Privacy Notice v.1.4

Privacy Notice

A. Privacy Notice

This Privacy Notice (this “Notice”) is issued by Levvels Inc. (“Levvels,” “we,” “us,” or “our”) in relation to our Momentica service (“Momentica”) and is addressed to users of our website and app for the Momentica service (together, “you”).

For users located in the United States, the term “personal information”, as used in this Notice, shall mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.   Please see the United States Disclosures section for additional information pertaining to residents of certain states, including but not limited to California.

For users located outside of the United States, “personal information”, as used in this Notice, shall mean personal information as defined under Article 2 of the Korean Personal Information Protection Act. 

B. Collection of Personal Information

The personal information that we collect about you is as follows: 

• Required items: 

C. Purposes of Processing Personal Information

We process your personal information for the following business purposes pursuant to applicable law: 

• To manage users for our services (including web and mobile web/app), develop, provide and improve our services;
• To perform statistical analyses, analyze our services, personalize our services in light of the analyses, and post advertisements;
• To provide marketing information for events and promotions, deliver prizes, personalize marketing activities in light of demographic characteristics or areas of interests;
• To limit use of our services for users who violate applicable laws or our Terms of Use, prevent misuse, and prevent unauthorized use of accounts;
• To transmit notices and preserve records for mediation of disputes;
• To process complaints, protect users, and operate our services, including aspects related to customer service;
• To comply with our legal obligations, respond to legal, court or government regulator requests for information, and enforce our legal rights;
• To protect the security and integrity of the website or otherwise protecting our rights or property, your health and safety, or the health and safety of others;
• User photocard (TAKE) secondary sale and purchase; and
• To process refunds at the end of service.

D. Provision of Personal Information to Third Parties 

Levvels may share information with the following categories of third parties for the business purposes described above: 

• Service providers, including but not limited to LIST COMPANY NAMES (e.g., Tilia, Inc., Amplitude, Zendesk, and Twilio) that provide services to help us with our business activities.
• Law enforcement, government agencies, courts, or other third parties to protect ourselves, our employees, or others, to investigate fraud, or as required by law, such as to comply with a subpoena or similar legal process.
• Third parties in the event Levvels is involved in an actual or contemplated merger, acquisition, or sale of all or a portion of its assets, or in the unlikely event of bankruptcy. 

In accordance with relevant laws and regulations, we may share personal information without your consent to the extent that such sharing is reasonably related to the purpose of the collection of such personal information.  In the foregoing case, we will comprehensively consider factors such as whether the sharing is related to the original purpose of collection, whether the sharing is predictable in light of the circumstances under which the personal information was collected or under usual processing practices, whether the sharing unreasonably infringes upon your interests and whether security measures such as pseudonymization or encryption have been implemented.

E. International Transfer of Personal Information 

For the purposes of providing our services and enhancing users’ convenience, we may transfer and/or manage your personal information to entities outside Korea as follows.  The details on such transfers of personal information are described below. 

F. Data Security 

We have implemented, in accordance with applicable law, technical and organizational security measures designed to protect your personal information against accidental or unlawful destruction, loss, alteration, theft, divulgence, unauthorized disclosure, unauthorized access and other unlawful or unauthorized forms of processing, as follows:  

• Organizational measures: Establishment and implementation of internal management plans, provision of regular employee training, etc.
• Technical measures: Management of access rights to the personal information processing systems, installation of access control systems, encryption of uniquely identifiable information, etc., installation of security programs.
• Physical measures: Access control of IT rooms, data storage rooms, etc. 

G. Data Retention 

If we collect any personal information from you, we comply with our internal policy to use and retain such personal information for the period during which you use our services. 

In addition, if we need to preserve personal information in accordance with the provisions of applicable law or our internal policies, we will retain relevant personal information for a specified period as follows: 

• Records regarding contracts or withdrawal of offer, etc.: 5 years (to comply with laws like the Korean Act on the Consumer Protection in Electronic Commerce)
• Records regarding payment and supply of goods, etc.: 5 years (to comply with laws like the Korean Act on the Consumer Protection in Electronic Commerce)
• Records regarding the handling of consumer complaints or disputes: 3 years (to comply with laws like the Korean Act on the Consumer Protection in Electronic Commerce)
• Users’ login history: 3 months (to comply with laws like the Korean Protection of Communications Secrets Act)
   
• If retained under our internal policies and/or your separate consent: 

H. Procedures and Methods of Destroying Personal Information 

Once the purposes of collection and use of your personal information is achieved, we destroy your personal information in accordance with our internal policies and other applicable laws.  However, personal information collected with your consent or stored in the form of electronic files will be deleted using technical means that make the records unreproducible, and personal information printed on paper such as filings or printed materials will be shredded or incinerated. 

I. Your Legal Rights 

Subject to applicable law, you may have the right to request access, modification, deletion, suspension of processing your personal information and the right to withdraw consent for collection/use of the same, relating to your personal information managed by us:

Your rights and your legal representative/guardian’s rights can be directly exercised on the “User Information” page or through Customer Service.

Users located in the United States, including but not limited to California, should read the United States Disclosures section below for information about rights they may have. 

J. Data Protection Officer 

In order to protect users’ personal information and handle complaints related to personal information, we have designated our Data Protection Officer as follows.  Users may report all complaints related to personal information protection arising in the course of using our services to the Data Protection Officer, and we will provide prompt and sufficient responses to such reports. 

- Data Protection Officer: Miri Kang

- Email: Privacy@levvels.io

K. Handling of Comments and Complaints 

We operate a customer services center for smooth communication and resolution of any comments and/or complaints presented by our users in connection with personal information protection.  If you are a user in Korea, in the event of a dispute arising between us and you in connection with personal information protection, for which you require help regarding potential infringement upon your information, you can contact the Personal Information Infringement Report Center of the Korea Internet & Security Agency, the Cyber Bureau of the National Police Agency, or other relevant agencies. 

L. Installation and Operation of Automatic Collection Tools for Personal Information and Refusal Thereof 

We use cookies to store and discover information about members.  Cookies are strings of small amounts of texts transmitted by the website server to users’ computer browsers (e.g., Internet Explorer, Safari, Chrome, Firefox).  Cookies identify each member’s computer, but do not identify individual members.

(1) Operation of Cookies

    ① Provide differentiated information depending on each individual’s interests

    ② Analyze members’ and non-members’ frequency of visits and time spent on each visit to identify members’ tastes and interests for use in targeted marketing 

    ③ Identify the traces of browsing records of contents in which members were interested in to provide personalized services on the next visit 

    ④ Analyze customers’ habits and use the results as criteria for service reorganization, etc.

(2) Cookie options 

By adjusting the settings on their web browser, members may accept all cookies, receive notifications whenever cookies are installed, or refuse all cookies. However, if you refuse cookies, you may not be able to use certain functions of the service that require login. 

(3) Options to block cookies

You can choose whether or not to allow cookies as follows, depending on your browser:
- Microsoft Edge: [Settings] > [Site permissions] > [Cookies and site data] >  Decide on the scope of cookies to allow as you wish. 
- Chrome: [Settings] > [Advanced settings] > [Privacy and security] > [Cookies and other site data] > Decide on the scope of cookies to allow as you wish.

- Safari: [Preferences] > [Privacy] > Decide on the scope of cookies to allow as you wish.

United States 

The following provisions supplement the main text of the Privacy Notice and are intended for residents of states that have adopted comprehensive privacy laws, including but not limited to California, Colorado, Connecticut, Utah, and Virginia.    In the event of conflict between the following and the main text of this Privacy Notice, the following shall prevail. 

Collection of personal information  

We collect, store, and use the following categories of personal information:  

• Personal identifiers, including usernames, IP addresses, phone number and email addresses;

• Protected classifications, including age, country, gender and profile photo;
• Commercial information, including purchases and transactions made;

• Internet or other electronic network activity information;
• Sensitive personal information in the form of login credentials for the services; and

• Inferences for use in creating a consumer profile. 

We do not intentionally collect personal information of users under the age of 13. 

Categories of Sources of Personal information 

We collect or obtain personal information from the following sources: 

• Information provided to us by users;
• Information we collect when our users interact with us
• App data;
• Website data;
• Social media;
• Our service providers and partners that help us operate our services;
• Information obtained from content and advertising providers; and
• Information provided to us by third parties. 

Disclosure of Personal information 

We do not sell any personal information to third parties.  In particular, we do not sell the personal information of minors under 16 years of age.   In the preceding 12 months, we have disclosed the following categories of personal information to the following categories of recipients: 

• Individual rights

Residents of certain states, including but not limited to California, have certain rights regarding personal information about them.  

The rights you may have include:  we will generally require you to provide us with certain personal information for the purpose of identifying you in the course of handling your request and compare such personal information against the personal information we have collected about you to verify your identity 

Right to Know About Personal Information We Collected about You, including

• The categories of personal information we collected about you.
• The purposes for which the categories of personal information collected about you will be used.
• The categories of sources for the personal information we collected about you.
• The categories of third parties with whom we share your personal information.
• Our business or commercial purpose for collecting your personal information.
• The specific pieces of personal information we collected about you.
• The categories of personal information we have disclosed for a business purpose. 

Right to Request Deletion of Personal Information, subject to certain exceptions.  

Right to Request Correction of Personal Information, subject to certain exceptions.

Right to Non-Discrimination. We will not discriminate against individuals who exercise their rights under applicable laws by : 

• Denying you goods or services;

• Charging you a different price or rate for goods or services;

• Providing you with a different level of quality of goods or services;
• Suggesting that you may receive a different level of quality of goods or services. 

We may provide different prices or levels of service if the difference is reasonably related to the value of the personal information.

To exercise your rights to know, delete, or correct personal information, please email us at momentica_support@levvels.io.  We will ask you to provide us with certain personal information, such as your name, username, email address, and phone number, for the purpose of identifying you in the course of handling your request and compare such personal information against the personal information we have collected about you to verify your identity.  Authorized agents may submit requests on behalf of others via the email address listed above and will be asked to provide us with a signed permission demonstrating they are authorized to submit a request on your behalf. We note, should your authorized agent fail to submit proof that they have been authorized to act on your behalf, we will deny their request.