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1.	MobiCoins¡¯ Privacy Policy
MobiCoins (hereinafter ¡°MobiCoins¡±) uses and provides the user¡¯s personal information based on the user¡¯s consent, and actively guarantees the user¡¯s right(the right to control one¡¯s own personal information) under the service of Thefor, Inc.
MobiCoins complies with applicable laws, personal information protection regulations and guidelines, which must be obeyed by information communication service providers.
MobiCoins¡¯s Privacy Policy refers to guidelines on protecting the user¡¯s valuable personal information which MobiCoins is required to comply with, in order to ensure that users use its services with confidence.
This Privacy Policy is applied to MobiCoins Services (hereinafter ¡°MobiCoins¡± or ¡°the Services¡±).

2. Collection of Personal Information
MobiCoins collects the minimum personal information to provide the Services.
The following minimum personal information is collected when the user signs up for the service or while the user uses the Services, through the home page, individual applications and programs, and etc.

[MobiCoins Wallet] Required
Phone number, contact information stored in the device¡¯s Contacts (third party phone numbers, names), user name (nickname), profile picture, Email, password, name (nickname), profile picture, MobiCoins Service Friend List, MobiCoins phone number, Wallet address,
Date of birth, gender, nationality and city.

[Customer Service]
Phone number, MobiCoins Account (ID, Email, Wallet Address and Coin amount)
Some services may collect personal information additional (optional information) to those collected commonly by MobiCoins Account upon the user¡®s consent in order to provide specialized services.

What is optional information: Additional information which needs to be collected to provide more specialized services. (Users still can use the Services without agreeing to provide additional information.)

The method of personal information collection is as follows.
When collecting personal information, MobiCoins informs the fact to the user in advance and asks for an agreement. Personal information is collected using the following method:
	The user agrees to the collection of personal information and enters relevant information when signing up for a service or while the user uses the Services.
	Personal information is provided through affiliated services or groups.
	Personal information is provided via the home page, email, fax, phone, etc. during customer service calls.
	The user participates in online and/or offline events.
The following personal information may be collected while the user uses the Service.
Device information (OS, screen size, device ID), IP address, cookies, date of visit, improper usage record and service usage record may be automatically created and collected while the user uses the PC web or mobile web & apps.
MobiCoins receives the following personal information from third parties through partnership agreements or affiliation with other services.
MobiCoins receives voucher information (including expiration date) to provide the online service and transaction history (purchase goods and cash & coin use) to suggest customized contents to the user.
In addition, MobiCoins receives the result of user verification collected while users sign up for MobiCoins (date of birth, CI, region, Customer service provision history and etc,.) for the purpose of user identification with MobiCoins Services.


3. Use of Personal Information
Personal information is used to manage membership, to provide and improve Services and to develop new service.
Personal information is collected to the minimum extent required to provide Services when the user signs up for the service or while the user uses the Services, through the homepage, individual applications and programs, and etc
	Member identification, confirmation of the user¡¯s will to sign up, user and age verification, prevention of improper usage
	Confirmation of consent of a legal representative in case of collecting personal information of children under 14 years of age, verification of identity of the legal representative thereafter
	Message transmission between friends, friend registration and suggestion
	Notification of activities to friends, user search & sign-up
	Analysis and service provision based on demographic characteristics
	Location search service between users and user identification. 
	New service development, provision of various services, inquiry and complaint handling, delivery of notifications
	Sending contents, etc. to the users of paid services, or shipping / payment
	Prevention and sanction of any act that interrupts normal service operation of the service
	Confirmation of participation in events; marketing and advertising purposes
	Voice-command recognition and customized service
	Statistics based on service usage record, frequency of visit and service use; development of service environment to protect privacy; development of customized services; service improvement.
4. Provision of Personal Information
MobiCoins does not provide personal information to any third party without your consent or unless demanded by applicable laws. MobiCoins entrusts the following personal information to a third party to connect MobiCoins Services to third-party services.
MobiCoins does not disclose a user's personal information to third parties without the user's prior consent.
However, personal information may be provided to third parties upon the user's consent within the extent necessary for the user to use the services of MobiCoins's partner companies.
Users can ask customer service center for special request to check the status of the provision of his or her own personal information for individual services.
The following affairs are entrusted to third parties to provide seamless Services.
MobiCoins provides personal information to third parties in the course of entrusting some parts of the affairs required for service provision. MobiCoins also supervises and monitors the entrusted parties to prevent any violation of applicable laws.

5. Destruction of Personal Information
The user's personal information is to be destroyed immediately once the purpose of the collection and use of personal information is fulfilled. The procedure and method of destruction is as follows:
Personal information stored in electronic file formats is to be deleted using technical means which make the information unrecoverable. Personal information printed on paper records, printed matters and documents is to be destroyed through shredding or incineration.

However, the following personal information is destroyed after being kept for a certain period in accordance with internal policies.
1) The following information is destroyed after being kept for one year from the date of the user¡¯s unregistration from the service.
-MobiCoins Account and the email address to which a unregistration notification email was sent to send notifications and handle customer service inquiries after unregistration
- Improper usage records
2) MobiCoins separately stores or deletes the personal information of its members who have not used the Services for one year or longer in accordance with the expiration system of personal information. The stored information will be destroyed after being kept for four years.
Other personal information which are required to be retained by law and their respective provisions are as follows: 
*Act on the Consumer Protection in Electronic Commerce, etc., Framework Act on National Taxes, Electronic Financial Transactions Act and Protection of Communications Secrets Act.


6. Others
MobiCoins is committed to protecting the user¡¯s rights. The user may view and edit his or her personal information at any time (through a legal representative for users aged 14 or under), and may at any time withdraw his or her agreement on personal information provision or unregister from the service. Users may unregister from the service or withdraw his or on personal information provision by clicking the Unregister button in the Services, or contact the Customer Service via in writing, or through phone or email and unregistration will be completed within 72 hours. If a user requests the revision of personal information, the user's information is not to be used or provided until the revision is completed. In addition, MobiCoins also provides a page containing information on the user¡¯s right protection in accordance with the Privacy Guidelines for Online Customized Ads. Sometimes cookies are used to provide PC-based services. Cookies are used to support a faster and more convenient use of websites and to provide customized services. 

[What is a Cookie] 
A cookie is a small piece of text file usually set by the web server, sent from a website and stored in a User's computer hard disk while the user is browsing that website.

[Purpose of use of cookie]
MobiCoins uses cookies which save and retrieve user information in order to provide personal customized service. When a user visits the website, the website server reads cookies stored on the user's device to maintain environment settings and customized services. Cookies help the user use the website easily and conveniently by finding out the user's preferences. Also, they are used to provide customized marketing information by tracing the number of visiting to the website and use patterns.

[Rejecting a cookie]
Cookie does not collect personally identifiable information automatically or actively, and a user has an option for setting a cookie. Hence, a user may allow all cookies by setting the option on the web browser; whenever a cookie is stored, the confirmation thereof shall be completed; or, otherwise, a user may reject the storage of all cookies. Provided, however, when a user rejects the storage of a cookie, then the user may have some difficulties in using a service.

[Allow or Don't Allow Cookies]
	1) Internet Explorer
Select "Tool" menu at the top of the browser. > "Internet Options" > "Personal Data" Tab > Settings
	2) Chrome
Select "Settings" menu at the top right side of the browser. > "Show advanced settings" > In the "Privacy" section, click "Content settings". > Cookies
MobiCoins complies with the General Data Protection Regulation (GDPR) as well as the domestic laws of each member country.
The following may apply when MobiCoins provides services to users in EU countries.

[Purpose and Basis of Personal Information Processing]
MobiCoins uses personal information collected from users only for purposes specified in "3. Use of Personal Information", informs users prior to any use thereof and asks for agreement.
In addition, MobiCoins may process personal information in accordance with applicable laws including GDPR in any of the following cases:
	When agreed by the data subject
	For signing and fulfilling a contract with the data subject
	For legal compliance
	When personal information processing is necessary for the material benefit of the data subject
	For the pursuit of legitimate interests of the company (except for cases where the benefits, rights or freedom of the data subject is more important than that of the company)

[Guarantee of Users' Rights in EU Countries]
As described in "MobiCoins protects your personal information", MobiCoins is committed to protecting your privacy.
In accordance with applicable laws including GDPR, a user may request that his or her personal information be transferred to another manager, and refuse the processing of his or her information. In addition, a user has a right to file a complaint with data privacy protection authorities.
MobiCoins may also use personal information for marketing purposes such as event promotion or advertisements, for which MobiCoins obtains a prior agreement. A user may withdraw the agreement at any time if he or she does not want it. A user may contact the Customer Service of any request related to the above via paper, phone or email. The request will be handled in a proper and timely manner. When a user requests for the correction of personal information, the concerned information will not be displayed until correction is completed.
Questions regarding Privacy Protection
For any inquiries, complaints, feedback or other matters related to personal information protection which arise while you use the Services, please contact the Privacy Protection Officer or the responsible department. MobiCoins will do its best to listen to you and promptly answer any questions you may have.

Privacy Protection Department 
	Department: Privacy Protection Part: seohyun@isea.center
	Contact: Customer Service [Tel: +1-646-330-5719]
Please make inquiries to the following organizations if you need to report or consult in regards to the violation of personal information.


Amendment to the Privacy Policy
MobiCoins may amend its Privacy Policy to reflect any legal or service changes. MobiCoins will notify such amendment in advance, and the amended Privacy Policy will take effect seven days after the notification of the amendment
However, any major change in user rights, including personal information items to be collected and the purpose of collecting thereof, will be notified at least 30 days in advance.

	Announcement Date: Oct 3, 2018
	Effective Date: Oct 10, 2018