rifundrama Privacy Policy

Team rifundrama (hereinafter referred to as "the Company") sets forth the handling of user information (including personal information) in connection with the following services provided by the Company (collectively referred to as "the Services"). For details regarding the transmission of user information to external operators in the Services, the recipients of such transmission, the purposes of use, and the opt-in/opt-out methods, please refer to *Transmission of User Information to Third Parties* at the end of this Policy.

Applicable Services

(1) rifundrama

1. Information We Collect

The information obtained by the Company from users' use of the Services (hereinafter referred to as "User Information") includes, but is not limited to:

(a) Identification and Profile Information

Name, date of birth, gender, address, telephone number, email address, avatar, nickname, and account information (ID and password) that users may provide when using the Services.

If a user links the Services with external services provided by third parties (such as social networking services, e.g., Facebook or X (formerly Twitter)), the Company may obtain the name and other information registered by the user on such external services.

(b) Payment Information

If a user purchases goods or uses paid services within the Services, they may be required to enter credit card information or similar details; however, payment processing is handled by a payment agent, and the Company does not store credit card information.

(c) Service Usage Information

The Company may collect device information (device identifiers, operating systems, etc.), log information (IP address, browser information, language, region, etc.), viewing history (names of browsed content, number of views, etc.), purchase history, and similar information.

For certain functions, with the user's consent, the Company may obtain location information transmitted by the user's device or communication equipment.

(d) Cookies and Similar Technologies

The Company may use Cookies and similar technologies to provide the Services. For details (purposes, settings, opt-out, etc.), please refer to Section 8.

2. Purposes of Use

The Company uses User Information for the following purposes:

(1) Use of name, address, telephone number, email address and other such information

- To process account registration and perform identity verification (including SMS verification) for the Services.

- To respond to inquiries and verify user identity.

- To address violations of the *User Terms of Service* and other relevant rules of the Services.

- To conduct event lotteries and deliver prizes or goods.

- To send important notifications and other necessary communications related to the Services.

(2) Use of payment information

- To process transactions for the purchase of goods and use of paid services within the Services.

(3) Use of service usage information, date of birth, gender, interests and other such information

- To prevent unauthorized use of the Services.

- To generate statistical data on the usage of the Services.

- To conduct research, analysis and improvements to enhance the Services.

- To provide information about the Services and other services, and deliver targeted advertising.

- To plan, develop and operate new services.

3. Restrictions on the Scope of Use of Personal Information

Unless in the following circumstances, the Company shall not use personal information beyond the scope necessary to achieve the intended purposes without the user's prior consent:

- When required by applicable laws and regulations;

- When it is necessary to protect human life, body or property and obtaining consent is impracticable;

- When it is particularly necessary to improve public health or promote the sound development of children and obtaining consent is impracticable;

- When it is necessary to cooperate with national or local government authorities or their entrusted parties in the performance of their statutory duties, and obtaining consent may hinder the performance of such duties.

4. Provision of Personal Data to Third Parties

Unless in the following circumstances, the Company shall not provide personal data to third parties without the user's prior consent:

- When disclosure is required by applicable laws and regulations (e.g., when a court, procuratorate, police authority, tax authority, bar association or other authority with similar powers requests disclosure);

- When it is necessary to protect human life, body or property and obtaining consent is impracticable;

- When it is particularly necessary to improve public health or promote the sound development of children and obtaining consent is impracticable;

- When it is necessary to cooperate with national or local government authorities or their entrusted parties in the performance of their statutory duties, and obtaining consent may hinder the performance of such duties.However, in the following circumstances, the recipient of personal data shall not be deemed a "third party" for the purposes of the above provisions:

- When the Company entrusts all or part of the processing of personal data to a third party to the extent necessary to achieve the intended purposes;

- When personal data is provided due to business succession resulting from a merger or other such event;

- When personal data is shared with specific parties, and the user has been notified in advance or can easily learn of the matters necessary for such sharing (the items of personal data to be shared, the scope of the sharing parties, the purposes of use, and the name of the responsible manager).

The Company does not currently engage in the sharing of personal data with any third parties. If the Company decides to do so in the future, it will publish the items of personal data to be shared, the scope of the sharing parties, the purposes of use, and the name of the responsible manager via this Policy or an announcement page.

5. Security Management of Personal Information

The Company shall implement appropriate management and provide guidance to prevent the leakage, damage or loss of personal information and ensure its secure management. If the Company entrusts the processing of personal data to a third party, it shall enter into a confidentiality agreement and supervise the entrusted party.

The Company shall not retain personal data for a period longer than necessary to achieve the purposes for which it was obtained or the period prescribed by applicable laws and regulations. The Company shall adopt organizational, technical and physical security measures (including access control, encryption, log auditing, employee training, supervision of entrusted parties, etc.) and conduct regular inspections and reviews.

6. Disclosure of Personal Information

(1) When the Company receives a request from a user in accordance with local laws and regulations for notification of the purposes of use and disclosure of personally identifiable information (collectively referred to as "Disclosure Requests"), the Company shall verify that the request is made by the user and process the Disclosure Request without delay. If no relevant personal information exists, the Company shall notify the user accordingly.

The Company may refuse to disclose all or part of the information in the following circumstances:

- When such disclosure may harm the life, body, property or other legitimate rights and interests of the user or a third party;

- When such disclosure may significantly hinder the proper conduct of the Company's business;

- When such disclosure may violate other applicable laws and regulations.

(2) For Disclosure Requests, please contact the email address set forth in Section 10. The Company may charge a reasonable fee for Disclosure Requests and notifications of the purposes of use within a reasonable scope considering the actual costs incurred.

7. Correction, Cessation of Use, Deletion and Other Such Actions

(1) When the Company receives a request from a user in accordance with local laws and regulations for the correction, addition, deletion, cessation of use or erasure of personal information, the Company shall verify that the request is made by the user, conduct the necessary investigation promptly, and process the request in accordance with the investigation results within a reasonable period.

(2) If a user wishes to delete their personal information, in addition to the procedures stipulated in the *User Terms of Service*, iOS and Android users may initiate account deletion at any time within the Services via [My Page] → [Settings] → [Delete Account]. If the user does not use the App, please contact the inquiry window set forth in Section 10. Upon receipt of the request, the Company shall deactivate the account promptly and delete the personal information in accordance with the law.

8. Cookies and Similar Technologies

The Services may use Cookies and similar technologies. Such technologies store specific text information on the user's device to identify the user upon their subsequent visits, retain settings, understand usage patterns, improve functions and optimize advertising delivery.

For advertising delivery and related purposes, the Company may use advertising identifiers (IDFA/AAID). Users may manage personalized advertising and tracking permissions (including iOS App Tracking Transparency) through in-App settings and/or operating system settings. Users may also change their Cookie acceptance preferences through browser settings; however, this may result in the inability to use certain functions of the Services.

In addition, for certain functions and advertising displays of the Services, Cookies and similar information may be transmitted by third parties other than the Company. For details regarding external operators, the recipients of such transmission, the purposes of use, and the opt-in/opt-out methods, please refer to *Transmission of User Information to Third Parties* at the end of this Policy.

9. Changes to This Privacy Policy

The Company may amend this Privacy Policy. In the event of material revisions, the Company shall notify users via in-App notifications or on the Company's official website. Users are advised to review this Policy from time to time and use the Services only after understanding its contents.

10. Contact Information

For complaints and inquiries regarding the handling of personal information, please contact:

Team rifundrama Customer Support

Email: [email protected]

11. Cross-Border Transmission (Provision/Entrustment to Overseas Third Parties)

For the purposes of providing the Services, measurement, analysis and other such activities, the Company may entrust the processing of personal data to or provide personal data to operators located in foreign countries (e.g., operators in the United States). In accordance with the *Personal Information Protection Law* and relevant guidelines, the Company shall understand the regulatory regime of the recipient country and the security management measures of the recipient, and adopt appropriate protective measures through contracts and other such means. Upon the user's request, the Company shall provide information such as an overview of the regulatory regime of the recipient country and an overview of the security management measures of the recipient.

12. Response to Data Breaches and Other Such Incidents

In the event of a leakage, loss or damage of personal data that poses a risk of harm to the user's legitimate rights and interests, the Company shall make the necessary reports (initial and final reports) to the Personal Information Protection Commission and take such necessary measures as notifying the user, as appropriate.

13. Personal Information of Minors

Minors must obtain the consent of their legal guardians as needed when using the Services. The Company shall process requests from legal guardians for the disclosure, correction, deletion and other such actions of minors' personal information in an appropriate manner.

Transmission of User Information to Third Parties

The Company may obtain information related to the use of the Services and transmit such information to external operators to improve the Services and deliver optimal advertising.

The user information transmitted to external operators in the Services, the recipients and the purposes of use are as follows:

Firebase (Google LLC)

Purposes of Use

- Analyze usage patterns to improve the Services

User Information Transmitted

- Advertising identifiers (IDFA/AAID)

Recipient

- Google LLC

Privacy Policy

- Google Privacy Policy: https://policies.google.com/privacy?hl=en

Team rifundrama