< SPOGAMES >

Effective Date: January 1, 2022

SPOGAMES ("http://3cmasters.com/", hereinafter referred to as "3Cushion Masters") establishes and discloses this Privacy Policy in accordance with Article 30 of the Personal Information Protection Act to protect users' personal information and handle related grievances promptly and smoothly.

Article 1 (Purpose of Processing Personal Information)

SPOGAMES processes personal information for the following purposes. The personal information will not be used for purposes other than those listed below. In the event of a change in purpose, necessary measures such as obtaining separate consent will be taken in accordance with the Personal Information Protection Act Article 18.

• Membership Registration and Management: To confirm the intention to sign up, verify identity for membership services, maintain and manage membership, prevent misuse of services, confirm parental consent for children under 14, and provide notifications.
• Provision of Goods or Services: To provide services and content, verify identity and age.
• Marketing and Advertising: To develop new services/products, provide customized services, deliver event and promotional information, and offer participation opportunities.

Article 2 (Retention and Use Period of Personal Information)

SPOGAMES retains personal information only for the period agreed upon by the data subject or as required by law.

Retention periods for each purpose:

• Membership information is retained for 3 years from the date of consent.
• Grounds: Terms of Use and Privacy Policy.
• Related law: Records of consumer complaints or dispute resolution – 3 years.

Article 3 (Rights of Data Subjects and Legal Guardians)

• Data subjects may exercise rights such as access, correction, deletion, and suspension of processing at any time.
• These rights can be exercised via written request, email, or fax and SPOGAMES will respond promptly.
• These rights can also be exercised through a legal representative or agent with a letter of delegation.
• Requests may be restricted under Article 35(4) and 37(2) of the Personal Information Protection Act.
• Correction/deletion requests may be restricted if other laws require the information.
• SPOGAMES verifies the identity or authority of the person making the request.

Article 4 (Items of Personal Information Processed)

• Membership Registration and Management:
• Required: Email, mobile number, password, login ID
• Optional: Usage records, access logs, IP address

Article 5 (Destruction of Personal Information)

SPOGAMES promptly destroys personal information when retention periods expire or processing purposes are fulfilled.

If retention is required by law even after purpose expiration, information is stored separately.

Destruction procedures and methods:

• Selection and approval by the Data Protection Officer
• Electronic files: Permanently deleted using technical methods

Article 6 (Measures to Ensure the Safety of Personal Information)

• Regular internal audits (quarterly)
• Minimization and training of personnel handling personal info
• Internal management plan implementation
• Technical measures against hacking/malware
• Encryption of passwords and sensitive data
• Retention and protection of access records (min. 1–2 years)
• Access control systems and firewalls
• Locked storage for paper-based documents
• Physical access restrictions to data storage areas

Article 7 (Use of Cookies)

SPOGAMES does not use cookies that store or retrieve user information.

Article 8 (Data Protection Officer)

• Officer: Kim Suchang
• Position: CEO, Planning & Development Department
• Contact: 02-573-8103, snsports@hanmail.net
• Responsible Department: Technical Development
• Person in Charge: Lee Hyoseong
• Contact: 02-573-8103, patgames007@gmail.com

Article 9 (Request for Access to Personal Information)

• Department: Technical Development
• Contact: Lee Hyoseong, 02-573-8103, snsports@hanmail.net

Article 10 (Remedies for Infringement of Rights)

If you believe your personal information has been compromised, you may contact the following institutions:

• Personal Information Dispute Mediation Committee: 1833-6972 (www.kopico.go.kr)
• Personal Information Infringement Report Center: 118 (privacy.kisa.or.kr)
• Supreme Prosecutors’ Office: 1301 (www.spo.go.kr)
• Cyber Bureau, National Police Agency: 182 (ecrm.cyber.go.kr)

You may also appeal to the Administrative Appeals Commission (www.simpan.go.kr) if your rights are violated.

Article 11 (Changes to the Privacy Policy)

This policy is effective as of January 1, 2022.