TENTUPLAY USER PRIVACY POLICY

Last modified: Sept. 4, 2020

IN ORDER TO PROTECT THE PERSONAL INFORMATION OF THE SERVICE USERS, SENTIENCE INC. (hereinafter referred to as “SENTIENCE,” “WE” OR US”) COMPLIES WITH THE PRIVACY PROTECTION REGULATIONS UNDER THE RELEVANT LAWS, SUCH AS THE “ACT ON PROMOTION OF INFORMATION AND COMMUNICATION NETWORK UTILIZATION” AND THE “PERSONAL INFORMATION PROTECTION ACT,” AND HAS THE FOLLOWING PRIVACY POLICY. SENTIENCE WILL NOTIFY USERS VIA EMAIL WHEN THE PRIVACY POLICY IS REVISED.

※This policy is effective from September 4, 2020.

1. Personal Information to be Collected


1.1 SENTIENCE collects the following personal information that is necessary for creating accounts, providing customer consultation, and allowing customers to access and use various services:

1. For Individual Member Sign Up
- Mandatory Information: Email address, password, name, mobile phone number, country, address
2. For Corporate Member Sign Up
- Mandatory Information: Email address, password, name of the business, country, phone number, address of the business
- (For residents in Korea) name of the representative, business registration number, copy of the business license
3. For Registering an Automatic Payment
- Credit card: Date of birth(business registration number for business), credit card number, credit card expiration date
- (For the Korean corporate members) Bank transfer: Bank name, date of birth (business registration number for businesses), account number
1.2 The following information is automatically created or collected while using the service or processing applications for service:
- IP Address, cookies, connection log, visit date, service user records, defective user records, payment records
1.3 The following information is collected for users of certain services of SENTIENCE. Such information is retained only while using the specific service:
1. When obtaining separate consent for the collection of personal information

ClassificationCollected information
General inquiriesMandatory: Email address, mobile phone number
Cash receipt applicationMandatory: Mobile phone number or cash receipt card number
Applying for the newsletter subscription Mandatory: Name, email address / Optional: Company name
When using a user environment diagnostic tool to measure service qualityMandatory: Client IP

2. Personal Information Collection Methods


2.1 SENTIENCE collects personal information via the following methods:
1. Website, written document, fax, phone, customer forum, email, collected at events or seminars
2. Data received from partner organizations
3. Collection of data via automated tools

3. Purposes for Collecting and Using Personal Information


3.1 Performance of Service Agreement and Settlement of Fees for Service Provided
SENTIENCE collects personal information to provide customers with content and customized services, deliver goods, issue invoices, authenticate user identities, process purchases, and fee payments, and to collect fees.
3.2 Customer Management
SENTIENCE collects personal information to verify user identities for using customer services or to comply with identity check requirement under applicable laws, to confirm individual identification, to prevent illegal use and unauthorized use, to confirm account registrations, to prevent duplicate registrations, to validate identities of legal representatives, to archive records for dispute resolution, for civil complaint processing, and to provide notices.
3.3 New Service Development and Marketing
SENTIENCE collects personal information to develop new services and customize services, provide existing services and posting advertising based on user demographics, validate services, provide event and advertising information, and provide opportunities for customer participation, understanding usage patterns, and developing statistics on customer user of services.

4. Providing Personal Information to a Third Party


4.1 SENTIENCE shall use the personal information of users within the scope specified in article 3(Purposes for Collecting and Using Personal Information) and shall not exceed this scope without the user's prior consent or disclose personal information of the user to any third party. Notwithstanding the foregoing, however, the following shall be exceptions:
1. If the users have agreed in advance
2. If based on the provisions of laws and regulations, or if there is a request of an investigation agency according to the procedures and the methods set forth in the laws and investigation purposes
3. The cases where personal information is provided after the user gives consent in advance shall be as below:


Receiving partyInformation ProvidedPurpose of userPeriod of retention and usage
TENTUPLAY PartnersCustomer Login ID, Customer nameTo provide Partner Program servicesFor the duration of the partner’s service provided

5. Period of Personal Information Retention and Use


5.1 In principle, SENTIENCE deletes or destroys customers’ personal information without delay once the purpose for collecting and using personal information has been satisfied. However, the following information will be retained for a specified period of time due to the following reasons:


Retained InformationReason for RetentionRetention Period
Record of illegal usePrevention of illegal use1 year
Inquiry/partnership details (only if the customer gives express consent)Customer consultation processing6 months
Attachment(s) determined to be infected malicious file(s)Analysis of the infected file(s)1 month

5.2 SENTIENCE retains users’ information for periods designated in applicable laws and regulations, when information retention is required hereunder, including, without limitation, the Commercial Law and Act on the Consumer Protection in Electronic Commerce. In this case, SENTIENCE will use the information for the purposes specified in the relevant acts and regulations. The retention periods for these purposes are as follows:


Retained InformationCause for RetentionRetention Period
Record on contracts or subscription withdrawalsAct on Consumer Protection in Electronic Commerce, etc.5 years
Records on payments and goods supply5 years
Records on complaints or dispute handling3 years
Records on display or advertisements6 months
Ledgers and evidential documents about all transactions as defined by the tax lawFramework Act on National Taxes, Corporate Tax Act5 years
Records on electronic transactionsElectronic Financial Transaction Act5 years
Login recordsProtection of Communications Secrets Act3 months

6. Personal Information Destruction Procedures and Methods


6.1 SENTIENCE deletes or destroys customers’ personal information without delay once the purpose for collecting and using personal information has been satisfied.
6.2 The information that the user has submitted for account sign-up will be moved to a separate database (or a separate document container for paper files) and destroyed after retention requirements related to information security in accordance with SENTIENCE policies and applicable laws are fulfilled (refer to the period of retention and use).
6.3 The retained personal information will not be used for any purpose other than for retention as required by applicable laws and SENTIENCE policies unless otherwise required by law.
6.4 For reference, the personal information of the members who have not used the service for one year is separately stored and managed in accordance with the ‘Personal Information Validity Period Policy.’

7. Destruction Method


7.1 Personal information printed on paper will be destroyed by shredding or incinerating.
7.2 Personal information saved in electronic formats will be deleted via a technical deletion method that destroys data permanently.

8. Rights and Duties of Information Subject and Legal Representative and Methods of Exercising Them


8.1 Users and their legal representatives can retrieve or modify personal information at any time or request cancellation of membership.
8.2 To retrieve or modify personal information, the user must complete the identity verification procedure on the “Your Profile” page of the TENTUPLAY website. To cancel membership (withdraw consent), the user must complete the identity verification procedure on the “Member Withdrawal” page of the TENTUPLAY website.
8.3 SENTIENCE will process deletion without delay if a user contacts SENTIENCE’s personal information manager via writing, phone, or email.
8.4 In the event that a user has requested to correct personal information, the relevant personal information will not be used until it is updated. In addition, if incorrect personal information is already provided to a third party, the change will be notified to the third party without delay.
8.5 SENTIENCE handles the personal information canceled or deleted by the user or a legal representative as specified under Article 5(Period of Personal Information Retention and Use) to prevent viewing or using information for other purposes.

9. Installation, Operation, and Rejection of Automatic Personal Information Collection Devices


9.1 SENTIENCE uses “cookies” to save and retrieve the usage information to provide the individually customized service.
9.2 Cookies are a small amount of information that the server (HTTP) used to run a website sends to the user's computer browser and is sometimes stored in the user's hard disk.
Purpose of using cookies: Cookies are used to provide optimized information to the user by identifying visits, usage types, search terms, and the secure access status, etc., regarding the services and websites used by the user.
Installation, operation, and rejection of cookies: The user can refuse to save cookies through the web browser option setting. If the user refuses to save cookies, he/she may experience difficulties in using customized services.

10. Technical and Administrative Protection of the Personal Information


10.1 SENTIENCE takes the following technical and administrative measures to secure the safety of user’s personal information, and prevent loss, theft, disclosure, alteration, or distortion.
10.2 Member passwords are encrypted for storage and management and only the user knows the password. As a result, only the user who knows the password can access the account to view or modify the personal information.
10.3 SENTIENCE takes reasonable precautions to prevent any leak or damage to the user’s personal information due to hacking attacks or computer viruses. SENTIENCE backs up data frequently to prevent damage to personal information. SENTIENCE uses up-to-date vaccine programs to prevent leakage or damage to personal information or data. SENTIENCE uses encrypted networks to allow the safe transmission of personal information on the network. SENTIENCE also controls unauthorized access using an intrusion prevention system. SENTIENCE takes reasonable precautions to operate and maintain all possible technical systems and equipment regularly to run systems securely.
10.4 Personal information handling is limited to the persons in charge only. For this purpose, a separate password is given and updated on a regular basis. Compliance with the privacy policy is always emphasized through frequent training of the persons in charge.
10.5 SENTIENCE is making efforts to make corrections and adjustments immediately if a problem is discovered by checking the fulfillment of privacy policy and compliance of the persons in charge through an in-house privacy task force, etc. However, SENTIENCE shall not bear responsibility for damages that are not caused by the negligence of SENTIENCE, such as the user’s own negligence or accidents in areas not managed by SENTIENCE when the SENTIENCE has fulfilled the obligations to protect personal information.

11. Contact Information of the Privacy Manager


Users can report complaints related to personal information protection to the Privacy Manager. SENTIENCE will promptly provide an adequate reply on the reported details of the users.


ClassificationPrivacy Manager
NameMyunsoo Kim
DepartmentSecurity & Privacy Division
Emailcompliance@sentience.rocks

If you need to report on other infringements of personal information or if you require consultation, please contact the agencies below.
Personal Information Infringement Report Center (https://privacy.kisa.or.kr / 118 without area code)
Cyber Investigation Bureau of the Supreme Public Prosecutor’s Office (http://www.spo.go.kr / 1301 without area code)
Cyber Safety Bureau of the National Policy Agency (http://cyberbureau.police.go.kr / 182 without area code)

12. Exceptions


Please be noted that this privacy policy is not applicable to personal information collected by the website linked to SENTIENCE’s Internet service.

13. Obligations to Notify


This Privacy Policy shall start to be effective on the enforcement date, and in case there is any addition, deletion, or correction of provisions in accordance with the relevant statutes and policies, SENTIENCE shall notify the details seven days before implementation of the change. However, if the amendment is revised to be unfavorable in relation to the Client's rights and obligations, notifications are made 30 days before the effective date.

14. Language


All communications and notices made or given pursuant to the Terms shall be in the Korean language. Provided that, SENTIENCE may provide English translation of the communications and notices for convenience purpose only. In case SENTIENCE provides an English language translation of the notices and/or the Terms, the Korean text of such notices and/or the Terms will control in case of any conflict. Notwithstanding the foregoing, however, the Customer may communicate or give notice to SENTIENCE in either the Korean or English language.

Notice for users of applications and websites with built-in SDK


SENTIENCE provides a wide range of services under the TENTUPLAY brand to its customers. SENTIENCE’s various services can be provided through SDK or server-to-server communication.
Customers can selectively use the variety of services provided by SENTIENCE, and such a selection right is entirely reserved by each customer. Customers can collect various data to analyze the use status of various users who use their services.
In this process, the customers can store via TENTUPLAY’s service part of non-personal information among the collected user data such as reversibly encrypted GAID, IDFA, etc. that are transmitted; unique device identification values legally defined as non-personal information and reversibly encrypted information of areas, languages, device names, network environments, OS versions, service use history of the user, etc. that are transmitted and use it for information mapping or deliver it for the purpose of matching unspecified anonymous users and information for identifying individuals.
In this process, SENTIENCE provides information to customers for the sole purpose of identifying anonymous users with personal information and does not use the received or entrusted personal information of customers for any other purpose than the above-mentioned and statistical purpose.