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STEPIN Privacy Policy

Last Updated: 2023-12-13
Sidewalk Entertainment Inc. ("Company", “We” or “Us”) has established this Privacy Policy (“Policy”) for the guidelines the Company must comply with in an effort to allow users to access and use STEPIN (“App” or “Platform”) with a sense of assurance and security. We are committed to protecting users’ rights and personal information.
By accessing or using the App, You are deemed to agree to the collection, handling, storage, and distribution of Your personal information in the manner specified in this Policy. If You do not agree to provide personal information to the Company or to the use of such information in accordance with the Terms of this Privacy Policy, please stop using the App.
Apart from this Policy, Your use of STEPIN is also bound by the STEPIN End User License Agreement (“EULA”) and other supplementary Policies and Terms set forth by the Company.
For residents of the Republic of Korea, please refer to Privacy Policy – Republic of Korea.
If you reside in the United States, European Economic Area (EEA), United Kingdom or Switzerland, please take note of the additional regulations in your country of residence in the Supplementary Terms section.

1 Collection of Personal Data

1.1 Account Registration Process

Below is the information we collect when users register for an account on the App.
Registration Method
Personal Data Collected
For all Account Types
ID, nickname, password, date of Birth, gender, email address
Email Address
(Required) Authentication data (CI, DI)
Facebook
(Required) Profile information, name, nickname, profile photo of public Facebook profile
Apple
(Required) Apple token, private relayed email address  (Optional) Email of Apple account
Google
(Required) Username and profile picture of Google account

1.2 Other Processes

When users access and use the App, the following data will be automatically generated and collected.
1) Images, videos, audio, motion data, and related content provided, taken, transmitted, and uploaded by the user;
2) Short messages and comments added by the user, device information (serial number, mobile, OS), initial access date, membership status and geographic information (city, country and region) of the device when it is connected to the internet;
3) The function being used and the status of the app when an error occurs;
4) Advertising identifier, user's app activity history, user's item purchase and collection history, interaction between You and other users, such as following other users, account report history;
5) Version of App used, time zone of device, country locale and language of device, user’s login time and location (country and city), payment information, including user’s App Marketplace purchase history and card information etc., in-app purchase history, records of usage and refunds, languages used by the user;
6) When the “Challenge” function is activated, through the device’s camera, the App uses motion tracking AI to detect the user's body movements. Based on the data collected, media content will be generated on the App and stored on the Company’s server. The information collected through this process is used solely for the purpose of motion tracking (not for personal identification) and will not be shared with third parties.
7) If You edit and apply effects to the media content created and upload it publicly on the Platform, both the original and edited versions of the content will be stored on the Company’s server. The Company may collect data including objects, landscapes, faces, bodies, and characteristics via the content.
8) When You participate in our events, promotions, reward programs, etc., the Company may collect your real name, ID card copy, ID details, bank details and email address.

2 Purpose of Personal Data Collection

Personal data is collected through user’s input during member registration process and usage of the App.
In conjunction with the personal information obtained through the process of member registration and App usage, information provided by users in inquiry process with our customer center is also collected.
Personal data is obtained from third parties through service-related partnerships and other connections.
In case you register as a member and log into this App through other platforms such as Facebook, Apple, or Google, this App will receive Your profile information which is uploaded publicly on the selected platform. In this case, the corresponding platform provides Your information to us after obtaining Your consent.
Personal data is acquired when the App is accessed and used.
The Company may collect user information through the data generated automatically when the App is being used. The information collected may or may not constitute personal information or data that is related to personal information.
Data regarding user’s content preference will be collected.
The Company may collect information about your preferred content, users you follow, your followers and their engagement with you, advertisements and videos you view and errors or issues you may encounter. Furthermore, the Company may use your videos, profile, and other content to promote your content and allow other users to view and explore it.
The collected personal data is used for the purposes listed below.
User management: Verification of user identity, intent to join, age and personal information, prevention of fraudulent and unauthorized use, set up of service restrictions concerning users who violate laws or the Company’s policies, prevention and sanctions against acts that interfere with service operations (including acts of unauthorized use).
Service Operations: Personalize connections between users, in-app payment processing, service-related inquiries, reports and complaints, notice publications, analyzation and provision of personalized services through demographic analysis of user characteristics, interests and preferences.
Service Improvement: Analysis of error log, advancement of chatbot’s service function and performance, development of new services and contents (such as even chatbot custom chatbots, or marketing chatbots), sanctions against usage behaviors that violate the Company’s policies, monitoring of a healthy platform environment, service provisions on user benefits, establishment and enhancement of platform service via analysis of statistical data regarding app usage records, access frequency and interactions between users and/or with chatbots etc.
Notification Delivery of Ads and Events: Providing marketing and promotional information regarding events, new products, features and services etc. through various communications such as text messages, emails, and app push notifications etc.
Third-party Platforms and Apps: When You share content on other social media platforms using the in-app feature, your video, user ID, and text associated with the content will be shared on the respective platform. When you share content on instant messenger apps such as KakaoTalk, Line, Whatsapp, Telegram, Signal, etc., an embedded link connected to the content will be shared.

3 Sharing of Information

We share or reveal your personal information to third parties in the situations explained below:
Affiliates, subsidiaries, partners and personnel – “Affiliate” shall mean any company or entity that Sidewalk Entertainment Inc. has direct or indirect ownership of. We disclose your information to our affiliates, subsidiaries, partners and personnel, which include agents and contractors, as well as other businesses, as required to offer our Service and achieve the objectives outlined in Section 2 “Purpose of Personal Data Collection”.
Service providers – We also share or reveal your information to select companies that offer services on our behalf, such as those that assist us in creating and managing systems for our App, payment and refund providers, IT service providers, security firms, hosting companies, analytics providers, mailing services, billing companies, and marketing firms. These organizations are permitted to access and utilize your personal information only as required to provide us with their services, and they are prohibited from using this information for any other purposes.
Business advisors – We may disclose your information to our lawyers, accountants, business advisors, insurers, and auditors, among others, to the extent necessary for them to provide us with their services.
Government agencies, regulatory bodies, judicial authorities or other third parties (when necessary) - We may share personal information with Government agencies, regulatory bodies, judicial authorities or other third parties when legally required or believed necessary:
To comply with the law or in response to compulsory legal processes, such as a search warrant, subpoena, or court order;
To verify or enforce compliance with the terms and policies governing our Service and to investigate fraud or other unlawful activity related to the use of our Service or affecting our business, as permitted by applicable data protection laws;
To safeguard and uphold our business operations, as well as the rights, property, security, and safety of our affiliates, staff, business partners, customers, or the general public.
Corporate transactions – We may transfer your information when we become involved, either wholly or partially, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy, or any other change in ownership or control.
Other third parties upon your consent or at your request. We may share information about you with third parties if you provide separate consent or request such sharing beyond what is outlined in this Privacy Policy. Please note that any User Contents that you voluntarily disclose for posting to the Service may become available to the general public. Once you have shared User Contents or made them public, they may be re-shared by others. Please be aware that this Privacy Policy does not apply to any public information.
As a general rule, the Company does not provide user's personal information to third parties unless in exceptional cases where the user has given prior consent, it is required by law, necessary to fulfill legal obligations, or needed for billing purposes related to the provision of information and communication services.

4 Retention of Personal Information

We adhere to the following principles to ensure that information is processed and retained appropriately:
At least for the period which the information is required to provide you with our service;
When it is required by law, contracts, or statutory obligations;
As long as it is necessary for the purpose it was collected or processed, or longer if required by law, contract, or for statistical purposes in an anonymized form with appropriate safeguards. (For instance, we may retain information associated with disputes between you and the Company until the dispute is resolved, or if you fail to make payment for an in-app purchase until the dispute is resolved or payment is settled, respectively;
If we process your information with your explicit consent, we will continue to do so until you withdraw your consent. We may retain your data for a short period after your withdrawal request for your request to be implemented effectively. Additionally, we keep a record of your requests to ensure that we respect them in the future.

5 Your Rights

You have the right to request modification or deletion of your personal information through utilizing the “Settings” function in the App or by contacting our Data Privacy Manager. You may contact our Data Privacy Manager using the contact information specified in Article 10 of this Policy. However, these rights may only be limited to personal data within our management and control scope. Furthermore, by selecting “Withdrawal” in the “Settings” menu in the App, and requests made in this method will be processed immediately. If you encounter difficulties requesting your withdrawal, you may contact us at stepin.cs@sidwalkplay.com for assistance.

6 Use of Cookies

To automatically collect necessary information such as access logs and device information for the App operations, the Company uses "cookies" that store and retrieve users' information at all times. Cookies are small amount of data that the server (HTTP) operating the App sends to the user device’s browser and can also be stored on the user device’s hard disk.
A. Purpose of using Cookies
The purpose of using cookies is to facilitate convenient communication among users based on login and recent access logs, provide customized services based on user behavior analysis, and improve and enhance the service of our App.
B. Installation and rejection of Cookies
You have the right to allow or reject the use of cookies. By adjusting your browser settings, you may allow all cookies, verify each time a cookie is stored, or reject all. However, please note if the usage of cookies is rejected, you may experience issues while using the App.
C. Customized Advertising
Customized advertising refers to online ads provided to users in a personalized manner by processing behavioral information to understand Your interests, and preferences. We collect and apply users' advertising identifiers to provide more useful services based on users' characteristics. Advertising identifiers, such as Android advertising ID, and other temporary and non-personal identifiers, are not used to identify individuals. We do not combine behavioral information obtained through advertising identifiers with information that can identify individuals without users' permission.
We allow the following advertising companies to collect behavioral information for personalized advertising:
Advertising company that collects and processes behavioral information: Google Ads
Method of collecting behavioral information: automatically generated and transmitted during the user's app usage process.
Users can always refuse to receive personalized ads, and if they do so, they will no longer see personalized ads. If users do not wish to be exposed to personalized ads within the app, they can disable the relevant settings using the following methods on each OS:
Android: Settings > Google > Ads > Select "Opt out of Ads Personalization"
iOS: Settings menu > Privacy > Apple Advertising > Turn on/off "Limit Ad Tracking"

7 Measures for Ensuring Confidentiality of Personal Data

Measures are implemented in compliance to the Republic of Korea’s Personal Information Protection Act, to ensure the security of users' personal data, such as controlling unauthorized access from external parties, retaining access records related to the personal information processing system, and providing regular internal training programs to staffs who handle personal data. The Company is committed to preventing users’ personal information from being lost, stolen, leaked, altered, or damaged.

8 Personal Information of Children

Our App is designated for users who are aged fourteen (14) or above and therefore, we have no intention of knowingly requesting or collecting personally identifiable information from children under the age of fourteen (14) through this App. In addition, we do not knowingly sell the personal information of users under the age of sixteen (16). In case we unintentionally obtain any personally identifiable information from a user under the age of fourteen (14) via the App, we will take immediate action to remove such information from our system records. In case you suspect that a child under the age of fourteen (14) has provided us with personal information, please contact us with the contact details stated in Section 10 “Contact Information”.

9 International Data Transfers

We operate globally, and in order to provide our services, we may need to transfer your data to countries and regions outside of your current location. However, we will take all necessary steps to protect the privacy of your personal information and ensure that it is processed, stored, and transferred in a secure and responsible manner. These transfers are necessary for our service delivery and compliance with the Company Policies.
For users residing in European Economic Area (EEA), UK or Switzerland, please refer to the supplementary terms for additional details.

10 Contact information

The Following personal information protection manager is designated to handle tasks, matters and complaints related to personal information. If you have any inquiries, complaints, suggestions or other issues related to personal information processing that arise while using the app, please contact our Privacy Officer at stepin.cs@sidewalkplay.com. We will respond promptly to your report.

11 Notifications of Modifications

The Company retains the right to modify and improve this Policy in accordance with relevant laws and internal policies. In such cases, the modifications will be notified on our App, Homepage, or via email or push notifications.

12 Third Parties

If You access third-party websites, products or services provided by third parties via the App or our services, the third party may receive your personal information. For such personal information processing, please review the corresponding privacy policy. Please acknowledge this Policy does not apply to the processing of your personal data by third parties in your relationship with them.

13 Supplementary Terms

These following terms and conditions are applicable to users who reside in certain countries. In case of any inconsistencies between these country-specific terms and the provisions stated in the main body of this Privacy Policy, the following terms shall take precedence.

1. For Users Residing in European Economic Area (EEA), UK or Switzerland

A. International Transfer of Personal Information
For users who reside in EEA (European Union, Iceland, Lichtenstein, Norway), UK, or Switzerland, your personal data may be transmitted to countries located outside these regions, including the Republic of Korea and United States.
As a company based in the Republic of Korea, in order to provide you with our services, we may need to transfer your personal information to our country if there are no adequacy decisions between South Korea and your country of residence.
We take the protection of your personal information seriously and will ensure that appropriate measures are taken in compliance with applicable laws if we need to share your data with other parties. Therefore, we may take various measures such as using EU-approved Standard Contractual Clauses or similar instruments under local law, or obtaining your explicit consent before sharing your data with others.
B. Usage of personal Data
In certain cases, we may acquire your consent before using your personal information. For instance, we may ask for your consent before using cookies and similar technologies, or before sending you marketing communications or customized advertisements. We will always notify you of the specific purpose for which we are seeking your consent and will only use your data for that purpose. If you choose to provide your consent, you have the right to revoke it at any time. However, please note that withdrawing your consent will not impact the lawfulness of any processing that occurred prior to the withdrawal. If you wish to revoke your consent, please refer to Section 6 "Your Rights" of this Policy.

2. For California Residents

This supplementary term serves as an addition to this Privacy Policy and is exclusively applicable to California consumers (excluding job applicants and personnel of the Company).
A. Collection and Disclosure
In the previous 12 months, we may have:
1) Collected the subsequent categories of your personal information:
(i) Contact information and personal identifiers, including your name, alias, IP address, online identifiers, email address, or similar identifiers;
(ii) Customer Records, including your name, phone number, and financial details, which are collected solely by our service provider;
(iii) Protected classifications Under California or Federal Law, including age and gender;
(iv) Geolocation Data, including geolocation data from your device;
(v) Commercial information, such as your purchase history and consumer behavior;
(vi) Internet or other network activity information, including browsing, search history and interaction with websites, applications or advertisements;
(vii) Audio, visual, or similar information, including profile photos, audio, video, electronic information;
(viii) Inferences drawn from the above categories for profile creation.
2) Your personal information is collected from the following sources:
(i) from you or your devices (through your use of our Service);
(ii) our affiliates;
(iii) vendors who offer services for us;
(iv) social media networks; and
(v) online advertising companies.
3) Personal Data Collection for Business or Commercial purposes
Your personal information collected will be utilized in relation to the business or commercial purposes listed below:
(i) Performing services such as maintaining and servicing accounts, providing customer service, processing orders and transactions, verifying customer information, providing advertising or marketing services, providing analytics services, or similar services;
(ii) Auditing related to current interactions and concurrent transactions, including counting ad impressions, verifying ad impression quality and positioning, and auditing compliance;
(iii) Short-term, transient use, such as customizing ads shown as part of the same interaction;
(iv) Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for such activity;
(v) Debugging to identify and repair errors that impair intended functionality;
(vi) Undertaking internal research for technological development and demonstration;
(vii) Undertaking activities to verify or maintain the quality or safety of services owned or managed by the Company, and to improve, upgrade, or enhance our services.
We may share or disclose the aforementioned categories of information with our service partners to assist in our internal functions, including but not limited to, analyzing data, maintaining the security of our systems, and ensuring compliance with the law. In addition, we reserve the right to share the aforementioned information with our affiliates, such as Google, Facebook and Apple etc., in order to enhance our ability to serve you and maintain our business operations.
Category of Personal Information
Recipient Categories
Identifiers
Our affiliated entities, solution provider, collaborators, system management and operational service provider
Commercial Information
Solution provider, system management and operational service provider
Geolocation Data
Solution provider, system management and operational service provider
Internet and Other Electronic Network Activity Information
Our affiliated entities, collaborators, solution provider, system management and operation service provider
Audio, Electronic, Visual, or Relevant Information
Solution provider, system management and operation service provider
Inference
Solution provider, system management and operation service provider
B. Privacy Rights
You have the rights to inquire us, twice in a 12-month period, for the following details about your personal information that we collected in the past 12 months:
(i) The types and specific details of your personal information that we have collected;
(ii) The categories of sources from which we collected your personal information;
(iii) The business or commercial purpose for which we collected or sold your personal information;
(iv) The categories of third parties with whom we shared your personal information; and
(v) The categories of your personal information that we sold or disclosed for a business purpose, and the categories of third parties to whom we sold or disclosed that information for a business purpose.
You may also request that we provide you with (i) certain categories of your personal information that we shared with third parties for direct marketing purposes during the previous calendar year and (ii) the identity of those third parties. Additionally, you may request that we delete your personal information that we have collected. You can opt out of the sale of your personal information by contacting our Privacy Information Protection Manage. And you will not be discriminated against if you decide to exercise this right associated with your personal information.
You or your authorized representatives can request access to or deletion of your personal information by contacting our Privacy Information Protection Manager. If you want to authorize an agent to make such a request on your behalf, you must provide us with written proof of your authorization. To protect your privacy and ensure the security of your information, we will take steps to verify your identity before fulfilling your request. If you have an account with us, we may use your login credentials to verify your identity. Please note that in some cases, we may need to charge a reasonable fee to process your request, as permitted by applicable law.

3. For Nevada Residents

Nevada residents have the option to request not to have their personal information sold. To exercise this right, you can send an email to stepin.cs@sidewalkplay.com. However, please note that we currently do not engage in the sale of data that would trigger this opt-out process.

4. For Residents in Japan

This additional clause is an extension of this Privacy Policy and applies exclusively to users residing in Japan. If you have any questions or concerns regarding the collection and handling of your personal information, you have the right to contact our Privacy Officer at stepin.cs@sidewalkplay.com.
A. Sensitive Information
We do not gather or share, without your explicit consent, any "sensitive personal information" about you. “Sensitive personal information” encompasses details such as religion, race, criminal record, medical history, social standing, experiences of harm, physical, intellectual, or mental impairments, outcomes of medical assessments or evaluations, counseling for mental and physical well-being, healthcare and prescriptions, criminal cases like arrests, searches, seizures, detentions, initiation of legal action, inquiries, as well as observations and protection measures, hearings and verdicts, protective actions, or other activities related to the safeguarding of minors.
B. International Transfer
By accessing and using our Service or providing any information, you consent to the transfer, processing, use, share, and storage of information about you with third parties or in other jurisdictions. Following *Section 3 - Sharing of Information*, your data may be transferred to, processed, stored, and utilized by parties located outside Japan, including Korea, Singapore, and the United States.
If the country to which your data is being transferred has a personal information protection system that differs from the standards set by Japan's Personal Information Protection Commission, we will endeavor to implement suitable measures to safeguard your personal data in accordance with applicable data protection and privacy laws. If you do not agree to the transfer, processing, utilizing, sharing, and storage of information about you by such third parties in other jurisdictions, please refrain from using our Service or providing information related to you.

5. For Residents of Taiwan (R.O.C.)

This supplementary section is specifically applicable to users who are residing in Taiwan (R.O.C.) or data subjects as defined according to Taiwan law.
A. Your Data Subject Rights
Taiwan’s Personal Data Protection Act grants the following rights to Taiwan residents and data subjects in Taiwan:
Right to enquire about and review your personal data;
Right to request a copy of your personal data;
Right to amend or supplement your personal data;
Right to demand the termination of the collection, processing, or use of your personal data; and
Right to remove your personal data.
Should you require access to your personal data, fees may be applied. To exercise any of these rights, please submit your request to stepin.cs@sidewalkplay.com.
B. Retention Period of Your Personal Data
The collected personal data is handled and processed in compliance with the guidelines of this Privacy Policy. The processing duration is determined by the necessity to fulfill the objectives specified in the 2 Purpose of Personal Data Collection section.
C. Region in which Your Personal Data will be Utilized
The collected personal data is handled and processed in compliance with the guidelines of this Privacy Policy in the regions where the entities mentioned in 3 Sharing of Information and 4 International Data Transfers operate and other territories essential to achieving the purposes outlined in the 2 Purpose of Personal Data Collection section.
D. Results of Not Providing Your Personal Data
If you decide not to share your personal data with us, you may face restrictions in using part of or the entire Platform. Furthermore, you may be ineligible to receive or utilize some or all of the products, services or promotional offers extended through the Platform.
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