This Policy (the "Policy") explains the way of treatment of the information which is provided or collected in the web sites on which this Policy is posted. In addition the Policy also explains the information which is provided or collected in the course of using the applications of the Company which exist in the websites or platforms of other company.
('WITHWINGS' or 'Company') is the controller of the information provided or collected in the websites on which this Policy is posted and in the course of using the applications of the Company which exist in the websites or platforms of other company.
Through this Policy, the Company regards personal information of the users as important and inform them of the purpose and method of Company's using the personal information provided by the users and the measures taken by the Company for protection of those personal information.
This Policy will be effective on the January 1, 2019 and, in case of modification thereof, the Company will make public notice of it through posting it on the bulletin board of Company's website or individual notice through sending mails, fax or e-mails).
1. Information to be collected and method of collection
(1) Personal information items to be collected
Personal information items to be collected by the Company are as follows:
• Information provided by the users
The Company may collect the information directly provided by the users.
- Customer feedback and complaint handling
Email, country, Language, Equipment identifier, OS version, App version
- Customized ads in free apps
Access IP, location, Service usage history information
(2) Method of collection
The Company collects the information of users in a way of the followings:
• Feedback email included in app, Banner ad
• provided by partner companies
2. Use of collected information
The Company uses the collected information of users for the following purposes:
• Improvement of existing services and development of new services
• Making notice of function of company sites or applications or matters on policy change
• To make statistics on member’s service usage, to provide services and place advertisements based on statistical characteristics
• To provide information on promotional events as well as opportunity to participate
• To comply with applicable laws or legal obligation
The Company agrees that it will obtain a consent from the users, if the Company desires to use the information other than those expressly stated in this Policy.
3. Disclosure of collected information
Except for the following cases, the Company will not disclose personal information with a 3rd party:
• when the Company disclosing the information with its affiliates, partners and service providers;
- When the Company's affiliates, partners and service providers carry out services such as bill payment, execution of orders, products delivery and dispute resolution (including disputes on payment and delivery) for and on behalf of the Company
• when the users consent to disclose in advance;
- when the user selects to be provided by the information of products and services of certain companies by sharing his or her personal information with those companies
- when the user selects to allow his or her personal information to be shared with the sites or platform of other companies such as social networking sites
- other cases where the user gives prior consent for sharing his or her personal information
• when disclosure is required by the laws:
- if required to be disclosed by the laws and regulations; or
- if required to be disclosed by the investigative agencies for detecting crimes in accordance with the procedure and method as prescribed in the laws and regulations
4. Cookies, Beacons and Similar Technologies
The Company does not collect non-personal aggregate information through 'cookies' or 'web beacons'.
5. User’s right
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 the Company:
• exercise right to access to personal information;
• make corrections or deletion;
• make temporary suspension of treatment of personal information; or
• request the withdrawal of their consent provided before
To do this, contact us using the feedback email function in your app and we will take action without delay: Provided that the Company may reject the request of you only to the extent that there exists either proper cause as prescribed in the laws or equivalent cause.
The Company regard the security of personal information of uses as very important. The company constructs the following security measures to protect the users' personal information from any unauthorized access, release, use or modification
• Encryption of personal information
- Transmit users' personal information by using encrypted communication zone
- Store important information such as passwords after encrypting it
• Countermeasures against hacking
- Install a system in the zone the external access to which is controlled so as to prevent leakage or damage of users' personal information by hacking or computer virus
• Establish and execute internal management plan
• Install and operate access control system
• Take measures to prevent forging or alteration of access record
7. Protection of personal information of children
In principle, the Company does not collect any information from the children under 13 or equivalent minimum age as prescribed in the laws in relevant jurisdiction. The website, products and services of the Company are the ones to be provided to ordinary people, in principle. The website or application of the Company has function to do age limit so that children cannot use it and the Company does not intentionally collect any personal information from children through that function.
8. Modification of Privacy Protection Policy
The Company has the right to amend or modify this Policy from time to time and, in such case, the Company 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. Contact information
The Company designates the following Data Protection Officer (DPO) in order to protect personal information of customers and deal with complaints from customers.