Action Power Co., Ltd. Privacy Policy
Action Power Co., Ltd. (https://www.actionpower.kr, hereinafter referred to as the "Company") collects, uses, and provides personal information based on the consent of members who use the Internet sites and mobile applications (daglo.ai, hereinafter referred to as "Daglo") operated by the Company.
The Company complies with relevant laws, regulations, and guidelines related to personal information protection in the Republic of Korea. To protect members' personal information and rights and to ensure that members can use the service with peace of mind, the Company has established the following Privacy Policy.
01. Collection and Use of Personal Information
A. The purpose of the Company collecting personal information is to verify the user's identity and intent to use the service, thereby providing optimized and customized services. The Company collects only the minimum information necessary to perform the essential functions of the service upon initial membership registration. The Company may additionally collect information necessary for payment, product delivery, and refunds associated with the use of services provided by the Company.
B. The Company does not use personal information for purposes other than the collection and use purposes stated in Paragraph C of this Article, nor does it provide such information to third parties without the user's consent.
C. The Company may collect and use personal information for the following purposes. In cases where the collection and storage of Resident Registration Numbers and bank account numbers are inevitable under relevant laws such as the Act on the Consumer Protection in Electronic Commerce, the Framework Act on National Taxes, and the Electronic Financial Transactions Act, or where the collection and storage of mobile phone number information are inevitable for billing settlement such as mobile phone micropayments, the Company may collect such information after notifying the user.
- Collection Purposes and Items
Purpose | Items | Mandatory/Optional |
Identity Verification, SSO Linkage
(*For registration purposes, limited to Name, ID, Password, Phone Number, Email Address) | Name, ID, Password, Email Address, Date of Birth, Gender | Mandatory |
Contact for Contract Fulfillment and Notices of Terms Changes, Confirmation of Intent, Handling Customer Complaints | ID, Mobile Phone Number, Email Address, Phone Number, Address | Mandatory |
Service Usage and Payment | Recipient Information, Payment Information, Bank Account Information, Mobile Phone Number, Cash Receipt Information, LLM Conversation History (including input info such as files, images, videos), Information permitted by the user (Voice, Video, File, URL, Image, etc.) | Mandatory |
Marketing | Advertising Identifier, Service Usage Records, Cookies | Optional |
Service Quality Improvement | Voice and Video Files, Call Recording Files, Text Conversion Results, Edited Text, Patterns of interaction with the service | Optional |
Provision of Customized Services and User Analysis | Gender, Age Group, Occupation, Purpose of Use, Expected Functions | Optional |
- Additional Services: Additional personal information collection may occur during the process of applying for additional services, customized services, or events (including but not limited to support programs, supporter operations). In such cases, the Company will inform the user of the ‘Items of personal information collected, Purpose of collection and use, and Retention period’ and obtain consent at the time of collection.Additionally, optional survey information such as gender, age group, occupation, and areas of interest may be collected during the initial service onboarding process for profile setting and customized recommendations. This information is limited to cases where the user directly inputs it, and there is no restriction on service usage even if it is not entered.
- Other The following information may be automatically generated and collected, stored, combined, and analyzed during the service usage or business processing process:
- IP Address, Smartphone Terminal Information (Device Model, OS, Mobile Carrier, Device ID), Service Access Date/Time, Service Usage Records (History), Voice and Video Files, Call Recording Files, Names stored in the mobile phone contacts (Call Counterpart Name), Phone Numbers, etc.
D. When collecting user personal information, the Company collects it with the user's consent unless there is a legal basis. The Company does not collect information that may infringe on the user's basic human rights, such as race, place of origin, domicile, ideology, political inclination, criminal record, or health status, except with the user's consent or as required by law.
E. The Company allows membership registration only for those aged 14 or older and, in principle, does not collect personal information of children under 14 years of age, which requires the consent of a legal representative. However, if the consent of a legal representative is obtained, the personal information of a user under 14 may be collected/used.
F. The Company may collect personal information via the following methods:
- Homepage, written form, fax, telephone, customer center inquiries, event participation, initial app survey.
- Automatic collection through information generation collection tools.
G. In collecting personal information, the Company classifies the minimum personal information necessary for service provision as "Mandatory Consent Items" and other personal information as "Optional Consent Items," providing a procedure to consent to them individually. The Company does not refuse the provision of services on the grounds that the user does not provide personal information other than the minimum necessary.
02. Use of Collected Personal Information
The Company uses personal information only for the following purposes, including member management, service development/provision/improvement, and establishment of a safe internet usage environment.
A. Personal information is used for member management, such as confirmation of intent to join, age verification and legal representative consent proceedings, identity verification of users and legal representatives, user identification, and confirmation of intent to withdraw.
B. In addition to providing existing services (including advertisements), personal information is used to discover new service elements and improve existing services, such as demographic analysis, analysis of service visits and usage records, formation of relationships between users based on personal information and interests, and provision of customized services based on acquaintances and interests. Optional survey information provided by the user (gender, age group, occupation, purpose of use, preferred functions, etc.) is utilized for providing personalized services, advancing recommendation functions, service improvement, and statistical analysis.
C. Personal information is used for user protection and service operation, such as restrictions on members who violate laws and the Company's Terms of Use, prevention and sanctions against acts that hinder the smooth operation of the service (including fraudulent use), prevention of account theft and fraudulent transactions, delivery of notices such as revisions to terms, preservation of records for dispute mediation, and handling of civil complaints.
D. Personal information is used for identity authentication, purchase, and fee payment associated with the provision of paid services.
E. Personal information is used for marketing and promotional purposes, such as providing event information, participation opportunities, and advertising information.
F. Personal information is used for service analysis and providing customized services and advertisements based on statistics, utilizing service usage records, access frequency analysis, service usage statistics, and user behavior analysis tools.
G. Personal information is used to build a service usage environment where users can use the service safely in terms of security, privacy, and safety.
03. Entrustment of Personal Information Handling
A. To provide smooth and improved services, the Company may entrust the handling of personal information to others. In this case, the Company notifies the user of all the following matters in advance and obtains consent. The same applies if any of the following matters change: 1) The person receiving the entrustment of personal information handling (Trustee), 2) The content of the work involving the entrustment of personal information handling.
B. If necessary for the fulfillment of a contract regarding the provision of information and communications services and for the enhancement of user convenience, the Company may entrust the handling of personal information to others without going through the notification and consent procedures by disclosing the matters in Paragraph A in the Privacy Policy.
C. The Company entrusts duties related to the processing of personal information as follows and takes necessary measures to ensure that personal information is safely managed during the entrustment contract in accordance with relevant laws. The Company considers the trustee's ability to protect personal information upon entering into an entrustment contract and periodically checks whether the trustee fulfills obligations such as the safe management and destruction of personal information. Also, the entrusted information is limited to the minimum information necessary to provide smooth services.
Trustee | Content of Entrusted Work |
NHN KCP Corp. | Payment Processing |
KG Inicis Co., Ltd. | Payment Processing |
Toss Payments | Payment Processing |
NICE Information Service Co., Ltd. | Identity Authentication |
Google LLC | Statistical analysis via Google Analytics/Firebase Analytics, Linkage for providing LLM-based functions |
AssemblyAI, Inc. | Service Operation |
OpenAI OpCo, LLC | Linkage for providing LLM-based functions |
Anthropic PBC | Linkage for providing LLM-based functions |
Perplexity AI, Inc. | Linkage for providing LLM-based functions |
X.AI LLC | Linkage for providing LLM-based functions |
Appsflyer | Analysis of media and sites utilized upon app installation |
Amplitude | Statistical analysis via Amplitude |
Microsoft Corporation | Statistical analysis via Microsoft Clarity |
Airbridge | Mobile App/Web inflow path analysis, Ad performance measurement & statistical analysis, Attribution data processing |
Sentry | Error monitoring and log analysis |
04. Overseas Transfer of Personal Information
To enhance personal information processing, the Company entrusts data to overseas entities as follows:
Trustee (Location) | Transfer Date & Method | Contact Info | Items Transferred | Content of Entrusted Work | Purpose & Retention Period |
Amazon Web Services, Inc.
(USA) | Transmitted frequently via server during service use | aws-korea-privacy@amazon.com | ID, Email, Smartphone info (Device model, OS, Device ID), IP Address, Cookies, Access logs, Usage records, Call recordings, Counterpart names, Phone numbers, etc. | Provision of service operation environment and data storage | Retained during service provision period |
Google LLC
(USA) | Transmitted frequently via server; User input in chat; Documents containing personal info; Transmission for LLM functions (e.g., summary based on STT) | googlekrsupport@google.com | ID, Email, Smartphone info, IP Address, Cookies, Access logs, Usage records, Call recordings, Counterpart names, Phone numbers; Chat history or STT results when using LLM functions | Provision of service operation environment and data storage | Retained during service provision period |
AssemblyAI, Inc.
(USA) | Transmitted frequently via server during service use | support@assemblyai.com | Voice and video files input by user, Call recording files | Provision of service operation environment | Retained during service provision period |
OpenAI OpCo, LLC
(USA) | Transmitted when using LLM functions (User input, Documents, STT based features) | privacy@openai.com | Chat history or STT results when using LLM functions | Provision of service operation environment | Retained during service provision period |
Anthropic PBC
(USA) | Transmitted when using LLM functions | privacy@anthropic.com | Chat history or STT results when using LLM functions | Provision of service operation environment | Retained during service provision period |
Perplexity AI, Inc.
(USA) | Transmitted when using LLM functions | support@perplexity.ai | Chat history or STT results when using LLM functions | Provision of service operation environment | Retained during service provision period |
X.AI LLC
(USA) | Transmitted when using LLM functions | privacy@x.ai | Chat history or STT results when using LLM functions | Provision of service operation environment | Retained during service provision period |
Microsoft Corporation
(USA) | Transmitted frequently via server during service use | privacy@support.microsoft.com | Website usage info (Page movement, clicks, scrolls), Browser info, Device info, IP Address, etc. | Analysis of interaction patterns, Statistics, and Service improvement | Retained during service provision period |
Sentry
(USA) | Transmitted frequently via server during service use | compliance@sentry.io | Device info, IP address, User ID | Collection of error information | Retained during service provision period |
05. Retention of User Personal Information: Period of Use and Destruction
In principle, the Company retains and uses the user's personal information for the notified and agreed period and destroys it without delay when the purpose of collection and use is achieved or upon the user's request for destruction. However, the following information is preserved for the specified period for the reasons listed below.
A. Reasons for Information Retention under Relevant Laws and Company Policy
If preservation is necessary under the provisions of relevant laws such as the Commercial Act, user personal information is stored for a certain period prescribed by law. In this case, the Company stores the information separately and uses it only for the purpose of storage, not for marketing or other purposes.
- Reasons for Information Retention under Relevant Laws
- Communication Secrets Protection Act (Art. 12-2): Log records, IP Address, etc. (Provided upon request by investigative agencies with a court warrant) - 3 Months
- Act on Consumer Protection in Electronic Commerce (Art. 6):
- Records on consumer complaints or dispute processing: 3 Years
- Records on payment and supply of goods: 5 Years
- Records on contract or withdrawal of subscription: 5 Years
- Framework Act on National Taxes (Art. 85-3):
- National tax limitation period calculation (Tax evidence, etc.): 10 Years
- Calculation of extinction prescription for national tax collection rights (Tax base and tax amount reports): 5 Years
- Value-Added Tax Act (Art. 71): Books, tax invoices, receipts, etc. (VAT tax base and tax amount reports): 5 Years
- Electronic Financial Transactions Act (Art. 22): Records on electronic financial transactions: 5 Years
- Reasons for Retention by Company Policy
- Fraudulent Transaction Records:
- Reason: Exclusion of fraudulent transactions
- Retention Period: 6 Months
- Items: ID, Mobile Phone Number, Email Address, Date of Birth, Reason for Fraud, Member Status upon Withdrawal, etc.
B. The retention and use period of collected personal information is from the time of service use contract execution (Sign-up) to the termination of the service use contract (Application for withdrawal, including forced withdrawal). Also, upon termination of consent, the Company destroys the user's personal information without delay, except for data stored for a certain period according to the information retention reasons specified above. If personal information handling is entrusted to a third party, the trustee is also instructed to destroy it.
C. A dormant account is an account that has not been used for at least 2 years. The Company reserves the right to delete accounts that have been dormant in the service for at least 2 years, as well as the activity and data of such accounts. The criteria for the dormancy period are determined according to the Service Dormancy Policy.
D. The Company notifies the user of the fact that personal information will be destroyed or separated/stored/managed, the expiration date, and the items of personal information concerned via notice, email, etc., 30 days prior to the expiration of the period in Paragraph C. For this purpose, users must provide/update accurate contact information to the Company.
E. User personal information is destroyed without delay after the purpose of collection and use is achieved. Personal information printed on paper is destroyed by shredding or incineration, and personal information stored in electronic file format is destroyed using technical or physical methods that make the records unrecoverable.
06. Smartphone App Management
When using the service through a smartphone app, information is collected or transmitted after notifying the user that the app accesses device information within the scope of the consent for personal information collection and use and obtaining approval. Just because a user allows device access permissions in the app does not mean that all information related to the allowed permissions is immediately collected or transmitted.
07. User Rights
A. Users may view or correct their personal information at any time through "Information Modification" on the Daglo site. If requested via email or in writing, we will process the viewing, correction, or deletion. If the user's personal information has been provided to a third party or entrusted, the user may request destruction from the Company, the 'Third Party', or the 'Trustee'. However, correction of Member ID, Name, Resident Registration Number, and Foreigner Registration Number is not possible, except for name changes due to renaming or exceptional changes to Resident (Business) Registration Numbers due to administrative issues. Processing may be restricted if correction or deletion is prohibited or restricted by other laws. In the case of a request for correction of personal information errors, the relevant personal information will not be used or provided until the correction is completed, unless the provision of personal information is requested by other laws. If incorrect personal information has already been provided, we will notify the third party of the correction result so that the correction can be made.
B. Users may request the suspension of processing of their personal information on the Daglo site at any time. However, the request for suspension of processing may be refused in the following cases:
- Where there are special provisions in the law or it is inevitable to comply with statutory obligations.
- Where there is a concern of harming the life or body of another person or unjustly infringing on another person's property or other interests.
- Where it is difficult to perform the contract, such as not being able to provide the agreed service to the data subject if personal information is not processed, and the data subject has not clearly expressed their intention to terminate the contract.
C. You may withdraw your consent to the collection, use, and provision of personal information through membership registration at any time. Withdrawal of consent can be done by clicking "Apply for Membership Withdrawal" on the Company site or by contacting us in writing or by email, and we will take necessary measures such as deleting personal information without delay. However, if the Company is required to preserve your personal information according to laws or terms, such processing may be restricted. In this case, you must reveal your Member ID and identity verification information for identification purposes, and there may be some restrictions on the service or inability to use some services due to the withdrawal.
08. User Obligations
Users have an obligation to protect their own personal information. The Company is not responsible for problems arising from the leakage of personal information due to the user's own negligence, such as transfer, lending, or loss of ID, password, or access media, or leaving the seat while logged in, or due to internet problems that the Company cannot control despite considerable caution, such as hacking using methods or technologies that cannot be blocked by security measures under relevant laws, provided that there is no fault attributable to the Company.
A. Users must keep their personal information up to date, and users are responsible for problems arising from inaccurate information input.
B. Signing up using another person's personal information or stealing a Resident Registration Number for product transactions may result in loss of user qualifications and punishment under the Resident Registration Act.
C. Users are responsible for maintaining the security of their ID, password, etc., and may not transfer or lend them to a third party. Users are obliged to cooperate with periodic password changes for security in accordance with the Company's privacy policy.
D. Users must close the login account and web browser program after using the Company's service.
E. Users must comply with laws related to other personal information, such as the "Act on Promotion of Information and Communications Network Utilization and Information Protection," "Personal Information Protection Act," and "Resident Registration Act."
09. Matters Concerning the Collection, Use, Provision, and Refusal of Behavioral Information
The Company collects and uses behavioral information without identifying individuals by utilizing cookies to provide service usability improvements, optimized customized services and benefits, and online customized advertisements to users. This information does not include information that can directly identify individuals and is used only for statistical analysis and service improvement purposes. If you do not wish for data to be collected, you may refuse collection through the method in [Matters Concerning the Installation, Operation, and Refusal of Automatic Personal Information Collection Devices] at the bottom of this policy. However, refusing to store cookies may limit the use of some services.