The company specifies and informs users of the company’s Privacy Policy as follows in regard to what purpose and method the personal information provided by the user to the company is being used for, and what measures are being taken to protect personal information. This Privacy Policy may be revised according to the changes in laws, public notices, etc., or the company’s terms of service and internal policies. In case of any revision, the company will post changes on the service screen or notify users.

By accessing or using the company’s service, the user consents to the company collecting, processing, retaining and sharing of the user’s personal information in the manner set forth herein. If the user has concerns about providing information to the company or about that information being used in methods permitted herein, the user shall not use the company’s service. The company’s service is not intended for children under the age of 7, as stipulated in the relevant terms of service. The user shall be at least 7 years old to access and use the company’s service. The company does not knowingly collect personal information from children under the age of 7.

• Items of personal information collected and processed

  The Company may collect and process the following information about the user.

  1. (A) Required

     • - Personal information, such as the user’s email address, name, age, location or gender provided to the company in the form that the user fills out when using the company’s service or opening an account with the company.
     • - Details of the user’s use of the company’s service and the resources accessed by the user, e.g., information about the country where the user is located, the time when the user plays the company’s game or visits the company’s website, or the device the user uses to access the company’s service.
     • - If the user contacts the company or responds to messages and communications sent by the company, then the company may record the content of the communication.
     • - Communication between the user and the company through the company’s social media channels
     • - And, as detailed below, the information which the company collects through cookies and other similar technologies.

  2. (B) Optional

     • - If the user allows the company to communicate with third-party social networks, the company may collect and process personal information about the user as provided to the company by the respective social networks, e.g., name and ID used by the user in the respective social networks, the email address, profile picture and contact list of the user, etc.
     • - The user’s advertising identifier as described below whose use is permitted by the user.

  Advertising identifier

  The company advertises the company’s service on mobile devices. The advertising identifier is a non-persistent, non-personal device identifier such as Android Advertising ID, Apple’s Advertising ID, or IDFA. When the company advertises the company’s service on mobile devices, the company may use the advertising identifier of the user’s device and other information associated with it, which may be held by the company or provided by the company’s advertising network partners, to help the company deliver advertisements that are relevant to the user’s interests and to improve and measure the effectiveness of the company’s advertising campaigns. The user can block the advertising identifier of their device from being used for interest-based advertising, or can reset such advertising identifier by changing their device settings. These settings are different for each device, but if the user is using an Apple device running iOS 7, the advertising identifier settings can be checked in Settings > Privacy & Security > Apple Advertising. If the user is using a Google Android device running Android 2.3 or later, the user can check advertising identifier settings in Settings > Google > Advertising.

  Payment information

  When the user purchases service from the company’s website, the company may collect certain payment information from the user for the company’s payment service provider, but this information is retained temporarily in a way that renders it unreadable by the company. When the user purchases a product through the company’s app (i.e., something the user can purchase on the App Store or Google Play), the company does not collect or retain any payment information from the user.

Advertising identifiers, cookies and similar technologies are used to provide the user with the company’s service and to collect information from the user’s device. These technologies enable the company and the company’s third-party advertising partners to:

• - Approve the user and the corresponding device.
• - Provide interest-based advertisements to the user.
• - Communicate with third-party social networks or platforms (medium selected for communication) through the company’s service.
• - Work with a third party to provide the user with more tailored services, e.g., providing the company’s service in the user’s native language.

The company uses the user’s personal information for the following purposes.

• - As part of the company’s customer service, or to contact the user to send updates about the company’s service, or to send push notifications to the user if the user has agreed to receive notifications from the company.
• - To manage the user’s account and relationship with the company, and to improve the user’s experience when using the company’s service
• - To create reports, analyses or similar services for use by the company for research or business information purposes (e.g., tracking potential problems or trends in the company’s service)
• - To prevent deception, crime, or fraud
• - Or, as otherwise expressly stipulated herein or as required by law.

The company shares the user’s information with third parties (e.g., the company’s group companies or suppliers in the cases specified below) only in the following cases.

• - When consent is obtained from the user, including when consent is given as stipulated herein
• - When it is reasonably necessary to provide service to the user (e.g., when providing the user’s personal information to suppliers which the company uses to perform the company’s service or to communicate with the user)
• - When the user’s identity cannot be personally identified from the relevant information, e.g., when the user’s information is used as anonymous statistical information
• - When the user provides information as part of a competition or otherwise to communicate with the company on the company’s social media channels (e.g., when the user provides a testimonial about the company’s service), the company may post the information the user submits along with their name and country of origin on the company’s website and social media channels.
• - When the company reasonably believes that it is permitted by laws or regulations
• - To comply with the company’s legal obligations, or to enforce or apply the company’s terms of service or other contracts between the company and the user, or to protect the rights, property, or safety of the company, the company’s users or others such as when the company passes on the user’s information to anti-fraud agencies or other organizations charged with preventing crime or fraud.
• - In the event of the company’s sale of assets or corporate restructuring, a change of control in the company or one of the company’s group companies, or preparations for such events. The third party, i.e., the other party to which the company transfers or sells the company’s assets, has the right to continue to use, in the manner stipulated herein, the personal information and other information that the user provides to the company. Except for these cases, the company does not sell or lease user information to a third party.

The company stores the user’s personal information when necessary to achieve the purpose for which the user’s information was collected as stipulated in Article 4 or for the period necessary to provide the service to the user, the company stores the user’s personal information, and will destroy after. If personal information is written on paper, it will be destroyed by shredding the paper document, and if it is stored in the form of an electronic file, it will be destroyed by technical means that make the record unreproducible.

When retention of the user’s personal information is reasonably necessary for the following purposes, the company may retain the user’s personal information even after the user’s account at the company is terminated or after the company ceases to provide service to the user.

• - To comply with the company’s legal obligations
• - To meet statutory requirements
• - To resolve disputes between members
• - To prevent fraud, deception, or abuse of rights
• - Or, to enforce this Privacy Policy or other contracts concluded between the company and the user

For example, although the company may only retain the user’s personal information for up to 5 years to comply with e-commerce laws, the company may decide to retain such personal information longer than that in order to facilitate the achievement of other purposes listed above.

• - The user may at any time withdraw their consent to the collection/use of personal information, to the sharing thereof for outsourced processing of information, etc.
• - The user may request inspection or reporting regarding the following: (i) information the company hold about the user, (ii) the status of use and outsourced processing of personal information, and (iii) the status of consent to such use and outsourced processing. When wishing to request inspection or reporting, please contact the company at the email address set forth in Article 7 below. The company may charge nominal fees for the requests.
• - The company want to make sure that the user’s personal information is kept accurate and up-to-date. If certain information is inaccurate, the user may request the company to change, correct, or delete the inaccurate information by contacting the company at the email address set forth in Article 7 below.
• - The information which the user shares through the company’s service on the social networks or third-party platforms cannot be changed or deleted by the company if it is managed by the social networks or third-party platforms. In addition, if the information the user provides through their use of the company’s service is copied by a third party (e.g., the user’s friend on social networks that the user allows to communicate with the user’s account), the company may be unable to change or delete that information since it is not under the company’s control.
• - The user may request the company not to use their personal information for marketing purposes. If you intend to change your marketing preferences or opt out of receiving marketing information, please contact the company at the email address set forth in Article 7 below.

If you have any inquiries or concerns about anything related to this Privacy Policy, including exercise of your rights, there are several ways you can contact the company:

• 1. You can contact the company through customer service page at https://rhythmlive.jstair.com/.
• 2. You can contact the company via email at help@jstair.com.
• 3. Or, you can send a letter to JStair, 11th floor, Superior Tower, 528 Teheran-ro, Gangnam-gu, Seoul.

For the information collected hereunder, the information controller is J-Stair. The company’s privacy officer can be reached at: help@jstair.com.

If any term of this Privacy Policy is held by a court or other competent authority to be invalid or unenforceable, the other terms of this Privacy Policy will not be affected.

This Privacy Policy is governed and interpreted in accordance with the laws of the Republic of Korea. For any disputes that arise in relation to this Privacy Policy, unless the user selects a court in the user’s home country, the courts of the Republic of Korea shall have exclusive jurisdiction.

The company is always innovating and looking for new ways to improve the company’s service and game. Therefore, in order to reflect the improvements or other changes to the company’s business, the company may revise this Privacy Policy from time to time. The company will endeavor to inform users of any significant changes to this Privacy Policy which the company believes may cause significant disadvantages to them. When opposing all or part of the changes, the user shall immediately stop using the company’s service and close their account opened at the company.