funpik

This Privacy Policy (“Privacy Policy”) details the personal data IDESIGNLAB Co., Ltd. (“FunPik”, ”IDESIGNLAB”, “we”, “us” or “our”) receives about you, how we process it and your rights and obligations in relation to your personal data. IDESIGNLAB Co., Ltd. a company registered at Room 303, Lime House, 24, Jandari-ro 3-an-gil, Mapo-gu, Seoul, Republic of Korea is the data controller for the purposes of the General Data Protection Regulation (“GDPR”) and any relevant local legislation (“Data Protection Laws”).

By using or accessing the Service, you agree to the terms of this Privacy Policy. Capitalized terms not defined here have the meanings set forth in the terms and conditions (the “Terms and Conditions”), located at http://funpik.net/ We may update our Privacy Policy to reflect changes to our information practices. If we do this and the changes are material, we will post a notice that we have made changes to this Privacy Policy on the Website for at least 7 days before the changes are made, and we will indicate the date these terms were last revised at the bottom of the Privacy Policy. Any revisions to this Privacy Policy will become effective at the end of that 7 day period.

This Privacy Policy (“Privacy Policy”) details the personal data IDESIGNLAB Co., Ltd. (“FunPik”, ”IDESIGNLAB”, “we”, “us” or “our”)

receives about you, how we process it and your rights and obligations in relation to your personal data. IDESIGNLAB Co., Ltd. a company

registered at Room 303, Lime House, 24, Jandari-ro 3-an-gil, Mapo-gu, Seoul, Republic of Korea is the data controller for the purposes of

the General Data Protection Regulation (“GDPR”) and any relevant local legislation (“Data Protection Laws”).

By using or accessing the Service, you agree to the terms of this Privacy Policy. Capitalized terms not defined here have the meanings set

forth in the terms and conditions (the “Terms and Conditions”), located at http://funpik.net/ We may update our Privacy Policy to reflect changes

to our information practices. If we do this and the changes are material, we will post a notice that we have made changes to this Privacy Policy

on the Website for at least 7 days before the changes are made, and we will indicate the date these terms were last revised at the bottom

of the Privacy Policy. Any revisions to this Privacy Policy will become effective at the end of that 7 day period.

When you use the Service, you will submit information. We will also generate data about your use of our Services including your

engagement in educational activities on the Service. We also collect technical data about how you interact with our Services;

for more information, see Cookies.

When you use FunPik, we use a service named Amplitude to log your in-app activities, e.g. button clicks and etc. Amplitude stores

and analyzes your usage data to help us make your FunPik experience better.

We may contact you to participate in product research activities. These may include surveys, interviews, and other types of feedback

sessions. When you participate in these research activities, the information you provide will be used to test, improve, and develop

our products. We will record the video, audio and text transcriptions of this feedback together with any additional contact information

you provide and will retain this data for two years.

To support and enhance the Service, we work with a variety of third party advertising networks, marketing analytics service providers and

website analysis firms, such as Google, Facebook (collectively, “Third Party Advertising Service Providers”). These Third Party Advertising

Service Providers collect and use personal data about your visits to and use of the Website and mobile Application, as well as other websites

in order to serve you with advertisements and content tailored to meet your preferences and likely interests or better understand ad

effectiveness. Aggregate demographic and interest data will also be used for market research purposes.

You can opt-out of receiving personalized ads from advertisers and ad networks that are members of the Network Advertising Initiative (“NAI”)

or who follow the DAA Self-Regulatory Principles for Online Behavioral Advertising using their respective opt-out tools. The NAI's opt-out tool

can be found here http://www.networkadvertising.org/choices/ and the DAA's opt out tool can be found here http://www.aboutads.info/choices/.

In addition, your mobile devices may offer settings that enable you to make choices about the collection, use, or transfer of mobile app information

for online behavioral advertising (for example, Apple iOS’ Advertising ID and Google Android’s Advertising ID). Please note that opting out does not

prevent the display of all advertisements to you.

FunPik may occasionally send you service related and product change announcements through the general operation of the Service.

We will send you reminder notifications to support the FunPik teaching methodology by reinforcing the learning cadence and help maintain

your learning streak. We process your data to help provide you with the Service and offer personalized features, to understand and improve

our Service and to keep our Service safe and secure.

FunPik may use or share anonymous data collected through the Service, including Activity Data without limitation. As a business, it is critical

that we perform our contract with you with the best service possible, and it is in our legitimate interests to perform these processing functions

and to enable service e-mails by default to keep your data secure and provide our Service.

We may also use your contact information to send you notifications regarding new services, offers and promotions offered by FunPik if you

affirmatively consent to receive such communications.

When you register with FunPik, some of your information is made public and available at various locations including FunPik App.

This will include the data from your Profile and Account (Nickname, Location, Membership status, XP, Ranking, Daily Progress, Level, Skills).

Your FunPik account email address is not shown publicly.

Profile information is used by FunPik to be presented back to and edited by you when you access the Service and to be presented to other users.

FunPik uses this information to provide you with support, to send you essential notifications, to enforce our terms, conditions and policies,

to communicate with you, to administer the Services, and for internal operations, including troubleshooting, data analysis, testing, research,

statistical, and survey purposes. FunPik’s Terms and Conditions provide the contractual lawful basis for these processing activities.

FunPik shares your personal data only when it is necessary to offer the Service, legally required, or permitted by you.

We will be required to access and disclose personal data in response to lawful requests, such as subpoenas or court orders, or in compliance

with applicable laws. Additionally, we will access and share account or other personal data when we believe it is necessary to comply with law,

to protect our interests or property, to prevent fraud or other illegal activity perpetrated through the Service or using the FunPik name,

or to prevent imminent harm. This will include accessing and sharing personal data with other companies, lawyers, agents or government agencies.

If the ownership of all or substantially all of the FunPik business, or individual business units or assets owned by FunPik that are related to the Service,

were to change, your personal data will be transferred to the new owner. In any such transfer of information, your personal data would remain

subject to this section. FunPik will share aggregate or anonymous data collected through the Service, including Activity Data, for purposes such as

understanding or improving the service.

You can manage your account settings at FunPik app.

You also have the following rights in relation to the personal data we hold about you, unless provided otherwise by local law:

- To request access to, or erasure of, the personal data we hold about you.
- To request us to restrict the processing of the personal data we hold about you.
- To object to us processing personal data relating to you.
- Where you have given us consent to process your personal data, you have the right to withdraw that consent at any time.
- To export the personal data you have provided to FunPik in a format that can be transferred electronically to a third party.
- To delete your account with FunPik by following the instructions available through the Service.

FunPik will retain your data until your account is deleted, after which point we will retain anonymous data collected through the Service,

including Activity Data, which may be used by FunPik and shared with third parties in any manner.

Please note that some of these rights are not absolute. In some cases, we may refuse a request to exercise particular rights if complying with

it meant that we are no longer able to meet our contractual obligation to provide you with particular products and services.

We will keep you informed as to the actions that we can take when you make your request.

FunPik protects personal information in accordance with Republic of Korea laws and regulations, and in the event of a complaint,

you can request a resolution to the following organizations.

- www.kopico.go.kr
- privacy.kisa.or.kr
- www.spo.go.kr
- cyberbureau.police.go.kr

If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your

request in accordance with applicable law. In some cases our ability to uphold these rights for you may depend upon our obligations to process

personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing

is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.

FunPik would like to inform you that anytime you click on links (including advertising banners), which take you to third party websites,

you will be subject to the third parties’ privacy policies.

Please review the privacy policies of each website you visit to better understand their privacy practices.

Our Services contain links to other sites operated by third parties. FunPik does not control such other sites and is not responsible for their content,

their privacy policies, or their use of personal data, including any personal or financial information collected by our third party payment processor

to process payments for in-app purchases. FunPik’s inclusion of such links does not imply any endorsement of the content on such sites or of their

owners or operators except as disclosed on the Services. Any information submitted by you directly to these third parties is subject to that

third party’s privacy policy.

When you use the Service, you will submit information. We will also generate data about your use of our Services including your engagement in educational activities on the Service. We also collect technical data about how you interact with our Services; for more information, see Cookies.

When you use FunPik, we use a service named Amplitude to log your in-app activities, e.g. button clicks and etc. Amplitude stores and analyzes your usage data to help us make your FunPik experience better.

To support and enhance the Service, we work with a variety of third party advertising networks, marketing analytics service providers and website analysis firms, such as Google, Facebook (collectively, “Third Party Advertising Service Providers”). These Third Party Advertising Service Providers collect and use personal data about your visits to and use of the Website and mobile Application, as well as other websites in order to serve you with advertisements and content tailored to meet your preferences and likely interests or better understand ad effectiveness. Aggregate demographic and interest data will also be used for market research purposes.

You can opt-out of receiving personalized ads from advertisers and ad networks that are members of the Network Advertising Initiative (“NAI”) or who follow the DAA Self-Regulatory Principles for Online Behavioral Advertising using their respective opt-out tools. The NAI's opt-out tool can be found here http://www.networkadvertising.org/choices/ and the DAA's opt out tool can be found here http://www.aboutads.info/choices/.

In addition, your mobile devices may offer settings that enable you to make choices about the collection, use, or transfer of mobile app information for online behavioral advertising (for example, Apple iOS’ Advertising ID and Google Android’s Advertising ID). Please note that opting out does not prevent the display of all advertisements to you.

FunPik may occasionally send you service related and product change announcements through the general operation of the Service. We will send you reminder notifications to support the FunPik teaching methodology by reinforcing the learning cadence and help maintain your learning streak. We process your data to help provide you with the Service and offer personalized features, to understand and improve our Service and to keep our Service safe and secure.

FunPik may use or share anonymous data collected through the Service, including Activity Data without limitation. As a business, it is critical that we perform our contract with you with the best service possible, and it is in our legitimate interests to perform these processing functions and to enable service e-mails by default to keep your data secure and provide our Service.

We may also use your contact information to send you notifications regarding new services, offers and promotions offered by FunPik if you affirmatively consent to receive such communications.

When you register with FunPik, some of your information is made public and available at various locations including FunPik App. This will include the data from your Profile and Account (Nickname, Location, Membership status, XP, Ranking, Daily Progress, Level, Skills). Your FunPik account email address is not shown publicly.

Profile information is used by FunPik to be presented back to and edited by you when you access the Service and to be presented to other users.

FunPik uses this information to provide you with support, to send you essential notifications, to enforce our terms, conditions and policies, to communicate with you, to administer the Services, and for internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes. FunPik’s Terms and Conditions provide the contractual lawful basis for these processing activities.

FunPik shares your personal data only when it is necessary to offer the Service, legally required, or permitted by you.

We will be required to access and disclose personal data in response to lawful requests, such as subpoenas or court orders, or in compliance with applicable laws. Additionally, we will access and share account or other personal data when we believe it is necessary to comply with law, to protect our interests or property, to prevent fraud or other illegal activity perpetrated through the Service or using the FunPik name, or to prevent imminent harm. This will include accessing and sharing personal data with other companies, lawyers, agents or government agencies.

If the ownership of all or substantially all of the FunPik business, or individual business units or assets owned by FunPik that are related to the Service, were to change, your personal data will be transferred to the new owner. In any such transfer of information, your personal data would remain subject to this section.

FunPik will share aggregate or anonymous data collected through the Service, including Activity Data, for purposes such as understanding or improving the service.

You can manage your account settings at FunPik app.

You also have the following rights in relation to the personal data we hold about you, unless provided otherwise by local law:

- To request access to, or erasure of, the personal data we hold about you.
- To request us to restrict the processing of the personal data we hold about you.
- To object to us processing personal data relating to you.
- Where you have given us consent to process your personal data, you have the right to withdraw
that consent at any time.
- To export the personal data you have provided to FunPik in a format that can be transferred
electronically to a third party.
- To delete your account with FunPik by following the instructions available through the Service.

FunPik will retain your data until your account is deleted, after which point we will retain anonymous data collected through the Service, including Activity Data, which may be used by FunPik and shared with third parties in any manner.

Please note that some of these rights are not absolute. In some cases, we may refuse a request to exercise particular rights if complying with it meant that we are no longer able to meet our contractual obligation to provide you with particular products and services. We will keep you informed as to the actions that we can take when you make your request.

FunPik protects personal information in accordance with Republic of Korea laws and regulations, and in the event of a complaint, you can request a resolution to the following organizations.

- www.kopico.go.kr
- privacy.kisa.or.kr
- www.spo.go.kr
- cyberbureau.police.go.kr

If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law. In some cases our ability to uphold these rights for you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.

FunPik would like to inform you that anytime you click on links (including advertising banners), which take you to third party websites, you will be subject to the third parties’ privacy policies.

Please review the privacy policies of each website you visit to better understand their privacy practices.

Our Services contain links to other sites operated by third parties. FunPik does not control such other sites and is not responsible for their content, their privacy policies, or their use of personal data, including any personal or financial information collected by our third party payment processor to process payments for in-app purchases. FunPik’s inclusion of such links does not imply any endorsement of the content on such sites or of their owners or operators except as disclosed on the Services. Any information submitted by you directly to these third parties is subject to that third party’s privacy policy.

Email membership	Nicknames
	Email addresses
	Passwords
Google Easy Subscription	Email addresses
Apple Easy Subscription	Email addresses
Facebook Easy Subscription	Email addresses
Profile Settings	Location
	Year of birth
	Gender
	Nicknames

Tech Specs	Device type
	Operating system
	Script errors
	IP address

Learning Activity	Learning purpose
	Initial Korean proficiency level (Tier)
	Current Korean proficiency level (Tier)
	Expected TOPIK grade
	Exam schedule
	Study time
	Session progress
	Answers
	Recorded voice data
	Learning works have written by users

Email membership	Nicknames
	Email addresses
	Passwords
Google Easy Subscription	Email addresses
Apple Easy Subscription	Email addresses
Facebook Easy Subscription	Email addresses
Profile Settings	Location
	Year of birth
	Gender
	Nicknames

Tech Specs	Device type
	Operating system
	Script errors
	IP address