Last Updated : 31 March, 2023
You may have specific privacy rights in your state or region. In the United States, residents of California and other states have specific privacy rights. Residents of the European Economic Area (“EEA”), the UK, the Republic of Korea, and other jurisdictions also have specific rights. Residents of each country can find information below.
1. Information we collect
A. Information you provide
l When you use Connecting, we collect personal information that you provide to us. This includes: Account Information. When you set up an account, we may ask you to provide information about yourself, including your name, phone number, email address, gender, date of birth, bios, profile pictures, interests. If you use our Products as a guest without setting up an account, we may ask you to provide your phone number. To add certain content, like pictures or videos, you may allow us to access your camera or photo album. You can add or remove whenever you want.
B. Information we get when you use our products
l When you use our Products, we collect additional personal information based on your activity and other personal information you might choose to provide. This includes:
l Usage and Activity information. This includes information about chat & voice rooms you speak in, Posts & Reply you create and Images & Recorded voice file you upload. It also includes who you send a friend request, what kind of person or posts you’re interested in, score you made and other types of works published on the Services.
l Conversations. Connecting records conversations in all chat & voice rooms and also messages you send to or receive from other users so we can investigate any complaints regarding violations of our Community Guidelines or our Terms of Service, or otherwise illegal or illicit activity. This is part of our commitment to you under these Terms of Service to provide the safest possible space for your conversations, and to combat illegal and harmful conduct and content. We will retain the recording as long as reasonably necessary to investigate the potential violation.
l Communications. If you contact us directly, we may receive additional information about you. For example, when you contact us for support, we will receive your nickname, email address, unique ID, title, the contents of a message or attachments that you may send to us, and other information you choose to provide.
l Payment and Transaction Information. If you subscribe or buy virtual “Diamonds(Virtual Item)”, your purchase will be made through your Apple or Google account. Connecting does not collect financial or billing information from you in relation to such a transaction. Please review Apple or Google’s terms and notices to learn more about how your data is processed. We do keep a record of the purchases you make, the time of your purchases, and the amount you spend in order to credit your account with the correct value.
l Log Data and Device Information. We may collect information from and about the devices you use. In particular, we may collect information about log-in authentication attempts and successful authentications, your hardware and software, such as the hardware model, operating system version, device memory, unique application identifiers, apps installed, unique device identifiers, browser type, and information about your wireless and mobile network connections, such as mobile phone number, service provider, IP address, and signal strength.
C. Information from third parties
l Social Media Information. If you use Twitter, Instagram, or any other social media accounts when you signup, we may receive information from those other services. The information we receive will depend on the privacy settings on those other services.
2. How we use the information we collect
We use the information we collect:
A. To administer your account and provide our services to you
l Create and manage your account
l Provide you with customer support and respond to your requests
l Communicate with you about our services
l Personalize pricing, offer discounts and other promotions, and complete your transactions
l Administer sweepstakes and contests
B. To help you connect with other users
l Recommend you to other members and recommend other members to you
l Show members’ profiles to one another
l Enable members to search for and connect with members
C. To provide new Connecting services to you
l Register you and display your profile on new Connecting features and apps
l Administer your account on these new features and apps
D. To provide offers and operate advertising and marketing campaigns
l Perform and measure the effectiveness of advertising campaigns on our services and marketing our services off our platform
l Communicate with you about products or services that we believe may interest you
l Send you various push notifications and text messages
E. To improve our services and develop new ones
l Administer focus groups, market studies and surveys
l Review interactions with customer care teams to improve our quality of service
l Understand how members typically use the services to improve them (for instance, we may decide to change the look and feel or even substantially modify a given feature based on how members react to it)
l Develop new features and services (for example, we may decide to build a new interests-based feature further to requests received from members)
F. To prevent, detect and fight fraud and other illegal or unauthorized activities
l Communicate to individuals who submit a report, including what we’ve done as a result of their submission
G. To ensure legal compliance
l Comply with legal requirements
l Assist law enforcement
We may also aggregate, de-identify, and/or anonymize any information collected through the Services in such a way that we cannot reasonably link information to you or your device. We may use such aggregate, de-identified, or anonymous information for any purpose.
l Provide our service to you: The reason we process your information for purposes A, B and C above is to perform the contract that you have with us. For instance, as you go about using our service to build meaningful connections, we use your information to maintain your account and your profile, make it viewable to other members and recommend other members to you and to otherwise provide our free and paid features to you and other members.
l Legitimate interests: We process your information for purposes D, E and F above, based on our legitimate interest. For instance, we analyze users’ behavior on our services to continuously improve our offerings, we suggest offers we think might interest you and promote our own services, we process information to help keep our members safe and we process data where necessary to enforce our rights, assist law enforcement and enable us to defend ourselves in the event of a legal action. Also we maintain records of user suspensions(addressing violations of our terms of service or our community guidelines) and allow users to provide feedback about our Products, submit questions or request help using our Products.
l Comply with applicable laws and regulations: We process your information for purpose G above where it is necessary for us to comply with applicable laws and regulations and evidence our compliance with applicable laws and regulations. For example, we retain traffic data and data about transactions in line with our accounting, tax and other statutory data retention obligations and to be able to respond to valid access requests from law enforcement. We also keep data evidencing consents members give us and decisions they may have taken to opt-out of a given feature or processing.
3. How we disclose the information we collect
We do not sell personal information about our users. We may, however, disclose that information to:
A. Services we use to market Connecting. When we market our Products we may disclose information to the websites and apps we use to market our Products, including Facebook, Google, Twitter or others.
C. Law enforcement or governmental or non-governmental organizations. If we believe that disclosure is reasonably necessary to comply with a law, regulation or legal request; to protect the safety, rights or property of the public, any person or Connecting; or to detect, prevent or otherwise address illegal conduct, fraud, security or technical issues, we may disclose information to law enforcement agencies, other governmental agencies, or private parties as needed.
D. Our wholly owned subsidiaries and affiliates. If we were to engage in a merger, acquisition, bankruptcy, dissolution, reorganization, or similar transaction or proceeding that involves the transfer of the information described in this Policy, we would disclose your information to parties involved in such a process (for example, a purchaser).
E. Consent. We may also disclose information from or about you or your devices with your permission.
4. Your rights and choices
We want you to be in control of your information, so we want to remind you of the following options and tools available to you:
l Access / Update tools in the service. Tools and account settings can help you access, rectify or remove information that you provided to us and that’s associated with your account directly within the service. If you have any questions on those tools and settings, please contact our customer care team for help.
l Device permissions. Mobile platforms can have permission systems for specific types of device data and notifications, such as phone contacts, pictures, location services, push notifications and advertising identifiers. You can change your settings on your device to either consent or oppose the collection or processing of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain services may lose functionality.
l Uninstall. You can stop all information collection by an app by uninstalling it using the standard uninstall process for your device. Remember that uninstalling an app does NOT close your account. To close your account, please use the corresponding functionality on the service.
l Account closure. You can close your account by using the corresponding functionality directly on the service.
We also want you to be aware of your privacy rights. Depending on where you live, you may have the right to:
l Access/know. You may have the right to request a copy of the information we keep about you, and in certain circumstances to receive this in a portable format. You can exercise your right to access directly within the service by putting in a request.
l Delete/erase. You may request that we delete the personal information we keep about you. You can exercise your right to delete by submitting a request.
l Correct/rectify/update. You can correct most information you provided to us by editing your profile directly in the service. If you believe the information we hold about you is inaccurate, you may contact us to rectify it.
l Object/restrict. You may also have the right to object to or request that we restrict certain processing. To do so, please contact us.
For your protection and the protection of all of our members, we may ask you to provide proof of identity before we can answer the above requests. Keep in mind, we may reject requests, including if we are unable to authenticate you, if the request is unlawful or invalid, or if it may infringe on trade secrets or intellectual property or the privacy or other rights of someone else. If you wish to receive information relating to another member, such as a copy of any messages you received from them through our service, the other member will have to contact us to provide their written consent before the information is released. We may also ask them to provide proof of identity before we can answer the request. Also, we may not be able to accommodate certain requests to object to or restrict the processing of personal information, notably where such requests would not allow us to provide our service to you anymore. For instance, we cannot provide our service if we do not have your date of birth and thus cannot ensure that you are 18 years of age or older.
If you are a resident of Virginia, USA, if we deny your privacy request, you may be able to appeal by contacting us, and explicitly referencing “Privacy Request Appeal.” If you have concerns about the result of your appeal you may contact the attorney general for your state.
In certain countries, including in the European Economic Area and the United Kingdom, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. You can find information about your data protection regulator in the European Economic Area(edpb.europa.eu), and in the United Kingdom(ico.org.uk). The data protection authority you can lodge a complaint with may be that of your habitual residence, where you work or where an alleged infringement took place.
5. How long we keep information
We keep your personal information only as long as we need it for legitimate business purposes (as laid out in Section 2) and as permitted by applicable law. If you decide to stop using our services, you can close your account and your profile will stop being visible to other members. Note that we will close your account automatically if you are inactive for a period of two years. After your account is closed, we will delete your personal information, as laid out below:
A. To protect the safety and security of our members, we implement a safety retention window of three months following account closure, or one year following an account ban. During this period, we keep your information in the event that it might be necessary to investigate unlawful or harmful conducts. The retention of information during this safety retention window is based on our legitimate interest as well as that of potential third-party victims.
B. Once the safety retention window elapses, we delete your data and only keep limited information for specified purposes, as laid out below:
l We maintain limited data to comply with legal data retention obligations: in particular, we keep transaction data for 10 years to comply with tax and accounting legal requirements, credit card information for the duration the user may challenge the transaction and “traffic data” / logs for one year to comply with legal data retention obligations. We also keep records of consents members give us for five years to evidence our compliance with applicable law.
l We maintain limited information on the basis of our legitimate interest: we keep customer care records and supporting data as well as imprecise location of download/purchase for five years to support our customer care decisions, enforce our rights and enable us to defend ourselves in the event of a claim, information on the existence of past accounts and subscriptions, which we delete three years after the closure of your last account to ensure proper and accurate financial forecasting and reporting, profile data for one year in anticipation of potential litigation, for the establishment, exercise or defense of legal claims, and data necessary to prevent members who were banned from opening a new account, for as long as necessary to ensure the safety and vital interests of our members.
l Finally, we maintain information on the basis of our legitimate interest where there is an outstanding or potential issue, claim or dispute requiring us to keep information (in particular if we receive a valid legal subpoena or request asking us to preserve data (in which case we would need to keep the data to comply with our legal obligations) or if data would otherwise be necessary as part of legal proceedings).
6. Cross-border data transfers
Sharing of information laid out in Section 3 involves cross-border data transfers to the South Korea and other jurisdictions that may have different laws about data processing. When we transfer personal information outside of the EEA, the United Kingdom, Switzerland or other countries which data protection laws have been deemed adequate by the European Commission or other competent governmental body, we use standard contract clauses (standard contractual clauses are commitments between companies transferring personal data, binding them to protect the privacy and security of your data) or other appropriate transfer mechanism. We are currently in the process of reviewing transfers to our vendors and associated legal basis further to the recent Court of Justice for the European Union’s ruling on transfers of personal data to the South Korea.
7. No children allowed
Our services are restricted to individuals who are 18 years of age or older. We do not permit individuals under the age of 18 on our platform. If you suspect that a member is under the age of 18, please use the reporting mechanism available on the service.
Because we’re always looking for new and innovative ways to help you build meaningful connections and strive to make sure explanations about our data practices remain up-to-date, this policy may change over time. We will notify you before any material changes take effect so that you have time to review the changes.
9. Additional Information for California residents
California Consumer Privacy Act (“CCPA”).
The CCPA requires us to provide our users who reside in California with the additional notice below.
We collect and disclose for a business purpose the following categories of personal information:
A. Contact Information and Identifiers, including name, alias, online identifiers, IP address, email address, or other similar identifiers.
B. Customer Records, including name, telephone number, and financial information (such as payment and bank account number, collected only by our service provider).
C. Protected Classifications Under California or Federal Law, including age and gender.
D. Commercial Information, including products or services purchased or obtained.
E. Internet or Other Electronic Network Activity Information, including browsing history, search history, and information regarding a user’s interaction with an internet website or application.
F. Audio/Visual Information, including audio, visual, and electronic information.
G. Professional/Employment Information, including job application or resume information if you apply for a job with us.
H. Inferences, inferences drawn from any personal information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, predispositions, behavior, psychological trends, intelligence, abilities and attitudes.
I. Identifiers for Verification, such as your government-issued identification if requested and provided by you, to manage your account, provide the Service, other internal operations and to verify or validate your account.
If you are a California resident, you may exercise the following rights:
A. The right to request a copy of the personal information that we have collected about you in the prior 12 months.
B. The right to request details about the categories of personal information we collect, the categories of sources, the business or commercial purposes for collecting information, and the categories of third parties with which we share information.
C. The right to request deletion of the personal information that we have collected about you, subject to certain exemptions.
California residents can submit deletion and access requests online by clicking here or by emailing us at firstname.lastname@example.org
We do not sell your personal information so no opt-out choice is necessary. What this means is that we do not sell, rent, release, disclose, disseminate, make available, transfer, or otherwise communicate in any way your personal information to another company for monetary or other valuable consideration.
We may disclose your personal information to relevant government regulatory authorities if we believe the disclosure is reasonably necessary to comply with a law, regulation; protect the safety, rights or property of the public, or any person or Connecting; or to detect, prevent or otherwise address illegal conduct, fraud, technical or security issues.
You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations.
An authorized agent may submit an access or deletion request on your behalf by sending a written authorization signed by you to email@example.com. We may still require you to directly verify your identity and confirm that you provided the authorized agent permission to submit the request
If you are a California resident under the age of 18 and you wish to remove content that you publicly posted, you may submit a request by contacting us at firstname.lastname@example.org. Removing the public content does not ensure complete or comprehensive removal of the content or information.
10. How to contact us
By post : 3F, 424 Youngdong dae-ro, Gangnam-gu, Seoul, Republic of Korea, 06174