Betaphonia
Last updated · 2025-02-07

Reflecto · Privacy Policy

Jeon Seokho ("the Developer") takes the privacy of users of the mobile application (hereinafter referred to as the "App") and related services (hereinafter collectively referred to as the "Service") very seriously. The following Privacy Policy outlines the handling of users' personal information.

By providing personal information to the Developer, you are deemed to have fully understood and agreed to the collection, use, and provision of personal information as described in this Privacy Policy.

If you do not agree with this Privacy Policy, please refrain from providing personal information. The Developer will notify the reasons for and contents of any amendments to this Privacy Policy via the website.

This Privacy Policy is effective as of February 7, 2025.

Article 1 (Purpose of Processing Personal Information)

The Developer processes personal information for the following purposes. The personal information being processed will not be used for purposes other than those stated below. If the purpose of use is changed, necessary actions such as obtaining separate consent will be taken under the Personal Information Protection Act (PIPA).

  • No personal information is stored by the App.
  • The App includes AdMob (advertising program). You can review AdMob's privacy policy here.
  • For service improvement, Google Analytics, Firebase Crashlytics, Facebook, and Flurry Analytics are used to collect the following information:
    • App installation, deletion, and update events
    • Device model and operating system
    • App events, location, gender, age, and referral sources

Article 2 (Processing and Retention Period of Personal Information)

The Developer processes and retains personal information within the retention and use period agreed upon by the data subject when collecting the personal information or as required by law. The retention and processing periods for personal information are as follows:

Article 3 (Provision of Personal Information to Third Parties)

The Developer processes personal information within the scope specified in Article 1 (Purpose of Processing Personal Information) and provides personal information to third parties only with the consent of the data subject or as permitted by law, such as Articles 17 and 18 of the Personal Information Protection Act. The Developer provides personal information to the following third parties:

Article 4 (Entrustment of Personal Information Processing)

The Developer does not entrust the processing of personal information to others.

Article 5 (Rights and Obligations of Data Subjects and Legal Representatives and Methods of Exercise)

Data subjects may exercise the following rights regarding personal information at any time:

  • Request access, correction, deletion, or suspension of processing of personal information.
  • Requests under paragraph 1 can be made to the Developer via written communication, email, or fax, in accordance with Article 41, Paragraph 1 of the Enforcement Decree of the Personal Information Protection Act. The Developer will respond promptly.
  • Requests can also be made through a legal representative or an authorized agent. In this case, a power of attorney must be submitted in accordance with Form No. 11 of the Personal Information Protection Act.
  • Requests for access or suspension of processing of personal information may be restricted under Articles 35(5) and 37(2) of the Personal Information Protection Act.
  • Requests for correction or deletion of personal information cannot be made if the information is required to be collected by law.
  • The Developer will verify the identity of the individual or their authorized agent before processing any requests.

Article 6 (Personal Information Items Processed)

The Developer processes the following personal information:

  • App: None

Links to the privacy policies of third-party service providers used by the App are as follows:

Article 7 (Destruction of Personal Information)

The Developer destroys personal information without delay when it becomes unnecessary, such as upon expiration of the retention period or achievement of its purpose.

  • Destruction Procedure: The Developer selects personal information that requires destruction and obtains approval from the Developer's data protection officer before destruction.
  • Destruction Method: Electronic files are irreversibly deleted, and paper documents are shredded or incinerated.

Article 8 (Measures to Ensure the Security of Personal Information)

The Developer takes the following measures to ensure the security of personal information:

  • Managerial Measures: Establishment and implementation of internal management plans, regular employee training, etc.
  • Technical Measures: Management of access rights to personal information processing systems, installation of access control systems, encryption of unique identifiers, etc.
  • Physical Measures: Access control to computer rooms, document storage rooms, etc.

Article 9 (Collection and Use of Advertising Identifiers)

  • The Developer may collect the ADID/IDFA of users. ADID/IDFA refers to advertising identifiers used in mobile apps to measure tailored service delivery or advertising environments.

How to Opt-Out

  • Android: Settings → Google Settings → Ads → Opt-out of Ads Personalization
  • iOS: Settings → Privacy → Advertising → Limit Ad Tracking

Article 10 (Additional Information for U.S. Users)

The Developer does not sell personal information. Under the California Consumer Privacy Act (CCPA), U.S. users have the following rights:

  • The right to know what personal information is collected and how it is used or shared
  • The right to request deletion of personal information
  • The right to opt out of the sale of personal information

Requests can be made via email to skylur@naver.com.

Article 11 (Additional Information for Japanese Users)

Personal information of Japanese users may be transferred abroad for advertising and service improvement purposes. Such transfers comply with the Japanese Act on the Protection of Personal Information (APPI), and appropriate safeguards are implemented. Requests regarding personal information can be submitted via written communication or email.

Article 12 (Contact Information of the Data Protection Officer)

Users can report any personal information protection-related complaints while using the Developer's services. The Developer will respond promptly and sufficiently to such reports.

For further assistance with privacy concerns, users may contact the following organizations:

Article 13 (Notification Obligations)

In case of any addition, deletion, or modification to this Privacy Policy, users will be notified at least seven days before such changes take effect via the Developer's website. For major changes affecting user rights, such as changes in the collection and use of personal information or third-party provisions, notification will be given at least 30 days in advance.

  • Announcement Date: February 7, 2025
  • Effective Date: February 7, 2025