Privacy Policy

Foreground Inc. (hereinafter referred to as the “Company”) complies with the personal information protection provisions under the relevant laws to be observed by information communication service providers, including the Communications Secret Protection Act, the Telecommunications Business Act, the Act Relating to Information Communications Network Use Promotion and Information Protection, etc., and does its best to protect the rights and interests of users by setting forth privacy policies pursuant to the relevant laws.

Items of Personal Information to be Collected and Collection Methods
1. Items of Personal Information to be Collected
① The device information(including device model, the name and version of OS, unique device numbers), Information on Users’ conditions, photos, cookies, visit dates and times, records of service uses, records of wrongful uses
- Initial service device identification number(device ID or IMEI), region format
- Device information(model, device type, OS version)
- Photograph, cookie, date of use, service use log, improper use log
- NAVER/KakaoTalk/Instagram/Facebook ID for SNS linked service
② Company collects following information additionally - requested information : user I.D, e-mail, password - optional information : name, gender, age(birthday), photo and etc.
③ The applications company provide can collect different personal information individually If the application collects the information no included in this privacy policy, the information to be collected will be notified and consent will be obtained through the corresponding application separately.
④ Company can collect user’s contact information(including phone number, address) to deliver the giveaways and prizes when users participate in event.
⑤ The Company does not collect, store and use information with which an individual’s location can be identified. However, certain ad solution (including banner, interstitial, reward ads, etc.) operated by 3rd parties, may collect, without storage, via location-recognition advertisements of advertising-service providers as such 3rd parties, and temporarily use, location information with a device’s censor data, etc. that may provide actual location information (including GPS signals from mobile devices) or information on nearby Wi-Fi access points and base stations. However, such use of location information is unrelated to the Company.

Collection Methods
Company collects the personal information in the following ways.
• Sign-up or using subscription service for applications
• Collecting information and photo by user’s input
• Provided by companies associated with company
• User’s participation in event
• Automatically collecting the personal information by the collecting tools

Purpose of Collection and Use of Personal Information
① Performance of agreements on provisions of services, and payments of costs for provisions of services - Provisions of content, provisions of specific customized services, delivery of goods, or sending invoices, verifications of IDs, purchases or payments of costs, collection of costs
② Control of members – to identify individuals, to prevent wrongful uses of undesirable members or unauthorized uses, to verify intents for subscriptions, to limit subscriptions and subscription frequencies, to verify consent by a legal representative to collect the personal information of a child of not more than fourteen (14) years old, to verify the identification of a legal representative afterwards, to retain records for dispute resolutions, to handle civil complaints including handling grievances, to convey notifications
③ Developing new services, Application thereof to marketing and advertisements - to develop new services and provide customized services, to provide services and publish advertisements according to demographic features, to verify the validity of services, to provide information for events or advertisements and provide opportunities to participate, to figure out access frequencies or obtain statistics on the service uses by members

Sharing and Provisions of Personal Information
Company uses personal information of users only within the scope as notified in policy and shall not use or in principle disclose to a third party the personal information of users in excess of the scope without the prior consent of users - provided, however, that exceptions are made in the following cases
- Users have given a prior consent to the disclosure
- The disclosure is required under the provisions of laws or requested by investigative agencies according to the procedures and methods prescribed under the laws for investigation purposes.

Delegation of Treatment of Personal Information
Company delegates personal information for improvements of services as follows and provides the required matters to safely control personal information in entering into a delegation agreement under relevant laws. Company’s personal information delegated agencies and the content of delegation are as follows
• FOREGROUND Inc.
• Providing Information : The device information(including device model, the name and version of OS, unique device numbers), Information on Users’ conditions, photos, cookies, visit dates and times, records of service use, records of wrongful uses
• Purpose : Performance of agreements on provisions of services, and payments of costs for provisions of services - Provisions of content, provisions of specific customized services, delivery of goods, or sending invoices, verifications of IDs, purchases or payments of costs, collection of costs
• Retention and Use Period for Personal Information : until the services are completed or members withdraw from their membership, or a delegation agreement is completed.

Retention and Use Period for Personal Information
Once the purposes of collection and use of personal information have been completed, company destroys the personal information - provided, however, that company retains the personal information during a specified period for the following reasons
1. Reasons for information retention under company’s internal policies
Company retains user’s information to record and prevent wrongful uses for 1 year, after 30 days of member withdrawal.
2. Reasons for information retention under relevant laws
If it is necessary to preserve personal information under relevant laws including the Commercial Code, the Act Relating to Consumer Protection in Electronic Commercial Transactions, etc., company retains the information of members for a certain period prescribed under relevant laws. In this case, company uses the personal information it retains only for the purpose of preservation thereof, and the retention period are as follows
- Records on agreements or withdrawals of offers. : 5 years - Records on payments and supplies of goods, etc. : 5 years - Records on complaints of consumers or dispute resolutions : 3 years - Records on verification of identification : 6 months - Records on visitations : 3 months
Destruction Procedures and Methods for Personal Information
Company destroys the personal information of users without delay if the purposes of collection or use of personal information have been completed. The information printed out in sheets is to be shredded by paper shredders or destroyed by way of incineration. The information saved in an electronic file format is to be deleted with the use of technical methods in which records cannot be regenerated.

Rights to Personal Information of Users and Legal Representatives
Users or their legal representatives may at any time inquire or change their personal information or the personal information of children of not more than fourteen (14) years old and may request terminations of subscriptions. Where a user has requested corrections of errors in the personal information, company does not use or provide the personal information until the corrections are completed. Also, where the wrong personal information has been already provided to a third party, company will make the corrections by giving the third party of the correction handling results without delay

Cookie Policy
Currently, this smartphone application does not use cookies; if you use them later, they can be used as the following policies - company uses “cookie” to store and occasionally bring in the user’s information to provide personalized and customized services. Cookies are stored on the user's computer's hard disk as a small text file that the server used to run the website sends to the user's browser. When a user then visits the website, the website server reads the contents of cookies stored on the user's hard disk to maintain the user's preferences and provide customized services. Users have a choice about installing cookies. Therefore, users may allow all cookies by setting the options for the web browser, check them every time cookies are stored, or refuse to store all cookies. However, if you refuse to install cookies, it may be difficult to use some services that require login.
Permission Request
“The Company” may access and use information within the customer’s mobile communication device as follows for its mobile application services. The Company explains, and obtains consent to, access to required items upon the installation, or first execution, of a mobile application, and obtains separate consent to access to optional items upon the first use of such mobile application. The method of obtaining consent to access to optional items may vary depending on the OS version, however, there is no restriction on the use of basic services by a member refusing to give consent.
1. Required Permission
- Device ID, application record : Examination of application status(version)
- Communication record, WIFI connection information : Optimization of application use, examination of network connection
2. Optional Permission
- Photograph/media/file : Storage or loading of photograph, video or contents
- Camera : Use of photo function or QR code
3rd Party Information Collecting Module
“Company” may use the functions of the service and independent third party information gathering modules to investigate the use propensity of this service, to ensure stable operation, and to prevent fraud. Policy for information management collected by the acquisition/analysis module may refer separately to the policy of handling personal information determined by the third party.
- Firebase (by Google LLC)
- Items to be collected : Firebase Instance ID, Birthday, User numbers, Session numbers, Session maintenance time, OS, Device model, Region, First execution, App execution, Play data in app.
- Purpose: To investigate user usage, traffic, and play data
- Firebase Privacy Policy : https://policies.google.com/privacy?hl=en
Limitiation
①Company may provide users with links to other companies’ websites or materials, but because they have no control over external sites or materials, they cannot be responsible for the legality of services or materials that users are provided with. If you move to another site through a link that includes the service of company, the personal information handling policy of the service is not related to company, so please check the policy of the new site.
② Company is not responsible for the damage, infringement, or leakage of information due to unexpected accidents caused by basic network risks, such as hacking, not the reason for the company’s fault, even though the company has made technical supplements to protect the personal information of users.

Notification
Company may modify its personal information policy for the purpose of changing laws or improving application services. Company publishes changes, and the changed personal information handling policy takes effect seven days after the date of the publication. However, if there is an important change in the user's rights, we will notify at least 30 days before.
Company will take the necessary steps to protect the personal information of the user faithfully.
Please contact the individual application 1:1 or receive any personal information protection inquiries and complaints that occur while using the service of the company through a separate notice customer center.
Contact : cookids20@gmail.com