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Privacy Policy

Effective date · To be set after legal review

This document is a draft. It will be published in final form, with an effective date, after legal review.

The Korean original is the legally binding version of this document; the Japanese and English versions are reference translations.

HOLOFLEX treats personal data with care and complies with the Personal Information Protection Act and other applicable law. This policy explains what personal data the Service processes, for what purposes, and for how long it is retained.

1. Personal data collected and how it is collected

The Service collects data entered by the user during registration, purchase and enquiry submission. Other items may be generated or collected automatically in the course of using the Service.

ContextDataPurpose
Registration (required)Email address, password (stored encrypted), display name, account typeIdentifying the account and providing the Service
PurchaseDepositor name, order amount and commission rate, order and approval historyPayment and supply of content, purchase history
Enquiries (including without sign-in)Name, email address, messageResponding to enquiries and replying with the outcome
Collected automaticallyIP address, browser information, access timestampsOperating the Service and preventing abuse

2. Purposes of processing

  • Confirming intent to register and maintaining the account
  • Performing the sale and purchase of content and settling payments
  • Issuing and managing download entitlements
  • Handling enquiries and complaints and replying with the outcome
  • Meeting obligations under applicable law

3. Retention period

Personal data is destroyed without delay once its purpose has been achieved. Records that applicable law requires to be preserved are kept for the periods below.

RecordsPeriodBasis
Contracts and withdrawal of purchase5 yearsE-Commerce Act
Payment and supply of goods5 yearsE-Commerce Act
Consumer complaints and dispute resolution3 yearsE-Commerce Act
Labelling and advertising6 monthsE-Commerce Act
Access logs3 monthsProtection of Communications Secrets Act

4. Disclosure to third parties

The Service does not disclose personal data to third parties, except where there is a specific provision of law or where an investigative authority makes a request under the procedures and methods prescribed by law.

5. Processors

Processing is entrusted to the parties below to the extent needed to operate the Service. They are supervised so that personal data is not processed for purposes beyond the entrusted work.

ProcessorEntrusted work
Supabase Inc.Database, authentication and file storage
Vercel Inc.Web hosting and request handling

6. Transfer of personal data abroad

Personal data is transferred abroad as set out below. A user may decline the transfer, in which case registration and use of the Service are not available.

ItemSupabase Inc.Vercel Inc.
RecipientSupabase Inc. (a US company)Vercel Inc. (a US company)
Country of transferJapan (Tokyo)Japan (Tokyo)
Time and method of transferTransmitted over the network at the time the Service is usedTransmitted over the network at the time the Service is used
Data transferredEmail address, password (encrypted), display name, account type, order and enquiry data, uploaded files, access logsThe items above, as handled while processing requests
Recipient’s purposeOperating the database, authentication and file storageRunning the web application and handling requests
Retention periodUntil the account is closed or the processing agreement endsUntil the account is closed or the processing agreement ends

7. Destruction of personal data

Personal data is destroyed without delay once the retention period has passed or the purpose has been achieved. Data held electronically is deleted so that it cannot be recovered.

8. Your rights and how to exercise them

A user may at any time request access to, correction of, deletion of, or suspension of the processing of their personal data. Requests can be made through the contact below and are acted on without delay once verified.

9. Cookies

The Service uses cookies to remember the chosen display language and to keep the user signed in. Cookies can be refused in the browser settings, in which case features requiring sign-in cannot be used.

CookiePurpose
holo-localeStores the selected display language
Authentication cookiesMaintain the signed-in session

10. Security measures

  • Passwords are stored using a one-way encryption scheme that cannot be reversed.
  • Purchased source files are held in private storage and served only through time-limited links to users whose entitlement has been verified.
  • Row-level access control is applied in the database so that a user can reach only their own records.
  • Administrative screens that handle personal data are reachable only by authorised accounts.

11. Data protection officer

A data protection officer is appointed to oversee the processing of personal data and to handle user complaints.

Name
Yoon Jeongwook
Role
CEO / Business Administration
Phone
010-9909-8075
Email
cs@theface.link

12. Remedies

For advice about or to report an infringement of personal data rights, the following bodies can be contacted.

  • Personal Information Dispute Mediation Committee (1833-6972 / www.kopico.go.kr)
  • Privacy Infringement Report Centre (118 / privacy.kisa.or.kr)
  • Supreme Prosecutors’ Office, Cyber Investigation Division (1301 / www.spo.go.kr)
  • National Police Agency, Cyber Bureau (182 / ecrm.police.go.kr)

13. Changes to this policy

Where this policy changes, the change and its effective date are announced on the Service.