ActionPower Corp.(http://www.actionpower.kr), hereinafter referred to as "the Company") collects and uses and personal information from Members using its Services through daglo website and its app (hereinafter referred to as "daglo"), based on the Member's consent.
The Company establishes the following policy to protect the personal information of our users, based on relevant law and regulations, policies and guidelines.
Personal Information Handling Policy
01. Collecting and Utilizing Personal Information
- The purpose of the Company's collection of personal information is to provide an optimized and customized service by checking the identity of the user and the intention to use the service. The Company collects only the minimum amount of information necessary to perform the essential functions of the service upon initial membership, and can collect additional information such as payment, shipment, and refund of the services provided by the Company.
- The Company will not use this information for any purpose other than those set out in the following Paragraph or provide it to a third-party without the consent of the user.
- The Company may collect and use personal information for the following purposes: In cases where collection and storage of resident registration number and bank account number are inevitable in accordance with relevant laws such as the Consumer Protection Act in Electronic Commerce etc., the National Tax Basic Act, the Electronic Financial Transactions Act, etc., if collection and storage of mobile phone number information is inevitable, you may notify the user and collect the information.
1) Purpose and Items of Collection
Purpose | Item |
Confirmation of identity, SSO integration(* For the purpose of registration, limited only for name, ID, password, mobile phone number, and e-mail address) | Name, ID, Password, Affiliation Authentication Mobile Number, Email AddressDate of birth / Gender |
Contact for notice such as contract execution and change of terms, confirmation of the applicant's name, complaint handling, etc. | Name, ID, mobile phone number, email address, phone number, address |
Service use and payment | Recipient information, billing information, bank account information, mobile phone number (when paying by mobile phone), cash receipt information |
Service Improvement | Audio and video files, call recording files, transcribed text, edited transcripts, Interaction patterns between users and the service |
Marketing | Advertising identifiers, service usage history, cookies |
2) Additional information may be collected during the provision of optional or customized services or events (including but not limited to Student Promotions and Ambassador Programs). On such collection of additional information, the affected Member will be notified of the collection, along with the items collected, the purpose of collection, and stored period.
3) The following information can be automatically generated and can be collected, stored, combined and analyzed during the process of using the service or the business process - usage information such as IP address, date of visit, history of service use, etc., audio or video files, call recording files, name and phone numbers stored in Contacts of the users' smartphones.
- When collecting user's personal information, the company collects it with the consent of the user and race, place of birth, personal history, ideology, political orientation, criminal record, health status will not be collected except by consent of the user or regulation of the law.
- The company will only accept memberships 14 years old or older. In principle, we will not collect personal information of children under the age of 14 who need the consent of legal representative to collect and use personal information. However, if the consent of legal representative is obtained, personal information of users under 14 years old can be collected/used.
- Company can collect personal information in the following ways:
1) Homepage, letter, fax, phone, customer center inquiry, application for event
2) Automatic collection through generated information collection tool
- In collecting personal information, the company shall establish a procedure by which the minimum personal information required for service provision shall be classified as 'required consent item' and other personal information shall be classified as 'optional consent item'. The company does not refuse to provide the service because the user does not provide personal information other than the minimum personal information required.
02. Use of Collected Personal Information
The Company uses personal information only for the following purposes: membership management, service development, provision and improvement, and safe use of the Internet.
- We use personal information for member management such as confirmation of member's intention, age confirmation and consent of legal representative, identity confirmation of user and legal representative, user identification, confirmation of member withdrawal intention.
- In addition to providing existing services(including advertising) such as content, we use personal information to find new service elements and improve existing services such as demographic analysis, analysis of service visits and usage records, formation of user-to-user relationship based on personal information and interest, and customized service based on acquaintances and interests.
- We use personal information for restrictions on use of members who violate the statute and ActionPower terms, prevention and sanctions against acts that hinder the smooth operation of services including fraudulent use, to prevent account theft and anti-corruption, to transfer notices such as amendment of terms, preservation of records for dispute settlement, and to protect users and operate services such as complaints.
- We use personal information for authentication, purchase and payment, delivery of goods and services in accordance with the provision of paid services.
- We use personal information for marketing and promotional purposes, such as providing event information, participation opportunities, and advertising information.
- We use personal information for service usage records, frequency analysis, statistics on service usage, service analysis, customized service according to statistics, and advertisement publication.
- We use personal information for service usage records and frequency analysis, statistics on service usage, service analysis using user behavior analysis tools, providing customized service according to statistics, and advertisement publication.
- We use personal information to build a service environment that users can use safely in terms of security, privacy and safety.
03. Consignment of Personal Information
- The Company may entrust the handling of personal information to others for the smooth and improved service. In this case, the company informs the user in advance of all the following matters in advance and obtains consent. The same shall apply when any of the following items is changed.
1) The person who is entrusted with the personal information handling
2) The contents of the work that entrusts the handling of personal information
- The company may disclose personal information of items 1) and 2) of paragraph A and consign to third party in accordance with the Personal Information Handling Policy when it is required to perform the contract for the provision of information and communication services and to enhance the convenience of the users.
- The company entrusts the following tasks related to the processing of personal information. In accordance with related laws and regulations, the company takes necessary measures to ensure that personal information is securely managed when contracted. The company takes into consideration the ability of the fiduciary to protect the personal information of the fiduciary contract, periodically confirms whether the fiduciary obligation is fulfilled, such as the safe management and destruction of personal information. Also, consignment information is limited to the minimum information needed to provide smooth service.
Entrusted Company | Entrusted Contents |
NHN KCP Corp | Processing of payment |
KG Inicis | Processing of payment |
NICE | Identity verification |
Google LLC | Usage data analysis through Google Analytics |
Google LLC | Usage data analysis through Firebase Analytics |
Amplitude | Usage data analysis |
Appsflyer | Media and website analysis for app installation |
AssemblyAI, Inc. | Provision of Service |
OpenAI OpCo, LLC | Provision of Service |
Microsoft Corporation | Usage data analysis through Microsoft Clarity |
04. Overseas Transfer of Personal Information
Some personal information is transferred overseas to perform the following affairs.
Entrusted Company | country | Transfer Date & Method | Information Management Officer | Items to be transferred | Purpose |
Amazon Web Services, Inc. | US | Cross-border tansfer via network at the time of Service use | ID, e-mail, smartphone information (device model, OS, device ID), IP Address, cookies, service access date and time, service usage data, call recording files, caller/receiver contact information (name, phone number) | Provision of Service and data storage | |
Google LLC | US | Cross-border tansfer via network at the time of Service use | ID, e-mail, smartphone information (device model, OS, device ID), IP Address, cookies, service access date and time, service usage data, call recording files, caller/receiver contact information (name, phone number) | Provision of Service and data storage | |
AssemblyAI, Inc. | US | Cross-border tansfer via network at the time of Service use | Audio, video input and call records submitted by Members | Provision of Service | |
OpenAI OpCo, LLC | US | Cross-border tansfer via network at the time of Service use | Audio, video input and call records submitted by Members | Provision of Service | |
Microsoft Corporation | US | Cross-border tansfer via network at the time of Service use | Website usage information(behavioral data such as page navigation, clicks, scrolling, etc.), browser information, device information, IP address, etc. | Analyzing patterns of interaction with the website for service improvement |
05. Retention of Personal Information: Period of Use and Destruction
The company reserves and uses the personal information of the user in principle for the period of notice and agreement, and if the purpose of collection and use of personal information is achieved or there is user's request to destroy the information, it will be destroyed without delay. However, the following information will be kept for the specified period for the following reasons.
- If necessary to preserve in accordance with the relevant laws and regulations, such as the Commercial Act, the user's personal information will be kept for a certain period prescribed by law. In this case, the company stores the information separately and keeps it only for the purpose of preservation and does not use it for other purpose such as marketing.
Relevant Law | Purpose | Items Collected | Stored Period |
Article 12-2 of Telecommunications Privacy Act | Receive a court warrant and provide it to the investigating agency upon request | Log record, IP, etc. | 3 months |
Article 6 of the Act on Consumer Protection in Electronic Commerce | Records of consumer complaints or disputes | Consumer identification information, dispute handling records, etc. | 3 years |
(same as above) | Record of payment and goods supply | Consumer identification information, contract / subscription withdrawal records, etc. | 5 years |
(same as above) | Record of agreement or withdrawal | (same as above) | (same as above) |
Article 85-3 Standard National Tax Act | Calculation of the national tax imposition period | Proof of tax receipt, etc. | 10 years |
(same as above) | Calculation of statute of limitations such as the right to collect national tax | Reporting standards of taxation standard and tax amount | 5 years |
Article 71 of the VAT Act | Books, tax invoices, income tax invoices, receipts, etc. | Taxation standard of the VAT and reporting data of the tax amount | 5 years |
Article 22 of Electronic Financial Transactions Act | To check the electronic financial transactions record | Records about electronic financial transactions, information about other parties, etc. | 5 years |
1) Reason for holding information according to related laws
2) Reason for holding information by company policy
- Fraud transaction record : For prevention of fraudulent transactions
Duration: 6 months
Retention items: ID, mobile phone number, e-mail address, date of birth, reasons for fraudulent transactions, value of membership at withdrawal, etc.
- Fraud transaction refers to a transaction of a method or content that violates the law, the terms of service between the company and the user, or the breach of public order or other company, member or other person's rights or interests.
- Retention and use period of collected personal information is from contract of service use to termination of service use contract. Also, in case of disagreement, the company shall destroy the personal information of the user without delay, except for the data which stores the information for a certain period according to the reasons for holding the information stated above, and instructs the trustee to destroy the personal information if it is entrusted to the third party.
- The personal information will be destroyed without delay after the purpose of collection and use is achieved. Personal information printed on paper is shredded or destroyed by incinerator, and personal information stored in electronic file format is destroyed using technical or physical methods that cannot reproduce the record.
06. Smart Phone App Management
When using the service through the smart phone app, the information is collected or transmitted after it is approved and the user is informed that it has access to the terminal information within the scope of receiving the personal information acquisition agreement. Not all information pertaining to the permissions is collected or transmitted immediately because the user has granted access to the device on the app.
07. User Rights
- The user can view, correct, and process your personal information at any time through the "Modify Information" of the daglo's Site. If you request by e-mail or in writing, we will review, correct or delete your personal information. In the event that your personal information is provided to or handed over to a third party, you may request the company or a "third party" / "trustee" to destroy it. However, it is not possible to correct the member ID, name, resident (business) registration number and alien registration number. Change of name due to name change or change of the resident registration number due to administrative issue may be exceptionally allowed. In case the correction or deletion is prohibited or restricted under any other law, such processing may be restricted. Also, in case of request for correction of personal information error, personal information will not be used or provided until the correction is completed, unless it is requested to provide personal information under other laws. If wrong personal information has already been provided, we will notify the third party of the result of the correction, and we will correct it.
- The user may request the suspension of processing of the personal information of the daglo site at any time. However, if the following cases apply, the request for processing stop can be rejected.
1) If there is a special provision in the law or it is inevitable to comply with statutory obligations
2) If there is a risk of harming another person's life or body, or there is a risk of unjustly infringing the property or other interests of another person
3) If the personal information is not processed, the information subject can not provide the contracted service, and it is difficult to fulfill the contract. If the information subject does not clearly disclose the intention to terminate the contract
- You may withdraw your consent at the time of registration at any time for the collection, use and provision of personal information. If you want to withdraw your consent, please click "Request for withdrawal of membership" on our website or contact us by written or e-mail, and we will take necessary measures such as deleting personal information without delay. However, if the company is required to preserve your personal information in accordance with the provisions of the Law or the Terms, such processing may be restricted. In this case, you must identify your identity (ID) and identity verification information to identify yourself, and you may be restricted in some services or you may not be able to use some services due to the withdrawal.
08. User obligation
Users are obliged to protect his/her personal information. The company is not responsible for the leakage of personal information due to the fact that the company cannot control the user's carelessness despite considerable caution, such as transferring, lending, losing or leave it logged in or hacking using methods or technologies that can not be blocked by security measures of related laws.
- You must keep your personal information up-to-date, and you are solely responsible for any problems caused by incorrect information input by users.
- You may be penalized in accordance with the Resident Registration Act along with the loss of user qualification in the case of trading with personal information of others such as stolen membership or resident registration number.
- The user is responsible for maintaining the security of the ID, password, etc. and cannot transfer or lease it to the third party. You are obliged to cooperate with the periodic change of password for security in accordance with the company's privacy policy.
- After using the company's services, the user must log out and close the web browser program.
- The user must comply with the Act on the "Promotion of Information and Communication Network Utilization and Information Protection", the "Personal Information Protection Act", the "Resident Registration Act", and other personal information laws.
09. Collection, Use, and Provision of Behavioral Information and Refusing Consent
The Company uses cookies to collect and use behavioral information without identifying individuals in order to improve the usability of the services provided to users and to provide optimized and customized services, benefits, and online personalized advertisements, etc. This information does not include information that can directly identify individuals, and is utilized for statistical analysis and service improvement purposes only. If you do not wish to have your data collected, you may refuse to have it collected by the method described in [Matters Concerning Automatic Personal Information Collection Device(Installation, Operation, and Refusal)] that follows this policy. However, if you refuse the storage of cookies, you may be restricted from using some services.
A. Information on Google Analytics
The Company uses Google Analytics, a web analytics service provided by Google LLC ("Google"), for the purpose of providing better services to users. Google Analytics uses cookies to collect information about how users use the Website. The information collected by Google through the cookie will be transmitted to and stored by Google on servers located in the United States. Google may provide this information to third parties as required by law or to third parties who process it on Google's behalf. Google will not associate your IP address with any other data held by Google. You can learn more about Google's privacy practices in the Google Analytics Privacy Notice.
If you wish to opt out of data collection by Google Analytics, you can do so on the Google site or by refusing the storage of cookies using the instructions [How to refuse cookie collection]. However, please note that if you refuse the storage of cookies, you may be restricted from using some services that require a login, and you are responsible for this.
B. Microsoft Clarity
Microsoft Clarity is a user behavior analysis tool that helps us understand how users interact with our website through features such as session replay and heatmaps. Microsoft Clarity uses cookies to collect information about how users use website. Clarity provides screen masking to prevent sensitive information from being collected, and you can opt out of data collection at any time in accordance with Microsoft's policies.
To opt out of data collection, you can do so on the Microsoft Clarity site or by refusing the storage of cookies using the instructions [How to refuse cookie collection]. However, please note that if you refuse the storage of cookies, you may be restricted from using some services that require a login, and you are responsible for this. You can learn more about Microsoft's privacy practices here.
C. KT NasMedia
KT NasMedia is not entrusted with the handling of personal information, and uses advertising identifiers(ADID, IDFA, etc.) to provide customized advertisements based on app and web usage history, and to conduct advertising effectiveness analysis and statistical analysis. This information is not personally identifiable and is collected automatically through cookies and SDKs.
If you wish to opt out of data collection, you can opt out of receiving marketing information through the [How to opt out of personalized ads] section.
Category | Behavioral items collected | How we collect behavioral information | Behavioral Information and Purpose of Collection | Retention/Use Period |
PC | Website usage information (behavioral data such as page navigation, clicks, scrolling, etc.), browser information, device information, IP address, etc. | Automatically collected when visiting the website | To analyze how you interact with the website, analyze statistics, and improve our services | Upon termination of service or withdrawal of membership |
Mobile | Advertising identifiers, access information, device information, etc. | Automatically collected when you run or use the App | To provide customized advertisements, measure advertising effectiveness, and analyze statistics | Upon termination of service or withdrawal of membership |
10. Matters Concerning Automatic Personal Information Collection Device(Installation, Operation, and Refusal)
A. The Company uses cookies that save and retrieve usage information to provide customized services to users. A cookie is a small piece of text file that is automatically created in the user's web browser when accessing the website. These cookies are automatically deleted when the user logs out and closes the web browser.
1) Purpose of Cookies
Cookies are used to collect information about user’s visit to and use of daglo service, IP address, browser type, access server, server location, response to certain advertisements, etc. to provide customized services (including personalized advertisements) and statistical analysis.
2) How to refuse cookie collection
User has the option to install cookies and can accept or reject the storage of cookies through browser settings. However, if user refuses to save cookies, the user may be restricted from using some services, such as logging in.
- Microsoft Edge
Set in [Settings > Cookies and site permissions > Cookies and site data]
- Chrome
Select ‘Block third party cookies’ in [Settings > Privacy & security > Third Party Cookies]
- Android
Select ‘Strict’ in [Settings > Internet settings > Security & Privacy > Smart Tracking Protection]
- iOS
Select 'Block all cookies' in [Settings > App > Safari > Advanced]
B. The Company uses user’s advertising identifiers and analytics software to provide users with services and advertisements(including personalized ads) that are relevant and more useful.
Advertising identifiers are collected automatically when advertising features are enabled in the OS settings of the smartphone or tablet PC users own, and users can opt out of having their advertising identifiers used for interest-based advertising by changing device settings or through the opt-out feature of the advertising platform provider.
- How to opt out of personalized ads
- Android: Select ‘Delete Ads ID’ in [Settings > Google > All services > Ads]
- iOS: Uncheck 'Personalized Ads' in [Settings > Privacy & Security > Apple Ads]
11. Designation of Personal Information Protection Officer
- 'ActionPower' is responsible for the handling of personal information, and has designated the person responsible for personal information protection as follows for the complaint handling and damage relief of information subject related to personal information processing.
1) Personal information protection officer
Name : Lee, Ji Hwa
Position : CTO
Contact :(+82) 070-7775-0033, jihwa.lee@actionpower.kr
The phone connects to the personal information protection department.
- You may inquire about personal information protection related complaints, complaints, damage remedies, etc., when you use the services (or business) of the company. The company will answer and handle inquiries of the information subject without delay.
If you need to report or consult about other personal information infringement, you can contact the following organizations.
- Personal Information Dispute Mediation Committee: www.kopico.go.kr / (1833-6972)
- Personal Information Infringement Report Center: privacy.kisa.or.kr / (118)
- Supreme Prosecutors' Office: www.spo.go.kr / (1301)
- National Police Agency: ecrm.police.go.kr / (182)
12. Obligation of Notice
The current privacy policy can be changed according to the policy of the government or the company. If there is any addition, deletion or modification of the contents, it will be notified in advance on the homepage or e-mail 7 days prior to enforcement. This policy will be enforced from the date of notification. If it is difficult to notify in advance, it will be announced immediately. However, if changes unavoidably operates to the users' disadvantage, the Company shall give notice 30 days in advance, and it will be implemented 30 days later. In addition, in the event that the contents related to matters requiring separate consent of the customer are added or changed in accordance with the related laws such as the collection and utilization of personal information, the provision of third parties, promotion of information network utilization and information protection, etc., you will receive separate consent from the customer.
Announcement date: 14 April, 2025
Effective date: 25 April, 2025