DALCOM SOFT INC. - PRIVACY POLICY

THE INFORMATION GATHERED and USE OF THE INFORMATION GATHERED

Dalcomsoft Inc. (hereinafter referred to as 'company') is fully committed to protecting personal information offered by members for the use of the service (hereinafter referred to as 'service') provided by the company. This Privacy Policy (hereinafter referred to as 'this policy') is subject to change when changes are made to the applicable laws of the Republic of Korea or terms of the company's policy.

Online Privacy Policy of DALCOM SOFT INC contains the following information.

1. COLLECT/USE OF PERSONAL INFORMATION GATHERED

2. PERSONALLY IDENTIFIABLE INFORMATION

3. RETENTION AND USE PERIOD FOR PERSONAL INFORMATION

4. HOW WE DISCARD YOUR INFORAMTION

5. SHARING OF YOUR INFORMATION

6. RIGHTS OF USERS AND LEGAL REPRESENTATIVES AND HOW TO EXERCISE

7. TECHNICAL AND ADMINISTRATIVE PROTECTION MEASURE ON PERSONAL INFORMATION

8. PERSONAL INFORMATION AUTO-COLLECT SYSTEM INSTALLATION / GAME OPERATION AND RIGHT TO OBJECT

9. PERSONAL INFORMATION PROTECTION SERVICE

10. OBLIGATION OF NOTICE

1. COLLECT/USE OF PERSONAL INFORMATION GATHERED

1) Mobile Service

(1) Identify Users on Mobile Service Use

- (Compulsory) ID, Nickname, Password, Mobile Phone Contact Number, Email Address

2) User Consultation

(1) User Identification and Documentary Evidence

- (Compulsory) Email Address

- (Optional) ID, Full Name, Nickname, Mobile Phone Contact Number, Mobile Device Information, Any form of identification (Passport, etc), Google Account, Gender, Address, Phone Number, Mobile Service Provider Information

3) Event and Service Marketing

(1) New Service and Event Notice

- (Optional) Mobile Phone Contact Number, Email Address

(2) Delivery Goods, Bill, and Prize To Users

- (Compulsory) Full Name, Mobile Phone Contact Number, Address

(3) Taxes and the public utilities' charge of Event Winners

- (Compulsory) Any form of identification (Passport, etc), Full Name, Address

(4) Check Duplicate Event Participants, In-game advertising System.

- (Optional) ADID / IDFA

4) Automatically Collected and Generated Information For Service Use

- Mobile Device Information, Mobile Service Provider Information, IP, Game Play Record, Service Use History, Abusing or Cheating Action Record, Download History, Payment History

2. PERSONALLY IDENTIFIABLE INFORMATION

1) Personally Identifiable Information stands for Resident Registration Number, Passport Number, Driver's License Numbers, and Foreign Registration Number according to Personal Information Protection Laws which is regulated by “Presidential Decree”.

2) Purpose of collect

(1) To pay taxes and the public utilities' charge of event merchandise or goods or prizes for event winners

3. RETENTION AND USE PERIOD FOR PERSONAL INFORMATION

1) Under your agreement the company will retain your personal information collected until your account is terminated by you or the company. Your personal information will be discarded in an irreversible manner if you request to discard the personal information or do not use the service for certain period of time.

(1) Information Collected For Providing Mobile Service

- Reason: Game or Membership Deletion by a user

- Duration: We will retain the account for thirty days and use account information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

(2) Information Collected For Event and Service Marketing

- Reason and Duration: For Marketing Information Provide, we will retain information for one year. (Information Send History will be stored for six months from the date of send.)

- Reason and Duration: For Event Information and Draw for winners, we will retain information for up to one year.

2) In following cases, personal information will be retained for longer period. Your personal information may also be retained for longer period of time if it is required by the related laws and regulations or consented by you.

(1) Records of contract or cancellation

- Reason: Law on Consumer Protection in Electronic Commerce

- Duration: 5 years

(2) Records of payments and the supply of goods

- Reason: Law on Consumer Protection in Electronic Commerce

- Duration: 5 years

(3) Records of consumer complaints and dispute settlement

- Reason: Law on Consumer Protection in Electronic Commerce

- Duration: 3 years

(4) Connection history, IP information, history of use of the service

- Reason: Protection of Communications Secrets Act

- Duration: 3 months

4. HOW WE DISCARD YOUR INFORAMTION

Your personal information will be discarded in an irreversible manner if you request to discard the personal information or do not use the service for certain period of time. We let you know the process of data discard and how to do this.

1) Discard Process

In case of Game or Membership Deletion by a user, we will retain the account for thirty days and use account information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. After thirty days, we discard the information with not reusable measures.

2) How To Discard

(1) Personal Database Information will be discarded with not reusable measures.

(2) Personal Information on papers will be destroyed by a shredder.

5. SHARING OF YOUR INFORMATION

1) It is our policy not to share your Personal Information with third parties unaffiliated with Dalcomsoft for their own use except in the following circumstances:

(1) With Your Consent. From time to time we may ask for your consent to share Personal Information with third parties. For example, from time to time we may make on behalf of third parties special offers to our users. If you decide to respond to the offer, you would be sharing information with that third party, and may be sharing information with Dalcomsoft simultaneously. When we ask for your consent, it is your choice whether to grant it or not, though certain features, offers or functionalities of the Service may be impaired depending on your choice. If you choose to not give your consent, we will not share your Personal Information with the third party at issue (unless another circumstance applies).

(2) Legal Purposes. We may provide your Personal Information to third parties where we have a good faith belief that doing so is required by law or to cooperate with regulators or law enforcement authorities. We may also provide your Personal Information to third parties in order to protect the rights or property of a third party or Dalcomsoft, including enforcing our Terms.

(3) (Optional) Partial consignments of tasks needed for service convenience, such as gift shipments

- Object : Jellablue

Purpose : Event gift shipment, Prize cash payment, public charge/tax handling

6. RIGHTS OF USERS AND LEGAL REPRESENTATIVES AND HOW TO EXERCISE

Users and their legal representatives can request to view, edit or discard their personal information at any time.

Users and their legal representatives can view, edit or discard their personal information by using edit member information and delete account menu in “SETTINGS” screen.

In case user request for the correction of error in the personal information, the company will not use or provide the personal information until correction is completed. Also, if the false personal information is provided to the third-parties the company will immediately correct the information and notice the third-parties.

As for the personal information of user that requested to be discarded by the user of their representatives. The company will proceed with the procedure as set forth in Clause 3.

7. TECHNICAL AND ADMINISTRATIVE PROTECTION MEASURE ON PERSONAL INFORMATION.

The company has taken technical and administrative measure necessary for securing safety in users’ personal information.

(1) We encrypt your password, account information, e-mail and mobile phone information. If you wish to have all Personal Information about you deleted, you may simply ask for a complete and permanent deletion. For your security, we reserve the right to contact you to confirm and verify your request to correct or delete Personal Information, including the right to request additional information to confirm your identity and that you have the right to correct or delete Personal Information tied to a particular account. If we request additional information and it is not provided to us, we will not act on the request to correct or delete Personal Information.

(2) We always use encrypted network to protect your information.

(3) We have installed security program and regularly upgrades, backup and inspects them, and has installed the system where external access is controlled and monitors and blocks any leakage or damage of personal data due to hacking or computer viruses. While we take reasonable precautions against possible security threats, there is no such thing as “perfect security” on the Internet, so we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. We strongly recommend that you take steps to maximize the security of your Personal Information, such as not sharing your login information and logging out of your account after you are done using our Service.

(1) By submitting your Personal Information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy Statement. Dalcomsoft has only minimum numbers of staffs that handle Users Personal Information.

- Marketing manager, Event manager, Support Team manager, and Dev Team director

- Chief Privacy Officer

- Few employees that inevitably handle Users Personal Information

(2) The Company also provides regular training to such employees to emphasize the importance of complying with the privacy policy.

(3) If a wrong practice on privacy policy is found in the office, we will amend this conduct immediately.

(4) All users should be aware that, when they disclose Personal Information to others through or using the Service, the information being shared may be made publicly available and may be collected and used by others outside of the control of Dalcomsoft. When you disclose about you to others, you do so at your own risk and we are not responsible for protecting the information that you choose to communicate to other users on the Service, or for the actions of other users.

8. THE SYSTEM INSTALLATION OF PERSONAL INFORMATION AUTO-COLLECT / GAME OPERATION AND RIGHT TO OBJECT

1) The company automatically collect the user’s specific information such as a phone number, mobile device identification number, e-mail address, and ADID / IDFA for providing customized mobile service, customer support, in-game advertising system and checking duplicated membership join.

2) All users can disagree with the auto-collect of a phone number, mobile device identification number, e-mail address, and ADID / IDFA. This shall cause the limitation on specific service use.

9. PERSONAL INFORMATION PROTECTION SERVICE

1) CHIEF PRIVACY OFFICER IN DALCOMSOFT

- Name : Daehoon Jang

- Telephone : 82-2-548-9531

- E-mail : privacy@dalcomsoft.com

2) If you need an advice on the privacy policy, you can contact the KISA, SPO Republic of Korea, Cyber Bureau, and more.

[KISA] 118 | URL - http://privacy.kisa.or.kr

[SPO Republic of Korea] 82-2-3480-2000 | URL – http://www.spo.go.kr/eng/index.jsp

[CYBER BUREAU] 182 | URL – https://cyberbureau.police.go.kr

[Personal Information Dispute Mediation Committee] 82-2-2100-2499 | URL – http://www.kopico.go.kr

10. OBLIGATION OF NOTICE

We will notify you of any changes to this Privacy Policy, the reason, effective date and the last updated version of the Privacy Policy by posting a notice on the service page for 7days from the effective date.

For any of matter which are not specified in this “THE INFORMATION GATHERED and USE OF THE INFORMATION GATHERED”, we follow the regulation of “Privacy Policy” of “DALCOM SOFT INC.”