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Privacy & Security

PENTACOMIX Privacy Policy

Last Updated: November 22, 2023

PENTACOMIX (including its affiliates, hereinafter together referred to as "we", "our" or "us") respect your concerns about privacy. This Privacy Policy applies to the personal information we collect through PENTACOMIX application (collectively "Services").

Overview of Privacy Policy

In this Privacy Policy, we describe the types of personal information we process through the Services, how we may use the information, with whom we may share it and the choices available to you regarding use of the information and exercise of your rights.

  1. 1. Data Controllers
  2. 2. Information We Collect
  3. 3. How We Use Information
  4. 4. Information Sharing
  5. 5. Retention
  6. 6. Your Rights
  7. 7. Exercising Your Rights
  8. 8. How We Protect Info
  9. 9. Children's Info
  10. 10. Contact Us
  11. 11. Links to Other Websites
  12. 12. Updates
  13. 13. Regional Disclosures

1. Data Controllers

TRULITE KOREA Ltd. has the controllership for processing personal information and provide Services efficiently and in compliance with applicable law.

In any event, you can contact us in writing at the following addresses:

TRULITE KOREA Ltd.
2-3F, 10, Dosan-daero 54-gil, Gangnam-gu,
Seoul, Republic of Korea.

2. Information We Collect

The following personal information is collected in connection with the Services:

Information you provide directly

When you use our Services, you may provide us with your personal information after being informed of the privacy information at the time of collection. For example:

  • Date of Birth: When you access our Services, we may request your date of birth to verify your age depending on your jurisdiction.
  • Contact information: When a user is considered a child in accordance with applicable law in the user's jurisdiction, we may need the user's name and legal guardian's e-mail address to obtain legal guardian's consent depending on your jurisdiction. Moreover, when you participate in our events or promotions, we may ask for your name, phone number, address, email address and any other information required to deliver prizes and to respond to inquiries.
  • Account information: When you create your own account and login to your account, we may need your nickname, email address and password. Additionally, when you login to a third party account or to your profile with us, we may ask for information such as a nickname or profile picture.
  • Survey information: When you participate in our surveys or opinion polls, we may ask for your name, phone number, gender and any other information that can be reasonably required to conduct surveys or opinions and provide rewards.
  • Customer Service information: To provide responses when you contact our Customer Service, we may collect any information you choose to provide, such as your requests or inquiries.
  • Identifiers: such as a unique personal identifier (such as (i) device identifiers (e.g., cookies, beacons, pixel tags), (ii) mobile ad identifiers and similar technology, (iii) customer number, unique pseudonym, or user alias, (iv) telephone number and other forms of persistent or probabilistic identifiers), online identifier, Internet Protocol address other similar identifiers.

Information about your use of services

In addition to the information you provide, we will collect information about your use of our Services through software on your devices and by other means. We will collect:

  • Service usage information: your interactions with the Services, dates and times of use of the Services and any Service usage information such as reading genre preferences, comments or likes, Coin and Free Passes balances, commercial information including purchase and transaction history, recent views, subscription history, download history, and event, promotion and/or contest participation;
  • Information relating to the organization of contests and/or any promotional operations: date of participation, responses to the contests and nature of the prizes offered;
  • Device and Log Information: Device and Log information such as device model, OS version, IP address, setting of devices, country information based on IP address, URL and network type; and
  • Transaction /Purchase details: we do not collect or process any payment details concerning you (e.g., credit card details). Such information is only collected and processed through Apple's App Store, Google Play Store, and PayPal. The only information that Apple, Google and PayPal may share with us is transaction and purchase details (e.g., transaction number, purchase history). Such information is only processed to validate the transactions.

Information collected through 3rd Party Analytics

Through certain Services, we may collect personal information about your online activities on websites and connected devices over time and across third-party websites, devices, apps and other online features and services. We may use third-party analytics services on the Services. The information we obtain may be disclosed to or collected directly by these providers and other relevant third parties who use the information, for example, to evaluate use of the Services or help administer the Services.

3. How We Use the Information We Collect

We may use the information collected above for the following purposes:

[For Users and Creators]

  • (i) Identify and authenticate you and (ii) administer your account
  • Provide a Service or feature you request, such as to respond to your request, questions and instructions made through the Services;
  • Conduct surveys and analyses necessary for improving the Service;
  • Send you information and prizes for campaigns and events;
  • Processing payment and billing when a user purchases a product or uses a Service that is not free;
  • Provide you with tailored functions such as recommendation based on your age and/or service usage information;
  • Provide you with ads which may include targeted (or interest-based) ads;
  • Send you communications via email or in-product notifications in relation to our Services;
  • Monitor and analyze trends, usage, and activities in connection with our products and services;
  • Create de-identified, anonymized or aggregated information;
  • Deliver and protect Digital Content;
  • Providing age-appropriate content and experiences;
  • Ensure the information security of our Services;
  • Protect against, identify and prevent fraud and other criminal activity, claims and other liabilities;
  • Generate statistical data pertaining to usage of the Services;
  • Ensure and monitor the effectiveness and availability of the services;
  • Comply with and enforce applicable law requirements, our statutory obligations, relevant industry standards and our policies;
  • Validate transaction and prevent fraud and abuse;
  • Respond to your inquiries and send users important notifications when necessary; and
  • Carry out any other purpose described to you at the time the information was collected

4. Information Sharing

We disclose or share personal information about you through the Services as described in the following:

  • Publicly Available Information. Information that you have voluntarily registered to be shared with the public can be seen by anyone, including those who do not have an account. This may include your nickname, profile picture, short bio, social media links, website, other information on your public profile, and any information or content you share with a public audience.
  • Service Providers. We may disclose your information to companies that provide Services on behalf of us, such as companies that help us develop and operate systems for the Service with customer contact centers, as well as customer care activities, advertising, conducting customer satisfaction surveys, billing or that send emails on our behalf.
  • Payment Partners. Payment and purchase information is collected and processed by payment partners for payment processing and anti-fraud purposes.
  • Other Parties When Required by Law. There may be instances when we disclose your information to other parties: to comply with the law or respond to compulsory legal process; to verify or enforce compliance with the policies governing our Services; and to protect our rights, property, or safety.
  • Other Parties in Connection with Transactions. We may disclose your information to a third party as part of an actual or planned merger or transfer, acquisition or sale, or in the event of a bankruptcy.
  • Other Parties with Your Consent. In addition to the disclosures described in this Privacy Policy, we may share information about you with third parties when you separately consent to or request such sharing.
  • Links to Other Websites, Devices, Apps and Features. The Service may provide the ability to connect to other websites, devices, apps and other features, which may operate independently from us and may have their own privacy notices or policies, which we strongly suggest you review.

5. Retention of Personal Information

We take appropriate steps to ensure that we process and retain information about you based on the following logic:

  • at the minimum duration for which the information is used to provide you with a service;
  • as required under law, a contract, or with regard to our statutory obligations (e.g., tax laws); or
  • only for as long as is necessary for the purpose for which it was collected, is processed, or longer if required under any contract, by applicable law, or, in anonymized form, for statistical purposes, subject to appropriate safeguards.

Thus, we will only keep your personal data for as long as we need it for the purposes for which we collect them and to comply with legal, financial, business or reporting requirements. When we no longer need the personal information, we will securely delete or destroy it.

We will store the collected data even thereafter, until the expiration of any legal liability arising therefrom.

6. Your Rights

Your personal information belongs to you. Depending on the jurisdiction in which you reside, you can ask us to provide details about what we've collected, and you can ask us to correct any inaccuracies. The details of your rights are as follows:

Right of access: You have the right to ask us whether or not we are using or storing your personal information. You can also ask us for copies of your personal information.
Right to rectification: You have the right to ask us to rectify information you think is inaccurate. You also have the right to complete information you consider incomplete.
Right to erasure: You have the right to ask us to erase your personal information when we no longer need it, you withdraw consent, your interests outweigh ours, we collected it unlawfully, or we have a legal obligation to erase it.
Right to restrict processing: You have the right to ask us to restrict processing when you challenge accuracy, object to use, we processed unlawfully, or we no longer need it but you need it for legal claims.
Right to object to processing: You have the right to object if we use your personal information for public interest tasks, our legitimate interests, research/statistics, or direct marketing.
Right to data portability: You have the right to ask us, if technically feasible, to transfer your personal information to another organisation or directly provide it to you in an accessible and machine readable way.
Right to withdraw consent: At any time where the processing is based on your consent, without affecting the lawfulness of processing based on consent before such withdrawal.
Right to lodge a complaint: You can lodge a complaint with the relevant supervisory authority if you consider that our processing of your personal information infringes applicable law.

7. Exercising Your Rights and Your Choices

If you want to exercise the above rights or if you would like to submit your request, please contact us as specified in the Contact Us section (section 10 of this Privacy Policy). However, if permitted by law, we may charge you a small fee for providing you with this ability. Subject to applicable law, we may decline to process requests that are unreasonably repetitive, require disproportionate technical effort, jeopardise the privacy of others, or for which access is not otherwise required by local law.

You may access or correct your personal information registered with us at any time via the "My Page".

You may ask us to delete your personal information by deleting your account at any time. Once you delete your account, your account profile and subscription history will be deleted permanently and become unrecoverable. Any tax information submitted to us will be maintained for a period of time, as required by financial laws and regulations.

If you would like to change your preference regarding our communications (including marketing communications), you can change your communication preferences. You can also unsubscribe from our email marketing communications at any time by clicking the "unsubscribe" link on the bottom of the email.

8. How We Protect Personal Information

We take protection of your information seriously and maintain safeguards designed to protect the information we collect in connection with the Services. The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information as it is transmitted to us.

You play an important role in keeping your information secure. You should not share your username or password for your account with anyone. If you have reason to believe that your account is no longer secure, please contact us immediately.

9. Children's Personal Information

The Services are designed for a general audience. If the consent of the parent (or legal guardian) is required to process the child's personal information pursuant to the applicable law, we will process such information upon obtaining consent of the parent (or legal guardian) in accordance with the legally required process.

10. Contact Us

If you have any questions, concerns or inquiries concerning the Policies for handling personal information, you may send them to our personal information management department at: Customer Service.

In any event, you can contact us in writing at the following addresses:

TRULITE KOREA Ltd.
2-3F, 10, Dosan-daero 54-gil, Gangnam-gu,
Seoul, Republic of Korea.

12. Updates to Our Privacy Policy

This Privacy Policy may be updated to reflect changes in our personal information practices with respect to the Service, or changes in the applicable law. We will post a notice on our Service to notify you in advance of material changes to our Privacy Policy and indicate at the top of the notice when it was most recently updated.

This Privacy Policy is effective from November 22, 2023 (effective immediately for new users).

13. Regional Privacy Disclosures

13.1 For U.S. Residents

This section supplements the PENTACOMIX Privacy Policy and applies solely to U.S. residents.

Information we process

  • We may request a date of birth, to verify your ability to access certain features of the Services and to tailor content and advertisements to you.
  • When a child is under 13 years of age, we collect the child's name and parent's e-mail address from the child that are necessary to provide any necessary notice and to obtain parental consent.

Children's Personal Information

Users under the age of 13 are not the primary audience for our service as it relates to the COPPA compliance. We may ask you to provide age-related information in order to help us comply with data protection laws. In particular, we will request your date of birth to determine whether or not you are allowed to benefit from the services or if we have to obtain verifiable parental consent from your parent or relevant holder of parental responsibility before allowing you to access and/or benefit from the services.

13.2 For Consumers Residing in Certain U.S. States

This section supplements the PENTACOMIX Privacy Policy and applies to consumers who reside in jurisdictions where there is a privacy statute.

A. Collection, Use, and Disclosure of Personal Information

(1) Categories of Personal Information We Collect:

We may have collected the following categories of personal information about you in the last 12 months:

  • Identifiers such as name, citizenship, residence address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, and other similar identifiers;
  • Other identifying information, such as social security number, tax ID, tax form;
  • Commercial information, including records of personal property, products or services purchased, obtained, or considered;
  • Internet and other electronic network activity information;
  • Inferences drawn from any of the information identified above to create a profile about you.

(2) Sensitive Personal Information:

Depending on the state in which you reside, we may collect some sensitive personal information about you when you use the Services, such as social security number for tax purposes.

(3) Categories of Sources of Personal Information:

  • From you or your devices, for example, through your use of the Services;
  • Our affiliated companies which provide services on our behalf;
  • Vendors who provide Services on our behalf;
  • Advertising networks;
  • Data analytics providers;
  • Payment partners; and
  • Social media networks.

(4) Business & Commercial Purposes for Collecting Personal Information:

  • Performing Services, including maintaining or servicing accounts, providing customer service, processing orders and transactions;
  • Auditing, counting ad impressions to unique visitors, verifying positioning and quality;
  • Helping to ensure the security and integrity of the Service;
  • Debugging to identify and repair errors;
  • Undertaking internal research for technological development; and
  • Undertaking activities to verify or maintain the quality or safety of a Service or device.

(5) Categories of Third Parties with Whom Personal Information is Disclosed:

  • Our affiliates, subsidiaries and business partners;
  • Vendors who provide services on our behalf;
  • Payment partners;
  • Social networks;
  • Other users or creators;
  • Professional services organisations;
  • Ad networks and analytics providers; and
  • Other third parties when you separately consent to or request such sharing.

We may also disclose your personal information with government entities and third parties in connection with mergers, acquisitions, or bankruptcy.

(6) Categories of Personal Information Disclosed for a Business Purpose:

In the preceding 12 months, we may have disclosed: identifiers, other identifying information, financial information, commercial information, internet and other electronic network activity information, sensory information, and inferences.

(7) Categories of Personal Information Sold & Third Parties:

  • Advertising/marketing cookies and similar information to advertising partners;
  • Identifiers such as device identifiers, online identifiers, and internet protocol address shared with service providers and advertising partners;
  • Internet and other electronic network activity information shared with service providers and advertising partners; and
  • Inferences shared with service providers and advertising partners.

We do have actual knowledge that we have sold personal information of consumers under the age of 16 only with consent.

(8) Categories of Personal Information Shared for Targeted Advertising:

The categories include: advertising/marketing cookies, identifiers, internet and electronic network activity information, and inferences — all shared with service providers, advertising partners, and other vendors to provide the Services.

We do have actual knowledge that we have shared personal information of consumers under the age of 16 only with consent.

B. Consumer Rights

Depending on where you reside, and subject to applicable law and exceptions, you may be entitled to the following rights:

Right to Know: Request disclosure of personal information collected, sold, or shared in the past 12 months.
Right to Data Portability: Request transfer of your personal information in a commonly used electronic format.
Right to Correct: Correct or modify inaccurate personal information.
Right to Delete: Request deletion of personal information we have collected.
Non-Discrimination: We will not discriminate against you for exercising your rights.

Other California Rights:

  • Shine the Light: California residents are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure of personal information to third parties for direct marketing purposes. We do not share personal information with third parties for their own direct marketing purposes.
  • Do Not Track: Some web browsers transmit "do-not-track" signals to websites. We currently do not take action in response to these signals.

To submit an access, deletion, correction, or portability request, contact us as specified in the Contact Us section. We may require that you provide us with your e-mail address to verify your identity. You may also have an authorized agent submit a request on your behalf. You may have the right to appeal a denial of your consumer rights request by Customer Service.

C. Data Retention

We take appropriate steps to ensure that we process and retain information about you based on the following logic:

  • at the minimum duration for which the information is used to provide you with a service;
  • as required under law, a contract, or with regard to our statutory obligations; or
  • only for as long as is necessary for the purpose for which it was collected.

When we no longer need the personal information, we will securely delete or destroy it. We will store the collected data even thereafter, until the expiration of any legal liability arising therefrom.

D. Other Topics

Contact Information: You can contact us by sending an email to the following address: cs@trulite.co