Privacy Policy

Privacy Policy

GloZ.Inc (hereinafter referred to as the “Company") establishes and publishes this Privacy Policy pursuant to Article 30 of the Personal Information Protection Act. This Policy sets forth the procedures and standards for the processing of personal information and ensures prompt and effective handling of related grievances.

Article 1 (Purpose of Processing Personal Information)

The Company processes personal information for the following purposes. Personal information will not be used for any purpose other than those stated below. If the purpose of processing changes, the Company will take necessary measures, such as obtaining separate consent in accordance with Article 18 of the Personal Information Protection Act.

1. Provision of Free Trial Services and Customer Management
a. Processing personal information for user identification and authentication related to free trial services, as well as for preventing service unauthorized use of service.

b. Processing personal information for customer management related to the conversion to paid services.

2. Demo Presentation, Service Adoption Inquiry and Customer Management
a. Processing personal information to identify and authenticate users requesting a demo or service adoption inquiry, and to prevent service misuse.

b. Processing personal information to respond to user requests and inquiries related to demo presentations or service adoption.

3. Management and Processing of Subscription Payments
a. Processing personal information to manage and operate subscription details and payment information upon conversion to a paid service.

4. Customer Support and Inquiry Handling
a. Processing personal information to manage and respond to inquiries via chat and email. t@google.

5. E’nuff Service User Guide and Free Trial Notifications a. Providing the user guides for the E’nuff service.

b. Sending pre-notifications before the free trial ends.

c. Sending pre-notifications before payments are processed.

6. Analyzing records of enuff.space service usage and access frequency, generating statistical data on service usage, providing tailored services and advertisements based on service analysis and statistics.

Article 2 (Retention and Processing Period of Personal Information)

1. The Company processes and retains personal information within retention period prescribed by law or the period agreed upon when collecting personal information from the data subject.

2. The retention period for each category of personal information is as follows:
a. Free Trial Service Registration and Management: Until the user withdraws from the free trial service (in cases of withdrawal after trial expiration, no request for an extension, or deletion request).

b. Preparation and Support for Free-to-Paid Conversion: Up to one year from the end date of the free trial (in cases of withdrawal after trial expiration, no request for deletion or withdrawal).

c. However, in the following cases, personal information will be retained until the specified period expires:
i. Records on transactions such as display, advertising, contract contents and performance in accordance with Article 6 of the Act on Consumer Protection in Electronic Commerce, etc.

1. Records of advertisements and promotional materials: 6 months
2. Records of contracts and withdrawal of offers: 5 years
3. Records of payments and supply of goods/services: 5 years
4. Records of customer complaints and dispute handling: 3 years
ii. Retention of Communication Records under the Protection of Communications Secrets Act, Article 15-2
1. Computer communication and internet logs, as well as access location tracking data: 3 months

Article 3 (Categories of Personal Information Processed)

The Company processes the following items of personal information:

1. Personal Information Processed with Consent

The Company processes personal information with the data subject’s consent in accordance with Article 15(1)(i) and Article 22(1)(vii) of the Personal Information Protection Act.

Handler	Category	Purpose of Collection and Use	Collected Data	Retention and Usage Period
TAD, LPM	Account Registration (Email, Google, LinkedIn)	- Verification and management of account registration - Provision of member services - Service delivery - Service improvement - Prevention of duplicate registrations and fraudulent use - Service notifications - Handling of service-related inquiries and complaints	Required Information: 1. Full Legal Name 2. Time zone Optional Information: 1. Job title 2. Mobile number 3. Phone number 4. Fax number	- Immediately deleted upon account termination - User identification data (CI, mobile number, email) is stored in a separate withdrawal database and deleted after one year to prevent fraudulent use (hashed for security) - Retained for the legally required period if
LPM	User Inquiries	Service provision	- Message transmission and reception history	- Retained until account termination - Immediately deleted upon account termination
Client	Account Registration (Email, Google, LinkedIn)	- Verification and management of account registration - Provision of member services - Service delivery - Service improvement - Prevention of duplicate registrations and fraudulent use - Service notifications - Handling of service- related inquiries and complaints	Required Information: 1. Company’s Business Registration Number 2. Company email 3. Time zone 4. Company address Optional Information: 1. Mobile number 2. Phone number 3. Fax number 4. Website URL	- Immediately deleted upon account termination - User identification data (CI, mobile number, email) is stored in a separate withdrawal database and deleted after one year to prevent fraudulent use (hashed for security) - Retained for the legally required period if applicable
Pro	Account Registration (Email, Google, LinkedIn)	- Verification and management of account registration - Provision of member services - Service delivery - Service improvement - Prevention of duplicate registrations and fraudulent use - Service notifications Handling of service-related inquiries and complaints	Required Information: 1. Email address 2. Full Legal Name 3. Time zone 4. Date of birth 5. Address 6. Years of experience 7. Resume (Proof of Work Experience) 8. Applying role and languages Optional Information: 1. Name pronunciation 2. Gender information (Pronouns) 3. Preferred name 4. Mobile number 5. Phone number	- Immediately deleted upon account termination - User identification data (CI, mobile number, email) is stored in a separate withdrawal database and deleted after one year to prevent fraudulent use (hashed for security) - Retained for the legally required period if applicable
Pro	Financial Information 1. Payment Withdrawal via Wise 2. Payment Withdrawal for International Transfers	- Processing payment withdrawals - Verifying bank account ownership and preventing fraudulent accounts - Confirming required details for international transfers	Required Information: 1. Proof of identification (Copy of ID, Bank Statement) 2. Resident Registration Number 3. Bank name 4. Account number 5. Residential address 6. W8/W9/Business license Optional Information: 1. Bank routing number 2. SWIFT code/BIC 3. IBAN	- Immediately deleted upon account termination - User identification data (CI, mobile number, email) is stored in a separate withdrawal database and deleted after one year to prevent fraudulent use (hashed for security) - Retained for the legally required period if applicable
	Financial Information 1. Payment Withdrawal via PayPal	- Payment withdrawal - Verification of account ownership and prevention of fraudulent accounts	Required Information: 1. Paypal email address 2. Proof of identification (Copy of ID) 3. Resident Registration Number 4. Residential address 5. W8/W9/Business license	- User identification data (CI, mobile number, email) is stored in a separate withdrawal database and deleted after one year to prevent fraudulent use (hashed for security) - Retained for the legally required period if applicable
	Financial Information 1. Payment Withdrawal via Domestic Bank Transfer	- Payment withdrawal - Verification of account ownership and prevention of fraudulent accounts	Required Information: 1. Proof of identification (Copy of ID, Bank Statement) 2. Resident Registration Number 3. Bank name 4. Account number 5. Residential address Optional Information: 1. Bank routing number 2. SWIFT code/BIC 3. IBAN	- User identification data (CI, mobile number, email) is stored in a separate withdrawal database and deleted after one year to prevent fraudulent use (hashed for security) - Retained for the legally required period if applicable
	User Inquiries	- Service provision	- Message transmission and reception history	- Retained until account termination - Immediately deleted upon account termination
Pro (Sole proprietor)	Financial Information 1. Payment Withdrawal via Domestic Bank Transfer	- Issuance of tax invoices - Payment withdrawal and verification of account ownership	Required Information: 1.Business verification documents (Copy of Business Registration Certificate, Business owner’s bank statement) 2.Business Registration Number 3.Company name (Trade name) 4.Bank name and account number 5.Business address 6.Business type 7.Business category 8.Tax invoice email address 9.Tax invoice manager 10.Tax invoice manager’s contact information 11.Bank name 12.Account number 13.Account holder name	- User identification data (CI, mobile number, email) is stored in a separate withdrawal database and deleted after one year to prevent fraudulent use (hashed for security) - Retained for the legally required period if applicable
LPM, TAD, Client, Pro	Customer Inquiries and Consultation	- Recording inquiry details and resolving disputes - Identity verification	Required Information: 1. Email address Optional Information: 2. Name ※ Additional personal information may be requested depending on the type of inquiry or report.	Stored for three years in accordance with the Act on Consumer Protection in Electronic Commerce and then deleted.

Recipient	Purpose of Provision	Provided Information	Retention and Usage Period
LPM, TAD	- Assignment of translation task permissions	- Email address - Full Legal Name - Time zone - Date of birth - Address - Years of experience - Resume (Proof of work experience) - Applying role and languages (Application information) - Name pronunciation - Gender information (Pronouns) - Preferred name - Mobile number - Phone number	- Immediately deleted upon account termination
LPM, TAD, Accounting team	- Payment withdrawal via Wise - Payment withdrawal for international transfers	- Proof of identification (copy of ID, bank statement) - Resident Registration Number - Bank name - Account number - Residential address - W8/W9/Business license - Bank routing number - SWIFT code/BIC - IBAN	- Immediately deleted upon account termination
LPM, TAD, Accounting team	- Payment withdrawal via Paypal	- Paypal email address - Proof of identification (copy of ID) - Resident Registration Number - Residential address - W8/W9/Business license	- Immediately deleted upon account termination
LPM, TAD, Accounting team	- Payment withdrawal for domestic bank transfer	- Proof of identification (copy of ID, bank statement) - Resident Registration Number - Bank name - Account number - Residential address - Bank routing number - SWIFT code/BIC - IBAN	- Immediately deleted upon account termination
LPM, TAD, Accounting team	- Payment withdrawal	- Business verification documents (Copy of Business Registration Certificate, Business owner’s bank statement) - Business Registration Number - Company name (Trade name) - Bank name and account number - Business address - Business type - Business category - Tax invoice email address - Tax invoice manager - Tax invoice manager’s contact information - Bank name - Account number - Account holder name	- Immediately deleted upon account termination
Pro	Information sharing when necessary for collaborative tasks	- Email address - Full Legal Name
LPM, Accounting team	Invoice processing (Information collected from all clients)	Required information: - Business registration number - Company email - Time zone - Company address Optional information: - Mobile number - Phone number - Fax number - Website URL
LPM, Accounting team	Invoice processing for clients who selected “Korea” as their office location	- Tax invoice manager	- Immediately deleted upon account termination
LPM, Accounting team	Invoice processing for clients who selected “Japan” as their office location	- Bank name - Account holder name - Company name (Trade name) - Company address - TAX ID - Business Registration Number	- Immediately deleted upon account termination
LPM, Accounting team	Invoice processing via bank transfer for clients who selected “United States” as their office location privacy@slac	- Bank name - Account holder name - Company name (Trade name) - Company address	- Immediately deleted upon account termination
	Invoice processing via check for clients who selected “United States” as their office location	- Company name (Trade name) - Company address	- Immediately deleted upon account termination
	Invoice processing via PayPal transfer for clients who selected “United States” as their office location Invoice processing via Wise transfer for clients who selected “United States” as their office location	- PayPal account information - Company name (Trade name) - Company address - Wise account information - Company name (Trade name) - Company address
LPM, Accounting team	Invoice processing via bank transfer for clients who selected “Singapore” as their office location	- Bank name - Account holder name - Company name (Trade name) - Company address - TAX ID - UEN ID	- Immediately deleted upon account termination
	Invoice processing via Stripe transfer for clients who selected “Singapore” as their office location	- Stripe account information - Company name (Trade name) - Company address - TAX ID - UEN ID
	Invoice processing via PayPal transfer for clients who selected “Singapore” as their office location	- PayPal account email - Company name (Trade name) - Company address - TAX ID - UEN ID
	Invoice processing via Wise transfer for clients who selected “Singapore” as their office location	- Account number - Company name (Trade name) - Company address - TAX ID - UEN ID
	Invoice processing via Airwallex transfer for clients who selected “Singapore” as their office location	- Account number - Company name (Trade name) - Company address - TAX ID - UEN ID

2. When entering into an outsourcing contract, the Company complies with Article 26 of the

Personal Information Protection Act by specifying in the contract or related documents the prohibition of processing personal information beyond the intended purpose, technical and managerial security measures, restrictions on subcontracting, supervision of the subcontractor, and liability for damages. The company also monitors whether the contractor processes personal information securely.

3. If there are any changes to the details of the outsourced tasks or the contractors, the company will promptly disclose such changes through this Privacy Policy.

Article 4 (Provision of Personal Information to Third Parties)

1. The company processes personal information only within the scope specified for its intended purposes and provides personal information to third parties only with the data subject’s consent or when permitted by special provisions of the law, such as Articles 17 and 18 of the Personal Information Protection Act. Personal information will not be shared with third parties beyond these cases.

2. To ensure seamless service provision, the company may share personal information with third parties only with the data subject’s consent and only to the minimum extent necessary. Some provided information may be masked (*) for privacy protection.

3. In cases where personal information is used or provided additionally without the data subject’s consent as permitted by law, the following criteria will be applied:
a. Relevance to the original purpose of collection
b. Predictability of additional use or provision based on the context of collection or processing practices
c. Unfair infringement on the data subject’s rights and interests
d. Implementation of security measures such as pseudonymization or encryption

Article 5 (Overseas Transfer of Personal Information)

1. The company entrusts certain tasks to overseas entities as follows.

Entrusted Entity	AWS	Google, Inc. (Google Analytics)	Freshdesk	MailChimp	Slack
Purpose of Entrustment	Customer management for E’nuff service users	- Analysis of user behavior data to improve and develop new services - Verification of user access information and identifiers	Handling and responding to customer inquiries	Sending emails	Sending notification messages
Entrusted Items	All data collected during the use of the E’nuff service	Cookie information collected during the use of the E’nuff service	Email address	Email address	Email address
Country of Transfer, Contact Information	United States, South Korea aws-korea-privacy@amazon.com	United States googlekrsupport@google.com com	United States privacy@freshworks.com	United States privacy@mailchimp.com	United States privacy@slack.com
Time and Method of Transfer	Transferred to the AWS cloud via the network upon account registration completion	Transferred via the network during service usage	Transferred via the network during service usage	Transferred via the network each time the service is used	Transferred via the network each time the service is used
Retention and Usage Period	Until service withdrawal or the termination of the outsourcing contract, or as required by law.	Until account termination or the termination of the outsourcing contract, or as required by law	Until account termination or the termination of the outsourcing contract, or as required by law	Until account termination or the termination of the outsourcing contract, or as required by law	Until account termination or the termination of the outsourcing contract, or as required by law

2. The company utilizes cloud services only after thoroughly reviewing the cloud service provider’s

compliance with information security and personal data protection standards. Cloud service providers do not have access to the Company’s customer personal information.

Article 6 (Destruction of Personal Information)

1. The company promptly destroys personal information without delay when the retention period expires or the processing purpose has been achieved, making the data no longer necessary. 2. If the retention period agreed upon by the data subject has expired or the processing purpose has been fulfilled, but the company is required by law to continue storing the data, the personal information will be transferred to a separate database (DB) or stored in a different location.

3. The procedures and methods for the destruction of personal information are as follows: a. Destruction Procedure
i. The company identifies personal information subject to destruction and proceeds with its disposal upon approval from the Personal Information Protection Officer.

b. Destruction Method

i. Personal information stored in electronic files is permanently deleted in a manner that prevents recovery. Personal information recorded or stored in paper documents is shredded or incinerated for disposal.

Article 7 (Destruction of Personal Information for Inactive Users)

1. If a user does not request withdrawal or deletion after completing the free trial, due to additional internal review or a deferred adoption decision, their personal information will be retained for one year from the trial end date.

2. If there is no request for service reuse, free-to-paid subscription conversion, or reconsideration of adoption within one year, the user’s personal information will be deleted.

3. The company will notify users at least 30 days in advance via email, text message, or other available means about the impending deletion of their personal information, including the deletion date and the specific data to be erased.

4. If users do not wish for their personal information to be deleted, they must contact the company before the retention period expires.

Article 8 (Rights and Obligations of Data Subjects and Legal Representatives, and Methods of Exercise)

1. Data subjects may exercise their rights at any time to request the access, correction, deletion, or suspension of processing of their personal information.

2. These rights may be exercised through a written request, email, or chat consultation in accordance with Article 41(1) of the Enforcement Decree of the Personal Information Protection Act, and the company will take prompt action accordingly.

3. The rights mentioned above may also be exercised by the data subject’s legal representative or an authorized agent. In such cases, a power of attorney must be submitted in accordance with Form No. 11 of the Notification on Personal Information Processing Methods (No. 2020-7).

4. Requests for access to or suspension of personal information processing may be restricted under Article 35(4) and Article 37(2) of the Personal Information Protection Act.

5. Requests for correction or deletion of personal information cannot be made if the data is required to be retained under other applicable laws.

6. The company verifies the identity of the requester to confirm whether they are the data subject or a duly authorized representative before processing any request for access, correction, deletion, or suspension of processing of personal information.

Article 9 (Measures to Ensure the Security of Personal Information)

The company implements the following measures to ensure the security of personal information:

1. Administrative Measures
a. Establishment and implementation of an internal management plan, along with

regular employee training
2. Technical Measures
a. Access authority management for personal information, installation of access control systems, encryption of personal information, implementation and updates of security programs to prevent hacking, and storage and protection of access logs from tampering
3.
Physical Measures a. Access control for workspaces

Article 10 (Installation, Operation, and Refusal of Automated Personal Information Collection Devices)

1. The company uses cookies to store and retrieve user information as needed to provide personalized services.

2. Cookies are small pieces of data sent by the website’s server to the user’s web browser, which may be stored on the user’s computer hard drive.

a. Purpose of Cookies: Used to analyze users’ visit history and usage patterns across services and websites, track popular search terms, and verify secure access to provide optimized information to users.

b. Cookie Installation, Operation, and Refusal: Users can refuse cookie storage by adjusting the settings in their web browser under Tools > Internet Options > Privacy Settings.

c. Refusing cookie storage may limit access to certain personalized services.

Article 11 (Collection, Use, and Refusal of Behavioral Data)

The company does not collect personally identifiable information through Google Analytics and does not combine collected data with personally identifiable information obtained from other sources.

1. The company collects and uses behavioral data during service usage to provide users with personalized and optimized services.

2. The company collects behavioral data as follows.

Categories of Collected Behavioral Data	User’s service visit history, activity logs, search history, and advertising identifier
Methods of Behavioral Data Collection	-Installation and operation of cookies -Automatic collection and transmission of generated data through tracking tools when visiting web/app sites Automatic collection and transmission of generated data through tracking tools when running the app
Tools Used for Data Collection	Google Analytics
Purpose of Behavioral Data Collection	-Analyzing user service usage patterns to provide recommended services, including advertisements Utilizing behavioral data analysis as a metric for new service development and service improvements
Retention, Usage Period, and Subsequent Data Processing Methods	Retained for one year from the date of collection and then deleted

3. Data subjects can block or allow online personalized advertisements by adjusting their web

browser’s cookie settings. However, modifying cookie settings may affect the use of certain services, such as automatic website login.

a. Enabling or blocking personalized ads through web browsers

Microsoft Edge

* Click the “…” icon in the upper-right corner of Edge, then select Settings. * In the settings menu, click “Privacy, Search, and Services” on the left panel, then choose the desired level of Tracking Prevention.

* Enable or disable “Always use ‘Strict’ Tracking Prevention when browsing InPrivate.”

* In the Privacy section, choose whether to send a “Do Not Track” request.

Chrome

* Click the “⋮” (vertical three dots) icon in the upper-right corner of Chrome, then select Settings.

* In the Settings page, go to the “Privacy and Security” section and click “Site Settings.”
* Under the “Content” section, select “Cookies and Site Data.”
* Check the box for “Block third-party cookies.”

4. Data subjects may contact the following for inquiries regarding behavioral data, exercising

opt-out rights, or reporting complaints.

Article 12 (Data Protection Officer)
1. The company appoints the following Data Protection Officer (DPO), who is responsible for overseeing personal information processing, handling complaints, and providing remedies related to personal data processing.

[Data Protection Officer and Responsible Department] Name: Kim Ho-Kyun
Department: Development Team
Position: CTO
Phone Number: 070-8667-1191

Email: support@enuff.space

Fax: 0303-3442-5581

2. Data subjects may contact the Data Protection Officer and the responsible department regarding any inquiries, complaints, or requests for remedies related to personal data protection while using the company’s services. The company will respond and process such inquiries without delay.

Article 13 (Remedies for Infringement of Rights)

Data subjects may seek remedies for personal information breaches by requesting dispute resolution or consulting the Personal Information Dispute Mediation Committee or the Korea Internet & Security Agency’s Personal Information Infringement Report Center. For additional inquiries regarding personal data breaches or consultations, please contact the following organizations:

1. Personal Information Dispute Mediation Committee: 1833-6972 (www.kopico.go.kr) 2. Personal Information Infringement Report Center: 118 (privacy.kisa.or.kr)
3. Supreme Prosecutors’ Office: 1301 (www.spo.go.kr)
4. Korean National Police Agency: 182 (ecrm.cyber.go.kr)

The company is committed to protecting the data subject’s right to self-determination over personal information and strives to provide support for inquiries and remedies related to personal data breaches. If you need to report an issue or seek consultation, please contact the department below.

[Customer Support for Personal Data Protection Inquiries and Reports]

Department: Development Team

Contact: 070-8667-1191

Email: support@enuff.space

Data subjects whose rights or interests have been infringed due to a decision or inaction by a public institution concerning requests made under Article 35 (Access to Personal Information), Article 36 (Correction and Deletion of Personal Information), or Article 37 (Suspension of Personal Information Processing) of the Personal Information Protection Act may file an administrative appeal in accordance with the Administrative Appeals Act.

[Central Administrative Appeals Commission]

110 (www.simpan.go.kr)

Article 14 (Processing of Personal Location Data)
The company uses users’ location data only within the E’nuff app and does not transmit or store it on any servers.

Article 15 (Changes to the Privacy Policy)
1. This Privacy Policy has been effective since July 3, 2024.