INTRODUCTION
seoulmate, inc., and its affiliates (“seoulmate,” “Company,” “we,” “us,” “our”) are committed to maintaining a safe and trustworthy private community and we understand that privacy and confidentiality are of the utmost importance to our members, applicants, attendees, and other users (collectively, “you,” “your,” or “Users”).
To that end, the policy set forth below (the “Privacy Policy”) describes our information practices when you use our applications (“App(s)”), any websites operated by seoulmate, inc. that link to this Privacy Policy (“Sites”), and certain features thereof, or related services, including those related to RSVPing and/or attending events which are advertised, featured, hosted or otherwise disseminated through the Apps or Sites (collectively, “Service(s)”).
Please click the following links to learn more about our Privacy Policy:
What information we collect.
How we use information we collect.
How we share information.
How we use cookies and respond to Do Not Track signals.
How we respond to users under 18 years of age.
How we secure and retain your information.
How a change in control may affect your information.
How we may update this policy.
How to contact us if you have questions or complaints.
Privacy rights and additional disclosures for EEA and UK individuals.
Privacy rights and additional disclosures for California residents.
WHAT INFORMATION WE COLLECT
Information You Provide in Connection with Membership. To apply for membership to the App, you must provide us with certain information to verify your identity and evaluate your real-world connection to our existing members. Some of the information that you provide may be considered “special” or “sensitive” in certain jurisdictions. By choosing to provide this information, you consent to our processing of it. Any information you provide may be viewable by other users of the Service. If you communicate with other users within the Service, you provide us with the content of your conversation. Should you contact us with an inquiry, we may collect the content of that correspondence or interaction. You may change your personal information (other than your date of birth and Instagram handle) at any time within the App settings.
Specifically, we collect the following categories and types of personal information:
Identifiers, such real name, alias, unique personal identifier, online identifier, Internet Protocol address, email address, account name or other similar identifiers.
Categories of personal information described in Section 1798.80(e) of the California Civil Code, such as name, physical characteristics or description, address, telephone number, education, or employment.
Characteristics of protected classifications under federal law – such as race, religion, gender, or age – or under California law – such additional categories as sexual orientation.
Commercial information, such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Internet or other electronic network activity information, such as browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement.
Geolocation data.
Visual information, such as photographs.
Professional or employment-related information.
Education information.
Hometown information.
Height.
Religion.
Information regarding your interests and disinterests.
Inferences drawn from the above categories.
We collect the following categories of sensitive information:
Account log-in, in combination with any required security or access code, password, or credentials allowing access to the account.
Racial or ethnic origin, or religious or philosophical beliefs.
Contents of App messages unless we are the intended recipient of the communication.
Information collected and analyzed concerning your sexual orientation.
Information We Automatically Collect. In addition to the information you provide, certain information will be automatically collected as you use the Service, including, but not limited to, the operation system used by your device, your device type and ID, your IP address, how and how often you interact with other users and your access times. This information may be collected via several technologies, including cookies, web beacons, clear GIFs, canvas fingerprinting and other means, such as Google Remarketing and Facebook Pixel. You can control cookies in your browser to enable or disable them. Learn more in our Cookie Policy.
Information Other Users Provide. In addition to the information that you choose to provide to us, other users may provide information about you as they use the Service if, for instance, they contact us about you, or you are a contact in their phone.
Information We Get from Third Parties. We may collect personal information and non-personal information about you from third parties.
Surveys. From time to time, we send you surveys from us or brand recognition surveys on behalf of advertisers. If you participate in these surveys, we will have access to your survey responses.
No Financial Information. As we exclusively accept payment through third party services such as Apple and Stripe, we will never ask for your credit card information and your financial details are, and will remain, secured by and subject to the applicable third party’s security and privacy policies.
HOW WE USE INFORMATION WE COLLECT
We may use or disclose the personal information we collect for one or more of the following purposes:
To provide you with our Service, which includes:
Creating, maintaining, customizing, and securing your account with us.
Providing customer support and responding to your inquiries, including investigating, and addressing your concerns, and monitoring and improving our responses.
Processing your requests, purchases, transactions, and payments.
Verifying customer information.
Providing advertising or marketing services to you.
To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, we will use that personal information to respond to your inquiry.
To detect security incidents, protect against fraudulent or other criminal activity, debug and repair errors, and help maintain the safety, security, and integrity of our App, Site, products and services, databases and other technology assets, and business.
To personalize your App experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our App, third-party sites, and via email or text message (with your consent, where required by law).
For testing, research, analysis, and product development, including developing and improving our App, Site, products, and services.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
To fulfill our financial obligations.
To provide you with employment opportunities.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
AGE POLICY
Must be of Age. We restrict our Services to people who are 18 years of age and older. Only applicants 18 and over will be considered for acceptance, and we are not liable should an applicant misrepresent their age in their application. Should we become aware of a user who is not at least 18 years of age, we will immediately remove that user from our Service. We do not knowingly collect, maintain, or use information from children under the age of 18. If you become aware that a child under 18 has provided us with personal information, please contact us at support@seoulmateapp.com If we become aware that a child under 18 has provided us with personal information, we will take steps to delete such information.
INFORMATION SECURITY AND RETENTION
Information Security. We have security measures in place to protect against the loss, misuse, and alteration of personal information under our control. Please be advised that, although we take reasonable technological precautions to protect your data, no website, application, or data transmission can be guaranteed to be 100% secure. Therefore, we cannot and do not guarantee that your information will be secure. Any transmission of data at or through our website, Services or Apps is at your own risk.
We keep your personal information only as long as we need it for legitimate business purposes 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 users. 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:
To protect the safety and security of our users, we implement a safety retention window of three months following account closure. 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.
Once the safety retention window elapses, we delete your data and only keep limited information for specified purposes, as laid out below:
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. We may also need to keep “traffic data” / logs for one year to comply with legal data retention obligations. We also keep records of consents users give us for five years to evidence our compliance with applicable law.
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 to support our customer care decisions, enforce our rights and enable us to defend ourselves in the event of a claim, profile data in anticipation of potential litigation, for the establishment, exercise or defense of legal claims, and data necessary to prevent users who were banned or people who were found to be under the age of 18 from opening a new account, for as long as necessary to ensure the safety and vital interests of our users.
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).
Requesting Deletion of Your Data
We comply with all requests to delete users’ data. To request the full deletion of your data, send an email titled “Data Deletion Request” to support@seoulmateapp.com and include your name, phone number, and any potential email addresses you may have used so we can locate and delete all the data attributed to you. Data deletion requests are processed within 3-5 business days.
CHANGE OF CONTROL
If we enter discussions to sell, merge, or otherwise reorganize our business, we reserve the right to transfer and disclose all data (including personal and non-personal user information) to prospective and/or actual purchasers or investors. We will require that such purchasers/investors treat the transferred data as described in the Privacy Policy that exists prior to the change unless and until you consent to a new Privacy Policy.
PRIVACY POLICY CHANGES
We reserve the right to change our Privacy Policy at any time without notice. However, these changes will not reduce your privacy on a retrospective basis. We will post any Privacy Policy changes on this page, and it is your responsibility to check this page for updates.
CONTACT INFORMATION
If you have questions or complaints relating to this Privacy Policy, please contact us at support@seoulmateapp.com
PRIVACY RIGHTS AND ADDITIONAL DISCLOSURES FOR EEA & UK INDIVIDUALS
Lawful Bases for Processing. If you are from the European Economic Area (EEA) or United Kingdom (UK), our legal bases for collecting and using your personal information is as follows:
The performance of your contract or to enter into the contract and to take action on your request. For example, processing your membership application and completing your account registration.
Our legitimate business interests. For example, fraud prevention, maintaining the security of our network and services, direct marketing to you, and improving our services.
Compliance with a mandatory legal obligation. For example, accounting and tax requirements, which are subject to mandatory retention periods. We may also collect your personal information to record your requests to exercise your rights and to verify your identity for such requests.
The consent you provide where we do not rely on another legal basis. Consent may be withdrawn at any time.
In some limited cases, we may also have a legal obligation to collect personal information from you in response to lawful requests by public authorities, including to meet law enforcement requirements, as described in the “How We Share Your Information” section.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided above.
EEA and UK Individuals’ Rights. If you are from the EEA or UK, you have the right, under certain circumstances, to:
Access, correct, update, or request deletion of your information.
Object to processing of your information, asking us to restrict processing of your information, or requesting the portability of your information.
Withdraw your consent at any time if we have collected and processed your information with your consent. Withdrawing your consent will not affect the lawfulness of any processing that we conducted prior to your withdrawal, nor will it affect processing of your information conducted in reliance on lawful processing grounds other than consent.
To exercise any of these rights, contact us using the contact details provided above, and please specify which privacy right(s) you wish to exercise. We may need to verify your identity to honor your request.
International Transfers of Data. Any data that you provide to us may be accessed, shared or processed by our offices, located in the United States, and service providers located in the United States, if such a data transfer is necessary for the specific purpose for which you submitted your data (such as the provision of goods or services under a written contract).
This may entail the transfer of your personal information across international borders. The data protection standards may differ and be lower than the standards enforced in your jurisdiction. We maintain appropriate safeguards as required by applicable law for any personal information transferred internationally.
Right to Lodge a Complaint. If you have any issues with our compliance, you have the right to lodge a complaint with an EEA supervisory authority. We would, however, appreciate the opportunity to first address your concerns and would welcome you directing an inquiry to us via the contact information in this Privacy Policy.
PRIVACY RIGHTS AND ADDITIONAL DISCLOSURES FOR CALIFORNIA RESIDENTS
If you are a California resident, please see our California Privacy Statement, which supplements this Privacy Policy.
Third Party Marketing. If you are a California resident, California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of a Service that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to support@seoulmateapp.com
Access to Specific Information and Data Portability Rights. Residents of California have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see “Exercising Your Rights,” below), we will disclose to you:
The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting, selling, sharing, or disclosing that personal information, and the categories of personal information disclosed for such purpose(s).
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).
The categories of personal information we have sold, if any, about you and the categories of third parties to whom your personal information was sold, by category or categories of personal information for each third party to whom the personal information was sold.
Request for Deletion. California residents have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see “Exercising Your Rights,” below), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
Do Not Sell or Share My Personal Information. Residents of California have the right to opt out of the sale or sharing of their personal information. We do not sell your personal information. However, we may use your personal information to provide personalized or targeted advertising. In such circumstances, you have the right to direct us not to share your personal information for such purposes. If you wish to actualize this right, please visit this webpage: Do Not Sell or Share My Personal Information.
Limiting the Use of Sensitive Personal Information. Residents of California have the right to direct us to use or disclose sensitive personal information only for providing goods or services, or as otherwise minimally permitted under applicable law. However, we do not use or disclose sensitive personal information for any purpose other than providing our goods or services to you, or as otherwise minimally permitted.
Right to Equal Service and Price. California residents have the right to receive equal service and price from us, even if you exercise a privacy right.
Exercising Your Rights. To exercise any rights described above, please email us at support@seoulmateapp.com
Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information.
Verification Process for Exercising Rights. To protect our consumers’ privacy, we verify privacy rights requests to ensure that only you (or your authorized agent) can exercise rights pertaining to your personal information. As part of our verification process, we may request you to submit additional information.
If you are an authorized agent wishing to exercise rights on behalf of a state resident, please contact us using the email address above and provide us with a copy of the consumer’s written authorization designating you as their agent. We may need to verify your identity and place of residence before completing your rights request.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Appeal Process. If we do not decide to act in response to your request to exercise a right, we will provide a timely response detailing the reasons for not taking action and, depending on the circumstances, any rights that you may have to appeal our decision.
Response Timing and Format. We will confirm receipt of your request within ten (10) business days. Then, we will endeavor to respond to the request within forty-five (45) days of its receipt. If we require more time (up to 90 days), such as to verify your identity, we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response electronically.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.