Privacy Policy

DEVELOPTONIA Co., Ltd. (hereinafter referred to as the ”Company”) collects information from users of the services provided by the Company (hereinafter referred to as ”the Service”). We have established the following privacy policy (hereinafter referred to as ”this policy”) regarding the acquisition and handling of user information.

1. User Information to Be Acquired

Our company acquires the following user information through lawful and appropriate methods:

  1. Information Obtained from Users
    • Email addresses (including those that have been irreversibly encrypted)
    • Information entered by the user in the input form specified by our company (including entry in the delivery address input form for campaign prizes, etc., and responses to questionnaire surveys).
  2. Information Obtained When Using the Service or Information Obtained from Our Partners (*1)
    • User device information (device type, OS name and version, device unique ID, IDFV, DUID, etc.)
    • User ID
    • Access history to information within this service
    • User agent
    • IP address
    • Access history to advertisements within this service or third-party services (*2)
    • Location information (GPS information, accurate to within a few meters and acquired by our company approximately every hour or when you move. However, if you do not allow the use of location information in your mobile device settings, or if you do not consent to the acquisition of location information using this service, location information will not be provided.)
    • Advertising identifier (IDFA or Google Advertising ID, etc.)
    • Cookie information, etc. (*1) Our partners refer to advertisers, media companies, and other external affiliates related to our network advertising services. (*2) Third-party services are services operated and provided by other companies and are not our services.

2. Purpose of Use

Our company will use the acquired user information to the extent necessary to achieve the following purposes:

  1. To Maintain the Provision of This Service Our company handles user information in order to maintain the provision of this service. Examples of purposes include:

    • To analyze users' behavior history, attribute information, etc., and provide them with information they should know as well as news and content tailored to their interests, and to maintain and protect such services.
    • To notify users by push notifications.
    • To provide, maintain, protect, and improve identity verification, account creation, and login functions related to this service. The login function is used to transfer the settings from the old model to the new model when changing the device.
    • To provide coupons, points, discounts, and other benefits to users.
    • To deliver products purchased by users, campaign prizes, gifts, rewards, etc.

  2. For Development and Improvement of This Service and Related Research and Investigation We handle user information for the development and improvement of this service and related research and investigation. Examples of purposes include:

    • To enhance the service by investigating and analyzing the usage status of users of this service and improving it to meet the needs of users.
    • To help improve and analyze delivery logic based on usage status, develop new services, and conduct marketing research, etc.
    • To conduct questionnaire surveys, aggregate and analyze response results, utilize them, and publicly report statistical information, etc.
    • To understand the number of users of this service, the number of content advertisement views, user interests, usage status, etc., and conduct surveys, analysis, research (including academic research), and the development of new technologies.
    • In connection with this service, to create statistical data processed in a format that does not allow identification of individuals. Please note that statistical data may be shared with our partners or potential partners in the future, but information that can identify individuals will not be disclosed.

  3. To Serve Advertisements We process user information in order to provide advertisements. Examples of purposes include:

    • To analyze users' browsing history, attribute information, etc., and deliver or display advertisements (including behavioral targeting advertisements) regarding products and services according to the interests of users. Please note that this service may provide such advertisements through our partners, or advertisements related to this service may be distributed on services operated by partners. In addition, for these advertisements, we may exchange information, such as advertising identifiers, with our partners, which cannot identify individuals as personal data under the Personal Information Protection Act.
    • To conduct research, measurement, and analysis of the usage status and effectiveness of advertisements (including measurement and analysis by our partners), and to improve and analyze distribution logic, etc., based on the results.
    • To reduce advertisements that are not suitable for users based on user attribute information, etc. For example, we may receive advertising identifiers from our partners to reduce the number of advertisements soliciting membership registration for services for which you have already registered.

  4. For User Support and Management We process user information for user support and management purposes. Examples of purposes include:

    • To provide information regarding this service, respond to inquiries from users, address complaints, and manage other communications from our company to users.
    • To offer assistance with resetting your password when you are resetting your login password.
    • To detect and prevent acts that violate our terms of use, privacy policy, etc. (hereinafter referred to as ”Terms, etc.”) regarding this service, and to respond to such acts.
    • To notify you of changes to the terms of service, etc.

Please note that location information will only be used for the purpose of maintaining this service (including providing weather information and coupon information), improving development, and providing advertisements.

3. Providing Non-Personally Identifiable Information to Third Parties

Our company uses the user information of users of this service to provide information to content partners, advertising distribution companies, media companies, advertising companies, advertisers, information collection module providers, and other capital and business alliance partners (however, no personally identifiable information will be sent). The information provided will be managed based on the privacy policy and other regulations established by each partner company. If the user does not wish to have the user information of this service sent to the relevant company, please follow the opt-out procedure in accordance with Article 14. As a result, the opt-outs in this article and Article 14 will be implemented simultaneously. Please note that even if you opt out, user information may still be provided to the third parties listed above as statistical information that will be used in a manner that cannot be linked to individuals.

4. Restrictions on Use of Personal Information

The Company shall not collect personal information (as defined in Article 2, Paragraph 1 of the Personal Information Protection Act; the same shall apply hereinafter) beyond the scope necessary to achieve the purpose of use without obtaining the user's consent. However, this does not apply in the following cases:

  1. When based on laws and regulations.
  2. When it is necessary to protect a person's life, body, or property, and it is difficult to obtain the consent of the person.
  3. When it is particularly necessary to improve public health or promote the healthy upbringing of children, and it is difficult to obtain the consent of the individual.
  4. In cases where it is necessary to cooperate with a national agency, local government, or a person entrusted by them in carrying out the affairs stipulated by laws and regulations, and obtaining the consent of the person concerned may interfere with the execution of the affairs.
  5. In other cases permitted by the Personal Information Protection Act and other laws and regulations.

5. Provision of Personal Information to Third Parties

Our company will not provide personal data of user information to third parties without obtaining the user's consent in advance. However, this does not apply in the following cases:

  1. When our company entrusts all or part of the handling of personal data to the extent necessary to achieve the purpose of use.
  2. When personal data is provided due to business succession due to merger or other reasons.
  3. In other cases permitted by the Personal Information Protection Act and other laws and regulations.

6. Safety Management of Personal Information

Our company will implement the following safety management measures to ensure the safety of personal information against risks such as loss, destruction, falsification, and leakage of personal information:

  1. Appoint a person responsible for the protection of personal information and clarify the responsibilities of employees regarding the safe management of personal information.
  2. Provide necessary and appropriate supervision to our employees regarding the handling of personal information.
  3. If all or part of the handling of personal information is outsourced, ensure necessary and appropriate supervision to guarantee the safe management of personal information at the outsourcing company.
  4. Establish a reporting and communication system in the event of a loss or leak of personal information that violates laws and regulations.
  5. Manage access by limiting authorized access to personal information, etc.

7. Publication of Notices and Changes to This Policy

  1. Our company posts and publicizes this policy on our website.
  2. We will review the operational status regarding the handling of user information as appropriate and strive for continuous improvement, and may change this policy as necessary. If we make any changes, we will post them on our website. The revised policy will be applied from the time it is posted. Additionally, in the case of changes to the content that legally require the consent of the user, the consent of the user will be obtained by the method prescribed by the Company.

8. Disclosure of Personal Information

When a user requests the disclosure of personal information or records of third-party provision of personal data (defined in the Personal Information Protection Act) based on the provisions of the Personal Information Protection Act, the Company shall comply with the request from the user. After confirming that it is a request from the user, we will disclose the information to the user without delay (if the personal information does not exist, we will notify you accordingly). However, this does not apply if the Company is not obligated to disclose pursuant to the Personal Information Protection Act or other laws and regulations.

9. Correction and Suspension of Use of Personal Information, etc.

When a user requests the following matters based on the provisions of the Personal Information Protection Act, the Company shall confirm that the request is made by the user, unless the Company is under no obligation under the Act or other laws and regulations. After confirmation, we will conduct the necessary investigation without delay, and based on the results, we will correct the content of personal information, suspend its use, or suspend its provision, and notify the user accordingly. If we decide not to take these measures based on reasonable grounds, we will notify the user accordingly.

  1. Correction, addition, or deletion of personal information on the grounds that it is not true (hereinafter referred to as ”correction, etc.”).
  2. Suspension of use of personal information on the grounds that the information is being used beyond the scope of the previously announced purpose of use, or is being handled in a manner that is likely to encourage or induce illegal or unjust acts, or the information has been collected by deception or other illegal means.
  3. Suspension of use of personal information on the grounds that there is no longer a need to use personal information, that personal information has been leaked, lost, damaged, or other reasons specified by law have occurred, or that there is a risk that the rights or legitimate interests of the individual may be harmed.
  4. Suspension of provision of personal information to a third party due to the user's personal information being provided to a third party for reasons other than Article 3.

10. The Information Desk

For opinions, questions, complaints, and other inquiries regarding the handling of user information, please contact the contact point below. E-mail: info@developtonia.com

11. External Transmission, Presence of Information Collection Module

  1. Our company uses ”Google Analytics” to collect statistical usage information for purposes such as user usage surveys. Google Analytics uses cookies to collect user information that does not include information that identifies individuals. For more information on the use of collected user information, please visit the Google Analytics official website at https://marketingplatform.google.com/about/analytics/.
  2. In addition to what is described in each section of this article, our company or our partners may obtain user information (not including information that can identify individuals) by using SDKs provided by external partner companies.

12. Stopping Acquisition of User Information

Users of this Service can stop our company from acquiring user information by ceasing to use this Service or uninstalling the Service's application.

Established on September 1, 2023.