DONTALK Privacy Policy

Part 1. Purpose

1. BRINICLE (hereinafter referred to as the "Company") considers the protection of personal information of users important and has done the best to protect personal information of users.
2. The Company has complied with the provisions concerning protection of personal information under any applicable laws and regulations to be observed by information and communications service provider, including Communications Network Utilization and Information Protection, etc. The Company let users know the purpose and use of user personal information through this Privacy Policy.
3. The Privacy Policy is available at all times through the DONTALK notice.

Part 2 Personal information items collected and method of collecting personal information

1. The Company provides an agreement process of Terms and Conditions, Privacy Policy of its Service for user when registering of service. If a user clicks a button of ‘agree,’ he/she is deemed to agree to collection of personal information.
2. The Company shall acquire the following personal information in order to provide the DONTALK service. The Company does not require the personal information which concerned to violate the fundamental human rights (race and ethnicity, ideology and creed, place of birth, political affiliation, criminal records, health and sexual activity, etc.)
(1) Phone Number Member
- Mandatory Items: Mobile phone number, mobile phone information, DONTALK service version.
- Optional Items: 3rd parties’ phone numbers and name stored in the mobile phone contact list, profile photo.
(2) BRINICLE Account Member
- Mandatory Items: Name, gender, birth date, ID, PW, IPIN number(for IPIN user), CI, DI, mobile phone number, email address, data plan, DONTALK service version.
- Optional Items: 3rd parties’ phone numbers and name stored in the mobile phone contact list, profile photo.
3. The Company may collect the usage history, logs, cookies, IP address, ID, and payment history in the course of using the service.
4. The Company collects personal information in the following method.
(1) Sign Up, service inquiries, event participation, shipping request.
(2) Information gathering tool

Part3 Purpose of collecting and using personal information

The purposes of collection and use of personal information of users of DONTALK are as follows:
1. Provision of functions -Automatic registration of friends and recommendation of friends
(1) Providing functions of automatic registration of friends and recommendation of friends using user phone numbers and the phone numbers, names of third parties stored in the phone contact list of users
2. Fulfillment of contracts regarding service provision
(1) Content provision, delivery of goods
3. Member management
(1) Personal identification for the use of membership service and user identification pursuant to the Real Name Verification Law, personal identification, prevention of illegal and unauthorized use by rejected members, verification of intention to sign up, sign-up and limitation of the frequency of sign-up, checking whether the legal representative consented to the collection of the personal information of children under age 14, subsequent identification of legal representatives, maintaining records for resolution of disputes, handling civil petitions, including complaints, and delivery of notices
4. Use of personal information for marketing and advertising
(1) Development of new services and provision of customized services, provision of services according to statistical characteristics and advertising, checking the effectiveness of services, checking connection frequency, statistics on member service use, provision of information on events and advertising information, provision of opportunities to participate events

Part 4 Sharing and providing personal information

1. The Company uses user personal information within the scope stipulated in "3. Purpose of collecting and using personal information," and does not use it outside of this scope or disclose it without the user's prior consent in principle. However, an exception is made in the following cases:
(1) In the event that users consented to disclosure in advance; and
(2) In the event that an investigative agency requests disclosure in accordance with law, or in accordance with procedures and methods stipulated by law for the purposes of investigation
2. The Company may provide user’s personal information to a third third party with user’s consent as set forth below:

Third party to be provided with user personal information Purpose Personal information to be provided Term of retention
Event or Marketing Promotion Providers
[Service Provider]
Provision of services regarding events such as prize delivery, managing winners, etc. Name, mobile phone number, address, email address Until the end date of event

Part 5 Outsourcing the handling of personal information

1. The Company entrusts an outside specialty company with handling of personal information for smooth service performance. For safety of the outsourcing, the Company clearly defines policy regarding personal information handling, confidentiality of personal information, the responsibility of incident, etc. and retains the written agreements between the outsourcing companies.
2. The outsourcing companies and its purpose are as follows:

Outsourcing Company Purpose
SureM Phone Verification
KCB IPIN Verification, Phone Verification
Event or marketing promotion provider
[Service Providers]
Provision of services regarding events such as prize delivery, managing winners, etc.

Part 6 Personal information retention and use period

1. User personal information is completely destroyed and it will not be available for any purpose once a member unregister the service or the Company removes a user’s account as a result of the user is founded to have falsified information
2. User personal information is immediately destroyed once the purpose of collecting and using personal information is fulfilled according to the Part7(1). However, the Company may retain the user personal information for the following period if necessary in accordance with the internal policy of the Company or relevant raw.

Retention Item Relevant raw Retention Period
Records on illegal use Internal policy of the Company 6 month
Records on cancellation of contracts or subscription Act on Consumer Protection in Electronic Commerce 5 years
Records on payment and supply of goods 5 years
Records on consumer complaints or resolution of disputes 3 years
Records on visits Protection of Communications Secrets Act 3 month
Records on personal identification Act on Promotion of Information and Communications Network Utilization and Information Protection, Etc. 6 month

Part 7 Procedure for and method of destroying personal information

1. In principle, user personal information is immediately destroyed once the purpose of collecting and using personal information is fulfilled
2. Procedure for destroying personal information
(1) The information users entered to sign up for membership is immediately destroyed after the purpose is fulfilled. The personal information is not be used for purposes other than retention, unless otherwise stipulated by law.
3. Method of destroying personal information
(1) Personal information printed on paper is shredded using a shredder or incinerated, and Personal information saved in an electronic file is deleted using a technical method ensuring that records cannot be recovered.

Part 8 The rights of users and the method of exercising them

1. The Company allows only a person of fourteen (14) years or more to register. In principle, the Company does not collect personal information of children in order to protect personal information of a child of less than fourteen (14) years
2. Users may, at any time, confirm or modify their own registered personal information and request the cancellation of membership or suspension of the processing of personal information. In such case, some or all of the service use can be restricted
3. Users may confirm and correct their own personal information in “My Profile”. Users also cancel membership at any time through “Unregister”, and all user information will be deleted once user unregisters the service. According to the relevant raw, however, the personal information will be possessed for a certain period if necessary in accord with Part6(2) 4. If users request the correction or deletion of their personal information, the Company will take immediate action once completes the verification of user. In addition, based on the Part20 (1) of Terms and Conditions of Service, the personal information manager of the Company may destroy the user information.
5. . If user request that errors in personal information be corrected, the personal information is not used or provided until the correction is completed. Also, if incorrect personal information has already been provided to a third party, the correction is immediately sent to the third party.
6. The Company processes cancelled or deleted personal information in accordance with the request of the user as stipulated in "6. Personal information retention and use period" and does not view or use it for other purposes.

Part9. Technical/administrative measures to protect personal information

In handling user personal information, the Company is taking the following technical/administrative measures to ensure safety and prevent the loss, theft, leak, alteration, or damage of personal information.
1. Technical measures.
(1) The Company is taking every measure to prevent the leak or damage of member personal information due to hacking or computer viruses. The Company frequently backs up personal information and data and uses the latest vaccine programs to prevent personal information or data from being leaked or damaged. It also uses encrypted communication to ensure safe transmission of personal information over the network. The Company uses a firewall to prevent unauthorized access from outside and technical devices for systematically maintaining security.
2. Administrative measures
(1) Only authorized persons in the Company are permitted to handle personal information. Separate passwords are assigned to them and updated periodically, and they receive frequent training focusing on compliance with the DONTALK privacy policy.
(2) The Company assigns a personal information manager for protection of personal information to check that the DONTALK privacy policy is carried out. If problems are uncovered, the Company immediately makes changes and corrects them. However, the Company cannot be held liable for any problems caused by the leak of personal information due to the user's negligence or Internet problems.

Part 10. Link Site

The Company may provide a link to website or materials of another company for a member. In this case, the personal information protection policy of the relevant site is unrelated to DONTALK and, thus, the member is requested to review the policy of such site.

Part 11. Personal information manager

The company designates the personal information manager to handle the opinions and complaints regarding the user personal information.

Personal information manager Customer service
Company BRINICLE,Inc BRINICLE,Inc
Name Hakhee Lee Junghwa Ahn
Title COO Manager
Telephone 82-2-6959-3070 82-2-6959-3071
E-Mail privacy@brinicle.com contact@brinicle.com

(1) Personal information manager working hour
- Weekdays: 09:00~18:00
- Closed on weekends and holidays
(2) Additional organization for reporting invasion of privacy or counseling
- Privacy Invasion Reporting Center (http://www.118.or.kr / 118)
- Cybercrime Investigation Department, Supreme Prosecutors’ Office (http://www.spo.go.kr / 02-3480-2000)
- Cyber Terror Response Center, National Police Agency (http://www.ctrc.go.kr / 02-392-0330)

Part 12. Obligation to notify

This privacy policy is effective on October 15, 2013. If content is added to the current privacy policy or its content is deleted or modified, the Company will indicate the change on the "Notice" in the DONTALK service at least seven days before the effective date.
- Date of notification: October 7, 2013
- Effective date: October 15, 2013