Sharfoo Privacy Policy

1. Introduction
We, Sharfoo Corporation (“Sharfoo,” “we,” “us,” or “our”), believe your privacy is important.
To fulfill our commitment to respecting and protecting your privacy, we will adhere to the following principles:

1. We inform you of the fact that your personal information will be collected, and seek your consent to collect, process, use, or disclose your personal information through the appropriate way.
2. We will identify the purposes for which we will collect and further process your personal information within the minimum extent.
3. We will only collect information that is necessary to carry out the specified purposes of use.
4. We will use or disclose your personal information only for the purposes for which it has been collected, except with your consent, or as required or permitted by applicable law, and we will retain your information only as long as necessary to fulfill those purposes.
5. We will try to ensure that your personal information is accurate, complete, and up-to-date.
6. We will implement appropriate technical and organizational measures to protect your personal information.
7. We will make our policies and practices for the handling of your personal information as transparent as is reasonably possible.
8. You will have access to your personal information and will be able to correct your personal information as appropriate in accordance with your rights under the applicable law.
9. We will be responsible for your personal information. We are interested in hearing your opinion regarding our compliance with these principles, this Privacy Policy, and applicable laws.

2. Scope of This Privacy Policy

a. Purpose of This Privacy Policy
This Privacy Policy explains how Sharfoo will process and safeguard your personal information, and the rights and choices you have with respect to your personal information. This Privacy Policy applies to: personal information you provide us when you use the Sharfoo app (“Sharfoo App”), optional services made available within the Sharfoo App, and other apps that integrate with or work in conjunction with the Sharfoo App (collectively “Apps”); personal information we collect when you visit websites maintained by us relating to our Apps (“Websites.” Apps and Websites are collectively referred to as “the Services”); and personal information about you provided by other users of the Service.

To make our Privacy Policy easier to understand for non-native English users, we may provide translations in your native language as a reference. A Korean translation, an English translation, a Japanese translation, plus 4 more languages are now available. However, in the event that any provision in the translations contradicts the Korean version of this Privacy Policy, unless otherwise specified, the Korean version takes precedence to the extent permissible under applicable law.

This Privacy Policy applies if you are using the Services, or any part of the Services, anywhere outside or inside of Korea. If you are using the Services in Korea or USA, please refer to our Korean Privacy Policy or USA Privacy Policy respectively. The current version of this Privacy Policy is accessible at our website or appropriate location in our APP.

3. Types of Personal Information We Collect

a. What Personal Information Does Sharfoo Collect?
To provide you Services, Sharfoo collects, uses, and transfers the following types of information:

i. Information Concerning Your Account
When you create a Sharfoo account to access the Services (an “Account”), Sharfoo will ask you to provide your E-mail address. This information is necessary because we may send an E-mail message via E-mail to your E-mail which you provide, as part of our ongoing efforts to detect and deter unauthorized or fraudulent use of or abuse of the Services. We may also use your E-mail address to provide you important information about Services.

Alternatively, you may choose to create an Account using your Facebook account when, for example, you do not wish to provide your E-mail address. In such a case, E-mail provision is optional. Please note that we do not collect your Facebook password.

b. What Other Information Might Shafoo Collect?
To improve the quality of Services, we provide additional functionalities, including the ability to access your Account from multiple devices, help you find friends via the Service, and make the Services more efficient, usable and enjoyable. If you choose to use such functionalities, or choose to use your Account on multiple devices, we may ask you to provide the following information:

i. Email Address [OPTIONAL]
If you wish to access your Account from multiple devices (“Multiple Device Login”) or to transfer your Account from one device to another (“Account Transfer”), you will need to provide your e-mail address and a password and/or PIN code to Sharfoo, so that we may associate these devices with your Account. We may use your registered e-mail address to provide you with important information about the operation of the Services.

Please note that if you change your mind later and decide you no longer wish to provide your e-mail address, you can at any time remove it in the “Settings” > “Accounts” menu in the Sharfoo App.

ii. Sharfoo ID [OPTIONAL]
In order to make it easier for your friends to find you in the Services, you may choose to assign a Sharfoo identification name (a “Nickname”) to your Account, and allow your friends to find you through your Sharfoo ID. Alternatively, you may choose not to allow other Sharfoo users to contact you using your Sharfoo ID. Please note that your Sharfoo ID is not visible to other Sharfoo users without your consent, and your Sharfoo ID may be a pseudonym – it does not have to be your real name.

iii. Contact Information for Customer Support [OPTIONAL]
There may be circumstances in which you might wish to contact us to seek our customer support. If you contact us via our web site or appropriate location in our App, or by other means, we may obtain and maintain any information you choose to provide, including your name, contact information such as your e-mail address, phone number, as well as information about your mobile device or personal computer such as its device type, and OS type. We will use this information to address and investigate the issues you have raised, to provide you support, and to improve our customer support service. We may process this information in connection with the assistance you have requested, the administration of your Account, and retain this information in accordance with the provisions of this Privacy Policy.

iv. Payment Information [OPTIONAL]
If you choose to purchase an Additional Service or use a fee-based Additional Service and pay for such Additional Service by a means other than in-app purchases via iTunes or Google Play, we may engage a third party service provider to collect and process your credit card information. We will use your credit card information only to process your purchase or use our fee-based service. Please note that we will not retain your credit card information beyond the period necessary to facilitate the relevant payment. Your credit card settlement will be handled by appropriate third party payment agencies.

c. What About Information I Create About Myself and Share With Others?

i. User-Generated Content [OPTIONAL]
In addition to the information described above, you may choose to set your profile information (e.g., Sharfoo ID, “display name,” profile picture, and the phrase you choose to show under your status message) and show who you are to other Sharfoo users within the Services. Furthermore, you may choose to create “user-generated content” such as texts and audio messages, photos, videos, geolocation data, or the contact information of your Sharfoo friends, and share this user-generated content with other users. You may choose how much or little of your user-generated content to share with, and with whom you share it, when you create messages by selecting the recipients of your user-generated content and/or through the privacy settings in the Sharfoo App.

Please note that the profile information and user-generated content you share with others can be copied, stored, or disseminated by the recipients and potentially accessed by unintended third party recipients due to the nature of digital data. We encourage you to be very attentive and cautious when you generate and share your personal information or content with others.

4. How We Use and Handle Your Information?

a. How Does Sharfoo Use My Information?
To provide the Services and any Additional Services, Sharfoo, as a data controller or joint data controller, uses your personal information for the following purposes in accordance with this Privacy Policy:

• to provide the Services and any Additional Services to you and to allow you to transmit your user-generated content to other Sharfoo users;
• to verify your identity;
• to allow you to use your Account on multiple devices and transfer your Account to another device;
• to help you find people you know that are already Sharfoo users so that you can connect using Sharfoo and, subject to your prior agreement, to allow other Sharfoo users to connect with you;
• to offer Additional Services to those who want to have more various and convenient function;
• to monitor, detect and deter unauthorized or fraudulent use of, or abuse of the Services;
• to improve and/or optimize the Services and any Additional Services;
• to enable us to provide customer support, and to respond effectively to your inquiries and claims;
• to conduct user surveys;
• to provide you with information regarding the Services and any Additional Services;
• to measure the effectiveness of advertisements that we place on the Internet or in other media;
• to notify you of any other important information regarding the Services and any Additional Services, if necessary;
• to aggregate anonymized statistical data regarding the Services and any Additional Services; and
• to comply with applicable laws or legal obligations.

If, however, we provide you with more specific purpose(s) of use either at the time we ask you to provide your personal information or through other means, then such notice will take precedence over the general purposes of use stated in Section 4.a of this Privacy Policy.

b. How Does Sharfoo Protect My Personal Information?
To fulfill our commitment to respecting and protecting your privacy and the confidentiality of your personal information, Sharfoo has implemented appropriate technical and organizational security standards, including industry-standard safeguards to prevent unauthorized access or disclosure, misuse, alternation, or destruction of your information.
Because no method of electronic transmission or method of data storage is perfect or impenetrable, we cannot guarantee that your personal information will be absolutely safe from intrusion during transmission or while stored in our systems. To help protect your privacy and confidentiality of your personal information, we also need your help. Please do not share your password with others, or use the same passwords you use for other services. Also, please notify us in the event you suspect any unauthorized use of your Account or any other breach of security via our website or an appropriate location in our App.

c. Where Is My Personal Information Transmitted and Stored?
To provide the Services in a reliable and responsible manner, Sharfoo processes and stores your information on secure servers which may be physically located in Korea, In particular, through our Firebase service by Google. All such transfers are performed in accordance with the requirements of applicable laws.

d. How Long Does Sharfoo Keep My Information?
Sharfoo retains the personal information you provide while: your Account is active; for the length of time needed to fulfill any of the applicable purposes of use described in this Privacy Policy; or to comply with applicable laws and regulations.

We may retain your personal information following the closure or termination of your Account if retention is reasonably necessary:

• to comply with applicable laws, regulations or legal obligations;
• to provide and complete customer support service;
• to resolve disputes between or with Sharfoo users; or
• to detect and deter unauthorized or fraudulent use of, or abuse of, the Services.

e. Does Sharfoo Use Outside Service Providers or Agents?
To provide the Services, it sometimes is necessary for Sharfoo to enlist third party service providers to process user data, which may include your personal information. We strictly evaluate all such third party service providers. We take reasonable steps to ensure that they have established appropriate and secure information administration and organizational control systems. 

We impose binding contractual obligations on such service providers to comply with applicable laws and regulations regarding the processing of personal information. We also require that they access your personal information only to the extent necessary to perform tasks in accordance with our instructions, and for no other purposes.

f. Does Sharfoo Give My Information to Third Parties?
Other than as described in this Privacy Policy and other applicable privacy policies or addendums, Sharfoo will not provide your information to third parties without your consent, unless we believe in good faith that we are required or permitted to do so under applicable laws.

g. Does Sharfoo Use Cookies or Other Similar Technologies?
We use cookies and similar local storage technologies. A cookie is a small text file that is stored on your computer when visiting a website. This text file stores information that can be read by the website when visiting it again at a later date. Some of these cookies are necessary because otherwise the site is unable to function properly. Other cookies are convenient for the visitor: they remember your username in a secure way as well as your language preferences, for example. Cookies mean that you do not need to fill out the same information each time you visit a website.

We use cookies:
• to help us maintain your session when you use the Services and/or any Additional Service;
• to enhance security of our systems;
• to store your preferences and provide customized services to you; and
• to help us understand how people use the Services and to improve them.

By continuing to use the Services, you consent to our use of cookies and similar technologies in accordance with this Privacy Policy.

Most Internet browsers allow you to control whether or not to accept cookies. If, however, you deactivate cookies or limit the ability to set cookies, you may not be able to obtain the full benefit of the Website or access all of its functions, which may limit your overall user experience.

5. Your Choices, Your Rights
There is a possibility that Sharfoo may obtain personal information relating to individuals who are currently not the users of the Services. Please note that, regardless of whether or not you are a user of the Services, you have the choices and rights set out in this section if we hold your personal information.

a. How Do I Control My Information?
Subject to applicable law (including any exemptions or derogations under such law), you may have a right to access your personal information, to have errors in your personal information rectified, and to object to the processing of your personal information on legitimate grounds.

You can exercise some of these rights directly within the Sharfoo App at any time. For example:
• under your “Profile” in “Settings” in the App, you can confirm and/or revise your phone number, and you can confirm and revise your display name and profile picture; and
• under “Accounts” in “Settings” in the App, you can confirm and/or revise your registered e-mail address. You can also delete your registered e-mail address or de-link your Facebook account.

To exercise any of your other rights under applicable law, you may contact us using the web site or the appropriate location in our App. Upon verification of your identity, we will respond to your request within a reasonable period of time, and in accordance with relevant laws. If you would like to send us a written request, please refer to Section 6.a for our mailing address.

If you no longer wish to use the Service or if you no longer wish to consent to Sharfoo’s collection and use of your personal information, you may choose to delete your entire Account directly through the Sharfoo App. We will delete your information in accordance with Section 4.d.

b. What If I Change My Mind?
If you change your mind regarding how much information you wish to continue to share or disclose on the Services going forward, you can always change the settings in the Sharfoo App relating to, for example:

• your profile information (e.g., your profile picture, your display name, or a personal phrase shown under the status message);
• whether to block or unblock certain Sharfoo users;
• whether to allow other Sharfoo users, who already have your phone number, to reach you via Sharfoo; or
• whether and with whom to share or not share your posts on your Timeline.

6. Other Important Information

a. Questions/Comments/Concerns
If you have any questions, comments, or concerns about this Privacy Policy or our other privacy policies or practices, please contact us via the web site or the appropriate location in App or by writing to:

Sharfoo Corporation
Attn: Privacy Policy

Unit 401, 4^th Floor IT Building
47, Kyeondae-ro 17-gil, Buk-gu,

Daegu, Republic of Korea

41566

b. Changes to This Privacy Policy
We may modify our Privacy Policy from time to time for various reasons to improve our privacy practices, to reflect changes to our Service, and to comply with relevant laws. 

When we make any material changes to our Privacy Policy, we will notify you on our Services, or by other reasonable means. We encourage you to review changes carefully. If you agree to the changes, then please continue to use our Service. If, however, you do not agree to any of the changes and you no longer wish to use our Services, you may choose to close your Account. Continuing to use our Services after a notice of changes has been communicated to you or published on our Services constitutes your acceptance of the changes and consent to the modified Privacy Policy.

Appendix of Personal Information Processing Policy for Korean User

The Company provides the personal information processing policy to give what kind of information we collect, how to use the collected information, with whom we share(consign or provide) it if necessary, when or how to break the purpose-achieved-information which was aimed at and so on for improving transparency. Through this appendix we inform you of additional disclosing issues required by the Korea’s Information Protection related Regulation

1. Providing the Personal Information.
The Company does not provide the personal information to others without the user’s consent. However, only if the user consents directly to provide the personal information to others to use any service from other affiliates we provide the personal information. Also when the Company faces the obligations to provide the personal information by the related regulations we provide it, too.  

2. Personal Information Destruction Process and Method
The Company will instantly destruct the personal information when you withdraw from our App. Only when the law has prefixed measures we will follow the related regulations.

a. Destruction Process
When the purposes of collecting any personal information is fulfilled the Company keeps the personal information you provide for the service use for the certain period according to the inner policy and information protection reason(refer to Keeping and Use Period) by the law and destructs it. This personal information cannot be used in other purpose except a law related case.

b. Destruction Method
The printed personal information in paper is destructed by a paper grinder. The personal information stored in the electronic file type is deleted by using the technical method which cannot permit any replay.

3. Personal Information Keeping and Using Period
The Company destructs the personal information you provide when the purposes of collecting any personal information is fulfilled or when there is no legal basis to preserve any personal information. There are some exceptional regulations as below to preserve the information in case of the costumer protection related laws and so on in the electronic trade and so on. We retain your personal information according to the rules as follow

• Costumer Protection Law in the electronic trade and so on

- Contract or Withdrawal related record: 5 years preservation;
- Payment and the Goods and so on supply related record: 5 years preservation
- Costumer dissatisfaction or Dispute management related record: 3 years preservation

4. User and Legal Representative’s Right and Using Method
You can at any time see or change your personal information in the “Settings” > “Profile” menu in the App.
• Costumers can any time withdraw the consent for the collection and use of their personal information through the withdrawal and so on.  
• In case of any child under 14, a legal representative can have a right to see or change the personal information of the child and to withdraw the consent for the collecting and using the personal information. 

• When you ask the correction for the error in your personal information, the personal information won’t be served before the correction. Also in case that any false personal information was already given to a third party we will instantly inform the third party of the correction result and rectify the error.  

5. Security for the Personal Information Measures
The Company takes the administrative and technical protection measures for users’ personal information to protect securely according to the related rules and regulations.

a. Administrative Protection Measures
There will be the Operation of an exclusive Information Protection division, Establishment and Operation of Information Protection Management System, Minimizing of a personal information agent, Periodical Education for the Personal Information Protection and so on

b. Technical Protection Measures 

There will be Important Personal Information Encryption, Communication Block Encryption, Vaccine Program, and Frequent Back-up and so on in the Technical Protection Measures.

c. Physical Protection Measures
System will be installed and operated in the strictly controlled area from outside access.

6. Personal Information Protection Manager

The Company designated a personal information protection manager as below for the users’ personal information related inquiries, complaints handling and so on.

Personal Information Protection Manager

Name : Solrim Kim

Affiliate : Management Generalization

Position : General Manager

Tel: 82-53-622-8572