1. General

At Daebak! Korean, we care about your personal data, so we have prepared this Privacy Policy to explain how we collect, use and share it.

This Privacy Policy (“Privacy Policy”) details the personal data K lingua & cultura Corp.("KLNC", “we”, “us” or “our”) receives about you, how we process it and your rights and obligations in relation to your personal data. K lingua & cultura Corp., a company registered at 51 Seocho-daero 74-gil, 1808 Seocho-gu, Seoul, Kora is the data controller for the purposes of the General Data Protection Regulation and any relevant local legislation.

By using or accessing the Service, you agree to the terms of this Privacy Policy. We may update our Privacy Policy to reflect changes to our information practices. If we do this and the changes are material, we will post a notice that we have made changes to this Privacy

Policy on the https://gw.klingncul.com for at least 5 days before the changes are made, and we will indicate the date these terms were last revised at the bottom of the Privacy Policy. Any revisions to this Privacy Policy will become effective at the end of that 5 day period.

2. Information We Collect

This Privacy Policy explains how we collect, use and share your personal data.

a. Information you provide

Through the registration process, you will provide us with your name, e-mail address and age or date of birth. You may also provide us with your payment transaction information if you choose to pay for KLNC services.

b. Activity Data

When you use the Service, you will submit information and content to your profile. We will also generate data about your use of our Services including your engagement in educational activities on the Service, or your sending of messages and otherwise transmitting information to other users (“Activity Data”). We also collect technical data about how you interact with our Services.

c. Third Party Data

We also collect information about you from third parties. For more information, see Information obtained by Third Parties.

d. Product Research and Development

We may contact you to participate in product research activities. These may include surveys, interviews, and other types of feedback sessions. When you participate in these research activities, the information you provide will be used to test, improve, and develop our products. We will record the video, audio and text transcriptions of this feedback together with any additional contact information you provide and will retain this data for two years.

Please contact us at it@klingncul.com to:

- Request more information about the research activities you have volunteered for.

- Opt out of being contacted for research activities.

- Request a copy of any research related data you have provided to us.

3. Information Obtained by Third Parties

To support and enhance the Service, we work with a variety of third party advertising networks, marketing analytics service providers and website analysis firms, such as Google and Facebook (collectively, “Third Party Advertising Service Providers”). These Third Party Advertising Service Providers collect and use personal data about your visits to and use of the Website and mobile Application, as well as other websites in order to serve you with advertisements and content tailored to meet your preferences and likely interests or better understand ad effectiveness. Aggregate demographic and interest data will also be used for market research purposes.

In addition, your mobile devices may offer settings that enable you to make choices about the collection, use, or transfer of mobile app information for online behavioural advertising (for example, Apple iOS’ Advertising ID and Google Android’s Advertising ID). Please note that opting out does not prevent the display of all advertisements to you.

4. Use of information obtained by KLNC

KLNC may occasionally send you service related and product change announcements through the general operation of the Service. We will send you reminder notifications to support the KLNC teaching methodology by reinforcing the learning cadence and help maintain your learning streak. We process your data to help provide you with the Service and offer personalized features, to understand and improve our Service and to keep our Service safe and secure.

KLNC may use or share anonymous data collected through the Service, including Activity Data without limitation. As a business, it is critical that we perform our contract with you with the best service possible, and it is in our legitimate interests to perform these processing functions and to enable service e-mails by default to keep your data secure and provide our Service. You may opt out of any non-essential service e-mails at any time.

We may also use your contact information to send you notifications regarding new services, offers and promotions offered by KLNC if you affirmatively consent to receive such communications.

5. Sharing your personal data with third parties

KLNC shares your personal data only when it is necessary to offer the Service, legally required, or permitted by you.

We will provide personal data to hosting providers such as Amazon Web Services and search engine providers such as Google.

These data processors help us bring you the Service. For example, we may share your information in order to detect where or how you encountered a bug when using our mobile application. In connection with these operations, our service providers will have access to personal data for a limited time. When we utilize service providers for processing any personal data, we implement contractual protections limiting the use of that personal data to the provision of services to KLNC.

We will be required to access and disclose personal data in response to lawful requests, such as subpoenas or court orders, or in compliance with applicable laws. Additionally, we will access and share account or other personal data when we believe it is necessary to comply with law, to protect our interests or property, to prevent fraud or other illegal activity perpetrated through the Service or using the KLNC name, or to prevent imminent harm. This will include accessing and sharing personal data with other companies, lawyers, agents or government agencies.

If the ownership of all or substantially all of the KLNC business, or individual business units or assets owned by KLNC that are related to the Service, were to change, your personal data will be transferred to the new owner. In any such transfer of information, your personal data would remain subject to this section.

KLNC will share aggregate or anonymous data collected through the Service, including Activity Data, for purposes such as understanding or improving the service.

6. Data subject rights and data retention

You can manage your account settings at Daebak! Korean to update, amend, and correct your information.

You also have the following rights in relation to the personal data we hold about you, unless provided otherwise by local law:

To request access to, or erasure of, the personal data we hold about you.

To request us to restrict the processing of the personal data we hold about you.

To object to us processing personal data relating to you.

Where you have given us consent to process your personal data, you have the right to withdraw that consent at any time.

To export the personal data you have provided to KLNC in a format that can be transferred electronically to a third party.

To delete your account with KLNC by following the instructions available through the Service.

To make such a request, please send an email to it@klingncul.com. KLNC will retain your data until your account is deleted, after which point we will retain anonymous data collected through the Service, including Activity Data, which may be used by KLNC and shared with third parties in any manner.

Please note that some of these rights are not absolute. In some cases, we may refuse a request to exercise particular rights if complying with it meant that we are no longer able to meet our contractual obligation to provide you with particular products and services. We will keep you informed as to the actions that we can take when you make your request.

7. Protection of personal information of children

In principle, KLNC does not collect any information from the children under 13 or equivalent minimum age as prescribed in the laws in relevant jurisdiction. Daebak! Korean of KLNC is the one to be provided to ordinary people, in principle and has function to do age limit so that children cannot use it and KLNC does not intentionally collect any personal information from children through that function.

(Additional procedure for collecting personal information from children) However, if KLNC collects any personal information from children under 13 or equivalent minimum age as prescribed in the laws in relevant jurisdiction for the services for unavoidable reason, KLNC will go through the additional procedure of the followings for protecting that personal information of children

- verify, to the extent that efforts are reasonably made, whether they are children of the age at which consent from their guardian is required and the consenting person is an authorized one

- obtain consent from the parents or guardian of children so as to collect personal information of children or directly send the information of products and services of KLNC

- give the parents or guardian of children a notice of KLNC’s policy of privacy protection for children including the items, purpose and sharing of personal information collected

- grant to legal representatives of children a right to access to personal information of that children/correction or deletion of personal information/temporary suspension of treatment of personal information/ and request for withdrawal of their consent provided before

- limit the amount of personal information exceeding those necessary for participation in online activities

8. Modification of Privacy Protection Policy

KLNC has the right to amend or modify this Policy from time to time and, in such case, KLNC will make a public notice of it through bulletin board of its website (or through individual notice such as written document, fax or e-mail) and obtain consent from the users if required by relevant laws.

9. Contacting us

If you have any other queries relating to this policy, KLNC's Data Privacy Officer (the Data Protection Officer) can be reached by email at it@klingncul.com.

Appendix of Privacy Protection Policy

<1> Lawful processing of personal information under GDPR

Processing personal information by KLNC shall be lawful only if and to the extent that at least one of the following applies:

a. A user has given consent to the processing of his or her personal information.

b. Processing is necessary for the performance of a contract to which a user is party or in order to take steps at the request of a user prior to entering into a contract:

- Member management, identification, etc.

- Performance of a contract in relation to providing the services required by users, payment and settlement of fees, etc.

c. Processing is necessary for compliance with a legal obligation to which KLNC is subject

- Compliance with relevant law, regulations, legal proceedings, requests by the government

d. Processing is necessary in order to protect the vital interests of users, or other natural persons

- Detection of, prevention of, and response to fraud, abuse, security risks, and technical issues that may harm users or other natural persons

e. Processing is necessary for the performance of a task carried out in the public interest or in the excise of official authority vested in KLNC

f. Processing is necessary for the purposes of the legitimate interests pursued by KLNC or by a third party (except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child).

<2> User’s right when applying GDPR

The users or their legal representatives, as main agents of the information, may exercise the following rights regarding the collection, use and sharing of personal information by KLNC:

a. The right to access to personal information;

The users or their legal representatives may access the information and check the records of the collection, use and sharing of the information under the applicable law.

b. The right to rectification;

The users or their legal representatives may request to correct inaccurate or incomplete information.

c. The right to erasure;

The users or their legal representatives may request the deletion of the information after the achievement of their purpose and the withdrawal of their consent.

d. The right to restriction of processing;

The users or their legal representatives may make temporary suspension of treatment of personal information in case of the disputes over the accuracy of information and the legality of information treatment, or if necessary to retain the information.

e. The right to data portability

The users or their legal representatives may request to provide or transfer the information.

f. The right to object

The users or their legal representatives may suspend the treatment of personal information if the information is used for the purpose of direct marketing, reasonable interests, the exercise of official duties and authority, and research and statistics.

g. The right to automated individual decision-making, including profiling

The users or their legal representatives may request to cease the automated treatment of personal information, including profiling, which has critical impact or cause legal effect on them.

If, in order to exercise the above rights, you, as an user, use the menu of 'amendment of member information of webpage or contact KLNC by sending a document or e-mails, or using telephone to KLNC (person in charge of management of personal information), KLNC will take measures without delay: Provided that KLNC may reject the request of you only to the extent that there exists either proper cause as prescribed in the laws or equivalent cause.

<3> Data transfer to other countries

Considering it engages in global businesses, KLNC may provide the users' personal information to the companies located in other countries for the purpose as expressly stated in this Policy. For the places where the personal information is transmitted, retained or processed, KLNC takes reasonable measures for protecting those personal information.

(If used in the US, additional security measures may be available) In addition, when the personal information obtained from the European Union or Switzerland is used or disclosed, KLNC may have to comply with the US-EU Privacy Shield and Swiss-US Privacy Shield, take other measures or obtain consent from users so far as those complies with the regulations of EU so as to use a standardized agreement provision approved by executing organizations of EU or securing proper safe measures.

<4> 3rd party's sites and services

Daebak! Korean may include the links to the ones of a 3rd party and the privacy protection policy of the site of 3rd party may be different. Thus, it is required for the users to check additionally that policy of a 3rd party site linked to the site of KLNC.

<5> Guide for users residing in California

If the user resides in California, certain rights may be given. KLNC prepares preventive measures necessary for protecting personal information of members so that KLNC can comply with online privacy protection laws of California.

In case of leakage of personal information, a user may request KLNC to check the leakage. In addition, all the users in the website of KLNC, can modify their information at any time by using the menu for changing information by connecting their personal account.

Moreover, KLNC does not trace the visitors of its website nor use any signals for 'tracing prevent'. KLNC will not collect and provide any personal identification information through ad services without consent of users.

<6> Guide for users residing in Korea

KLNC guides several additional matters to be disclosed as required by the information network laws and personal information protection laws in the Republic of Korea as follows:

(1) Information collected

The items collected by KLNC are as follows:

- Name, email address, ID, telephone number, address, national information, encoded identification information (CI), identification information of overlapped membership (DI)

- For minors, information of legal representatives (name, birth date, CI and DI of legal representatives)

- Information of service use of members such as the type of contents watched or used by members, frequencies and period of activities of members

- Information of devices (equipment/device identifier, operation system, hardware version, equipment set-up and telephone number)

- Log information (Log data, use time, search word input by users, internet protocol address, cookie and web beacon)

- Location information (Information of device location including specific geographical location detected through GPS, Bluetooth or Wifi)

- Other created information

(2) Commission for collected personal information

In commissioning process of personal information, in order to secure safety of personal information, KLNC supervises and ensure to expressly state in the agreement with subcontractors so that those subcontractors will safely process personal information by strictly complying with directions regarding personal information protection, keeping personal information secret, not disclosing it to a 3rd party and being liable for accidents and returning or destructing personal information upon termination of the commission or process.

(3) Period for retention and use of personal information

In principle, KLNC destructs personal information of users without delay when: the purpose of its collection and use has been achieved; the legal or management needs are satisfied; or users request: Provided that, if it is required to retain the information by relevant laws and regulations, KLNC will retain member information for certain period as designated by relevant laws and regulations. The information to be retained as required by relevant laws and regulations are as follows:

- Record regarding contract or withdrawal of subscription: 5 years (The Act on Consumer Protection in Electronic Commerce)

- Record on payment and supply of goods: 5 years (The Act on Consumer Protection in Electronic Commerce)

- Record on consumer complaint or dispute treatment: 3 years (The Act on Consumer Protection in Electronic Commerce)

- Record on collection/process, and use of credit information: 3 years (The Act on Use and Protection of Credit Information)

- Record on sign/advertisement: 6 months (The Act on Consumer Protection in Electronic Commerce)

- Log record of users such as internet/data detecting the place of user connection: 3 months (The Protection of Communications Secrets Act)

- Other data for checking communication facts: 12 months (The Protection of Communications Secrets Act)

(4) Procedure and method of destruction of personal information

In principle, KLNC destructs the information immediately after the purposes of its collection and use have been achieved without delay: Provided that, if any information is to be retained as required by relevant laws and regulations, KLNC retain it for the period as required by those laws and regulations before destruction and, in such event, the personal information which is stored and managed separately will never be used for other purposes. KLNC destructs: hard copies of personal information by shredding with a pulverizer or incinerating it; and delete personal information stored in the form of electric file by using technological method making that information not restored.