LUPLE (hereinafter referred to as 'Company' or 'LUPLE') has established and published the following guidelines for handling personal information in order to protect the personal information of the data subjects and handle the related complaints quickly and smoothly in accordance with the Personal Information Protection Act.

THIS PRIVACY POLICY APPLIES TO RESIDENTS OF OR USERS WHO ACCESS OUR SERVICE FROM OUTSIDE OF KOREA. IF YOU ARE A RESIDENT OF, OR ACCESS OUR SERVICE FROM WITHIN KOREA, PLEASE REFER TO OUR PRIVACY POLICY LOCATED [LUPLE KOREAN PRIVACY LINK].

Article 1 Purpose of processing personal information

The company processes personal information for the following purposes. The personal information processed shall not be used for purposes other than the followings, and if the purpose of use changes, we will take necessary measures such as obtaining separate consent subject to Article 18 of the Personal Information Protection Act.

1. Membership registration and management

Personal information will be processed for the purposes of confirming the intention to subscribe as a member, identification and authentication according to the provision of membership services, maintenance and management of membership, prevention of illegal or improper use of services, and various notifications and notices.

2. Service provision

We will process personal information for the purpose of providing services, content, and customer services.

3. Grievance handling

Personal information will be processed for the purpose of confirming the identity of the complainant, confirming the complaints, contacting and notifying for fact-finding, and notifying the results of processing.

4. The fulfillment of the claim-obligation relationship when such relationship remains due to service use and supply of goods, etc.

5. Re-subscription and exclusion of illegal or improper use

6. Restriction to subscription of illegal users and the person who has used the service improper way

Article 2 Processing and retention period of personal information

• The company shall process and retain personal information within the retention period and use of personal information in accordance with laws and regulations or within the period of retention and use of personal information agreed upon when collecting personal information from the data subjects.
• Each personal information processing and retention period will be as follows.
  1. Membership subscription and management, grievance handling: Immediately after membership withdrawal. However, in the case of any of the following reasons, it shall be until the end of the reason
     1. If an investigation or investigation in violation of related laws is in progress, it will be until the end of the investigation or examination
     2. Until settlement of the claim-obligation relationship related to service use
  2. Proving tasks records, sleepcoach service, etc: to be deleted without delay after membership widthdrawn
  3. Fulfillment and payment for the provision of goods or services: Until the completion of supply of goods and services, payment of fees, and settlement. However, in the events of any of the following reasons or based on relevant laws and regulations; until the end of the period
     1. Records on transactions such as marks, advertisements and contents of the contracts and execution thereof subject to the 「Act On The Consumer Protection in Electronic Commerce, etc.」
        • Records related to marks and advertisement: 6 months
        • Records related to cancellation of contracts or subscription, payment for and supply of goods, etc: 5 years
        • Records related to resolution of consumer complaints or dispute : 3 years
     2. Storage of communication confirmation data pursuant to Article 41 of the 「Enforcement Decree of the Protection of Communication Secrets Act」
        • Subscribers’ telecommunication date and time, start/end time, other party's subscriber number, frequency of use, The data on tracing a location of information communications apparatus: 1 year
        • Computer communication, Internet log record data, the data on tracing a location of connectors: 3 months
  4. Re-subscription verification and exclusion of illegal or improper use: Up to 60 days from the date of membership withdrawal or disqualification
  5. Restriction on subscription of illegal or improper users: 1 year from the date of the cheating ends

Article 3 Provision of personal information to a third party

The company shall process the user's personal information within the scope notified in 'Article 1 Purpose and Items of Personal Information Processing', and will not use it beyond the scope of consent or provide it to a third party, in principle. However, personal information may be provided to a third party in the following events.

1. In the case of processing and providing in a form that cannot identify a specific individual for statistical writing, academic research or market research

2. When users agree in advance