Sming Privacy Policy

Thank you for enjoying Sming. With the safety of your personal information being our top priority, we ensure to limit the collection and use of such data within the scope to which you consent so we can provide and improve our services (“Service”) properly. This Privacy Policy (“Policy”) states how Sming (“we”, “us” or “our”) handles our user’s (“you” or “your”) personal information. It also describes your rights to such information and options provided for you. This Policy applies to the collection of personal data when you use Sming and visit our website in relation to our Service. You may access and review the latest version of this Policy in full on our website at any time.

1. Purpose

Your privacy and protection of your sensitive data are very important to us. Your personal information will be collected and used solely within the statutory provisions of the applicable data protection laws. Collecting such information is necessary to provide our Service and improve the user experience for you. In providing basic features and special functionalities pursuant to the Terms of Service for which your consent is given, we may require data to validate your identity, including age, account details, and device information. Such information will be also necessary for us to send out individualized notifications, make contents available to you, process your purchases, offer appropriate events and promotions, and prevent or stop the activity that may cause inconvenience or violate our terms or applicable laws.

2. Scope

When you sign up for our Service and as you continue to use the Service, our app or website may collect your telephone number, contacts you saved on your smartphone or another device, username, your login email (Sming account email) and password, and email address(s) you choose to receive news and notifications. You may choose to provide us with your birthday, gender, Service ID, photos (including meta-data), and location data. Device-specific information (e.g. operating system, screen size, and unique device identifiers), IP address, cookies, date of visit, a record of illegitimate use, Service usage, and other payment-related data that can be generated automatically and collected when you use and purchase the Service.

3. Data Types

3.1 Account Information

We will collect your email address and password you provide to create your Sming account. When you sign up with your Facebook account, your Facebook password will not be a subject to collection. By connecting your Facebook account to our Service, however, you may give us permission to access, store and use your information from Facebook such as your Facebook UID, any information that you have permitted Facebook to share with us and any information you have made public on it. Alternatively, registering to our Service with your Google account will grant us access to your name, email address, profile image, and other login information.

We also collect information that you provide during registration and your profile data such as topics and interests that you create and change over time. These are non-identifying information and can be used to administer your requests.

3.2 Device Information and Access Logs

When you use our Service, we may collect and retain electronic identification or log data that are automatically generated from your mobile device, including operating system, IP address, browser information (type and language settings), device identifier, cookie data, advertising identifier or a mobile application identifier. Such information may be used to detect and deter unauthorized or suspicious access to the Service.

3.3 Contact Information for Promotional Events and Customer Surveys

When you choose to enter in promotional events or surveys we offer from time to time, we may ask for your contact details (e.g. name, mailing address, phone number, email address, gender and date of birth) to confirm your eligibility, process the event or survey, and ship the prize that may be available for you.

3.4 Payment Information

We may delegate the handling of your personal information to third parties for the purchase of Service by means other than in-app purchases via iTunes or Google Play. We may also collect and use your credit card information to process such purchase. We do not retain this information, however, as your payment itself is handled by the appropriate payment processor.

3.5 User Generated Contents

Any information you post, share with or set visible to other users (e.g. profile photo, text, images, videos) are digital data in nature that can be copied, stored, disseminated or accessed by intended or unintended recipients. We encourage you to exercise caution when you share personal information or generated contents.

4 Use and Handling

4.1 Use of Data

Sming will only use private information received for the following purposes:

1) To provide our service to users

2) As determining data for improvement for this service

3) To prevent usage violating the Sming community guidelines and Sming terms and conditions

4) In order to gather statistical data on users’ usage (in case of collecting such data, data shall be modified anonymously in order not to identify an individual).

5) In order to grasp the usage situation of users and use them for improvement of this service and development of new services

6) To confirm the application of the e-mail delivery service and to deliver e-mails(Mostly for email verification, payment confirmation etc.)

7) To send notices such as results of a contest, campaign, prizes and the like, dispatch of goods

9) In order to grasp the utilization status of this product, this service, this website, etc., and to deliver information and

10) In order to process revenue exchange to users’ designated account [i.e: PayPal]

4.2. Cookies

We use cookies and other similar technologies to collect information. A cookie is a small data file that we transfer to your hard disk for record-keeping purposes. Disabling all cookies may restrict you from accessing some features on our website, as they require those cookies to work as intended. We use cookies to a) maintain your session when you use or purchase our Service; b) keep our system safe; c) remember your preferences and optimize the experience for you, and d) gain user insights and improve our Service accordingly.

In order to collect information about how visitors use our website/application and to improve how our services work, we are using Google Analytics. You can find out more about how Google Analytics works and about how information is collected on the Google Analytics Terms of Services and on Google Privacy Policy.

Google Analytics Terms of Use

https://www.google.com/analytics/terms/us.html

Google Privacy Policy

https://policies.google.com/privacy?hl=en

To opt out of Google Analytics, please download the “Opt-out Browser Add-on” from the URL below. After you install it, you’ll be able to edit Google Analytics settings.

Google Analytics Opt-out Browser Add-on

https://tools.google.com/dlpage/gaoptout?hl=en

Your continued use of the Sming Service constitutes your acceptance of cookies and similar technologies described herein.

Most browsers allow you to control those cookies. You may disable or limit cookies if you wish to. Doing so, however, you may not be able to use all portions of the Service.

4.3 Security

As a part of our commitment to ensuring the confidentiality of your information, we implement industry-standard safeguards that allow encryption of any sensitive information as you type using Secure Socket Layer (SSL) technology. Some of the sensitive information stored in our systems will also be encrypted. Please note that no method of electrical transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute safety.

As an additional effort, we handle and maintain your information in a secure location in the United States to provide more reliable data protection. The entire transfer of user information strictly complies with applicable laws and regulations. This also means your information may be transferred to and store in a location outside of your jurisdiction.

Your personal information will be retained while your account is active or for the period of time set forth by applicable laws and regulations.

4.4 Discarding of Your Information

Collected and used the information to which you consent to will then be transferred to our database and be retained for the period of time as required by law before they are destroyed either by shredding or incineration. Digitally stored personal information will be permanently erased from our database using secure data wiping technology that produces no recoverable data. This does not apply to some information, however, such as notification of account cancellation, email address for the post-cancellation process, and any record of illegitimate use (as a reference for later conflict that may arise in respect to such use). Such information will be retained for 1 year before we destroy them. The governing law and appropriate requirements for data retention are as follows.

________________________________________

  • Items: Records of contract or termination of the contract
  • Applicable law: Enforcement Decree of the Act on the Consumer Protection in Electronic Commerce, etc.
  • Duration: 5 years

________________________________________

  • Items: Records of commercial exchange
  • Applicable law: Enforcement Decree of the Act on the Consumer Protection in Electronic Commerce, etc.
  • Duration: 5 years

________________________________________

  • Item: Records of consumer complaints or claims processes
  • Applicable law: Enforcement Decree of the Act on the Consumer Protection in Electronic Commerce, etc.
  • Duration: 3 years

________________________________________

  • Item: Records of display/advertisement
  • Applicable law: Enforcement Decree of the Act on the Consumer Protection in Electronic Commerce, etc.
  • Retained for: 6 months

________________________________________

  • Item: Accounts and related documentation of all transactions subject to tax
  • Applicable law: Framework Act on National Taxes
  • Retained for: 5 year

________________________________________

  • Item: Records of electronic commercial transactions
  • Applicable law: Enforcement Decree of the Electronic Financial Transactions Act
  • Retained for: 5 years

________________________________________

  • Item: Records of service visit
  • Applicable law: Protection of Communications Secrets Act
  • Retained for: 3 months

________________________________________

  • Item: Location information
  • Applicable law: Act on the Protection, Use, Etc. of Location Information
  • Retained for: 6 months

________________________________________

4.5 Changing and Deleting Your Information

All registered users above 12 years of age (or legal guardian for users under 12 years of age) may review, update or delete their personal information at any time, by visiting Account section of our app. You may completely delete all such information to deactivate your account. To delete your record in our system, please send your request that we delete your personal information from our database to support@sming.com. Once received, we will assist you with the request. You may also request an update of your information, upon which we will keep that information from being used or accessed until update completes.

4.6 Third Party

Our Service may contain links to third party websites or services. Clicking any of these links may direct you to that third party’s website. We do not control your visit to and/or interactions with these other websites or services. They may place their own cookies or other files on your hard disk, collect data or ask for personal information from you. As rules regarding the use or disclosure of the personal information will differ to each website, we encourage you to review privacy policies or statements of any third party websites you visit.

4.7 Phishing

We do our best to help protect you from identity theft and “phishing” as safeguarding your information is our top priority. Please always remember that we do not, and will not, at any time, request your credit card information, your account ID, login password, or national identification numbers over a non-secure or unsolicited email or telephone communication.

5. Change of This Privacy Policy

We may modify our Privacy Policy from time to time various reasons and also reflect changes to our Service. We will provide notice for you to access and review of any changes to this Privacy Policy we may make seven (7) days prior to the date the changes take effect. For important changes concerning your rights as a user, we will provide such notice thirty (30) days prior the effective date.

Released on: 05 22 2019

Effective from: 05 22 2019

6. Our Policy Toward Children

  • Special Note: Sming Service is not directed to children and adolescents under 12 years of age (11 years of age in the United States). We understand the special necessity to protect children’s online privacy and we explicitly do not knowingly collect personally identifiable information from children under 14. A parent or guardian who believes his or her child has provided us with personal information without their consent, he or she should contact us at support@sming.com. If we learn that a child under 14 has provided us with personal information, we will deactivate relevant account(s) and delete such information from our record.

7. Sming Office

For any questions, complaints, and opinions regarding personal information you may have on our Service, please email us at support@sming.com or contact our Personal Information Protection Manager.

[Personal Information Protection Manager]

  • Name: Bermseo Park
  • Division: Privacy Protection Part
  • Contact: +82-2-6463-0777

The responsible office under the data protection laws is:

CYCLOPS Co., Ltd
2nd Floor,
317 Ttukseom-Ro,
Seongdong-Gu,
Seoul,
South Korea