that the Company collects/uses, will be stored according to the internal policy and retention periods stipulated by other relevant laws and regulations after the purpose of use is achieved, and then destroyed.

Destruction Methods

① Personal information printed on paper is destroyed by shredding through a shredder or by incineration.

② Personal information records stored in electronic file format are deleted using non-recoverable technical methods.

Article 6: Rights of Users and Legal Representatives and Methods of Exercising Them

Members and legal representatives may withdraw consent to provide personal information at any time (member withdrawal). To withdraw consent to provide personal information, withdrawal can be processed by clicking "Member Withdrawal" or "Account Deletion" within the service, or by withdrawing consent to provide personal information through the customer service center. Furthermore, registered personal information of oneself or a child under 14 years of age (limited to legal representatives) can be inquired about or modified.

When a member requests correction of errors in personal information, that personal information will not be used or provided until the correction is completed. Additionally, if incorrect personal information has already been provided to a third party, the result of the correction process will be immediately notified to the third party to facilitate correction.

Personal information terminated or deleted upon the request of a member or legal representative is processed according to the content clearly specified in "Article 3: Retention and Use Period of Personal Information" and is handled in a way that makes it impossible to view or use for other purposes.

Article 7: Installation/Operation of and Refusal Regarding Personal Information Automatic Collection Devices

To provide customized services to members, the Company uses 'Cookies' that store and retrieve member information. Cookies are very small text files sent by the server to the member's mobile device when operating the service and are stored on the member's mobile device. Later, when the member uses the service, the server reads the Cookie content stored on the member's mobile device, confirms the member information, and provides customized services.

The Company uses Cookies for customized services such as linkage of member profile information. Members have the choice of whether to install Cookies. Members can set whether to allow Cookies in their mobile device settings and can also delete Cookies. However, if the use of Cookies is not allowed, difficulties may be encountered when using services requiring login.

Article 8: Technical and Administrative Protection Measures for Personal Information

When handling members' personal information, the Company takes the following technical and administrative measures to prevent loss, theft, leakage, forgery, or damage of personal information and to ensure security:

The Company endeavors to prevent leakage or damage of members' personal information due to hacking or computer viruses. To prepare for damage to personal information, data is backed up regularly, and the latest antivirus programs are used to prevent leakage or damage to members' personal information or data. Personal information is transmitted securely over networks using encryption algorithms, etc. Furthermore, intrusion blocking systems are used to control unauthorized access from outside, and efforts are made to equip all possible technical devices to ensure system stability.

The Company limits access rights to personal information to designated personnel. For this purpose, separate passwords are assigned and regularly updated. Through continuous education for personnel, compliance with the Company's Personal Information Policy is consistently emphasized.

Moreover, through internal dedicated bodies, etc., the Company checks the implementation of its Personal Information Policy and personnel compliance. When problems are found, they are corrected immediately, and efforts are made to rectify them.

The services provided by the Company are based on mobile devices. Loss of a mobile device may lead to personal information leakage. Therefore, please be careful not to lose mobile devices, and it is recommended to use security services such as screen lock functions or pattern functions. Additionally, members' personal information is securely protected by passwords. The responsibility for managing Member IDs and passwords lies with the members. The Company assumes no responsibility for any problems arising from the leakage of important personal information due to negligence by the member, such as disclosing the Member ID or password to a third party or losing the device.

Article 9: Complaint Services Regarding Personal Information

The Company listens to members' opinions regarding personal information and has prepared all procedures and methods for handling complaints.

Members can refer to the "Company Personal Information Management Officer and the Officer's Affiliation, Name, and Contact Information" indicated above and report complaint matters through established procedures such as telephone or 1:1 inquiry. The Company will provide prompt and sufficient responses to members' reported matters.

Article 10: Other Matters

The Company's Personal Information Policy may be amended due to changes in laws, guidelines, or internal company policies. When amending the Personal Information Policy, the Company will notify members of the changes through means such as the initial service screen and other methods where members can confirm.

If there are additions, deletions, or modifications to the content of the Personal Information Policy, notice will be given at least 7 days prior to the amendment.

Addendum

This Policy shall be effective from January 1, 2024.