# \[Privacy Policy]

NINEAM Co., Ltd. (“the Company”) operates the online service ‘CTEE’. In accordance with Article 30 of the Personal Information Protection Act (「개인정보보호법」 제30조), the Company establishes and discloses this Privacy Policy to protect users’ personal information and rights, and to promptly handle related grievances.\
The Company complies with all responsibilities and obligations required by applicable laws and strives to ensure that users’ personal information is safely managed.<br>

### Article 1 (Purpose, Items, and Retention Period of Personal Information Collection and Use)

The Company collects and uses the minimum personal information necessary to provide services. The purposes, items, and retention periods are as follows:

| Category                             | Purpose of Collection                                                                | Items Collected                                                                                                                                                                                                                         | Retention and Use Period                                                                                                         |
| ------------------------------------ | ------------------------------------------------------------------------------------ | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | -------------------------------------------------------------------------------------------------------------------------------- |
| Membership Registration & Management | Identification, service subscription, social login, customer management              | <p>\[Required] Nickname, Email, Password</p><p>\[Optional] Name, Profile photo, Gender, Year of birth</p>                                                                                                                               | Deleted 3 months after membership withdrawal                                                                                     |
| Service Use                          | Product and content purchase management, community management, membership management | <p>\[Required] Nickname, Email</p><p>\[Optional] Comments, Name, Profile photo, Phone number, Usage records, Address</p>                                                                                                                | Deleted 3 months after membership withdrawal                                                                                     |
| Paid Service Payment                 | Payment and settlement processing                                                    | Name, Phone number, Email, Card number, Expiration date, Date of birth (6 digits), Business registration number (10 digits)                                                                                                             | Retained in accordance with the Act on Consumer Protection in Electronic Commerce, etc. (「전자상거래 등에서의 소비자보호에 관한 법률」) and tax laws |
| Identity Verification                | Adult verification and personal identification                                       | Name, Gender, Phone number, Email, Date of birth (8 digits)                                                                                                                                                                             | Immediately destroyed upon fulfillment of purpose                                                                                |
| Customer Inquiries                   | Responding to inquiries                                                              | Name, Email, Phone number, Inquiry details                                                                                                                                                                                              | Retained for 3 months after inquiry resolution                                                                                   |
| Place Creation & Settlement          | Creator settlement and revenue payment                                               | Name, Profile photo, Social media address, Bio, Bank, Account number, Tax information (For businesses: Business registration number, Business license, Bankbook copy, Representative name / For individuals: Name, Mobile phone number) | Deleted 3 months after membership withdrawal                                                                                     |

※ The Company does not collect or use Resident Registration Numbers in principle, except where explicitly permitted by law.\
※ Methods of Collection: Direct input by users, handwritten forms at events/seminars, or automatic collection during service use (cookies, logs, etc.).

### Article 2 (Installation, Operation, and Rejection of Automatic Personal Information Collection Devices)

The Company may automatically collect cookies, logs, and advertising identifiers to provide personalized services.

1. Items Collected: Visit history, IP address, service usage records, advertising identifiers
2. Purpose of Use:
   1. Service security and prevention of unauthorized use
   2. Personalized content and product recommendations
   3. Advertising and marketing
3. How to Reject:
   1. Web browser: \[Settings] → \[Privacy] → \[Block cookies]
   2. Mobile: In-app \[Settings] → \[Clear browsing data / cookies]
4. Analytical Tools Used: Google Analytics, Meta Pixel, and Mixpanel (users cannot be personally identified; users may opt out through settings).<br>

### Article 3 (Retention and Destruction of Personal Information)

1. The Company retains and uses personal information only within the period specified at the time of consent.
2. Upon membership withdrawal, minimal information is retained for 3 months and then destroyed. Accounts inactive for more than 1 year are converted to dormant accounts with prior notice.
3. Where retention is required by law:
   1. Records of contracts or subscription withdrawals: 5 years (Act on Consumer Protection in Electronic Commerce, etc. / 「전자상거래 등에서의 소비자보호에 관한 법률」)
   2. Records of payment and supply of goods: 5 years (Act on Consumer Protection in Electronic Commerce, etc. / 「전자상거래 등에서의 소비자보호에 관한 법률」)
   3. Records of consumer complaints and dispute resolution: 3 years (Act on Consumer Protection in Electronic Commerce, etc. / 「전자상거래 등에서의 소비자보호에 관한 법률」)
   4. Records of labeling/advertising: 6 months (Act on Consumer Protection in Electronic Commerce, etc. / 「전자상거래 등에서의 소비자보호에 관한 법률」)
   5. Access logs: 3 months (Protection of Communications Secrets Act / 「통신비밀보호법」)
4. Destruction Method: Electronic files are destroyed using technical methods preventing recovery; paper records are shredded or incinerated.

<br>

### Article 4 (Outsourcing of Personal Information Processing)

The Company outsources certain tasks for service provision and supervises contractors to ensure safe handling of personal information.

| Contractor               | Outsourced Task                           | Contact                 |
| ------------------------ | ----------------------------------------- | ----------------------- |
| Stibee Inc.              | Email delivery                            | <support@stibee.com>    |
| Twilio (SendGrid)        | Email delivery                            | +65-3138-9142           |
| Daou Technology (Ppurio) | SMS, MMS, KakaoTalk notification delivery | <ppurio@unitel.co.kr>   |
| NICE Payments Co., Ltd.  | Credit card payment processing            | <service@nicepay.co.kr> |
| Korea PortOne            | Payment gateway integration               | 1670-5176               |
| Payple Co., Ltd.         | Card and recurring payments               | <help@payple.kr>        |
| Danal Co., Ltd.          | Identity verification                     | 031-697-1004            |
| Channel Corporation      | Customer service                          | <feedback@channel.io>   |

### Article 5 (Provision of Personal Information to Third Parties)

The Company does not provide users’ personal information to third parties without prior consent, except in the following cases:

1. With Prior Consent
   1. Recipients: Creators (sellers of products, content, events, support, memberships)
   2. Time of provision: At the time of Creator’s service use
   3. Purpose: Service provision, customer support, product sales and management
   4. Information provided: User ID, Nickname, Service usage details (product/content name, payment time, amount, quantity, currency)
   5. Retention period: During service provision (extended if required by law or agreed upon in advance)
2. By Law
   1. Upon requests by investigative authorities or legal demands by government agencies

<br>

### Article 6 (Cross-Border Transfer of Personal Information / 개인정보의 국외 이전)

The Company does not transfer personal information overseas in principle. However, certain services use overseas servers:

* Contractor: Twilio (SendGrid), United States
* Transferred Items: Email address
* Transfer Method: Encrypted transmission via network
* Retention Period: Until withdrawal of consent or termination of contract

<br>

### Article 7 (Measures to Ensure Security of Personal Information / 개인정보의 안전성 확보조치)

The Company takes the following measures to safeguard personal information:

1. Minimization of personnel handling personal information and provision of training
2. Establishment and implementation of internal management plans
3. Storage and tamper-proof management of access logs
4. Encryption of stored personal information
5. Installation of security programs to prevent hacking and viruses
6. Access control and management of permissions for personal information systems

<br>

### Article 8 (Rights of Users and Legal Guardians / 이용자 및 법정대리인의 권리)

1. Users may at any time request to access, correct, delete, or suspend processing of their personal information.
2. Children under the age of 14 cannot register as members. Legal guardians may exercise rights on behalf of minors.
3. Rights may be exercised through the Customer Center (+82-1522-1946) or by email.\ <br>

### Article 9 (Data Protection Officer and Inquiries / 개인정보 보호책임자 및 문의처)

* Data Protection Officer: Hyojun Shin, CEO, NINEAM Co., Ltd.
* Contact: <contact@ctee.kr> / +82-1522-1946
* In the event of rights infringement, users may also contact: Personal Information Infringement Report Center (개인정보 침해신고센터): 118,[ privacy.kisa.or.kr\ <br>](https://privacy.kisa.or.kr)

### Article 10 (Amendments to the Privacy Policy / 개인정보처리방침의 변경)

This Privacy Policy takes effect from August 27, 2025.\
Any changes due to legal or policy updates will be announced through the website.

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