Onnuri DMC

Privacy Policy

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Exelbid Privacy Policy


OnnuriDMC, Inc. (the “Company” or “OnnuriDMC”) has developed this Privacy Policy (this “Privacy Policy”) to demonstrate our commitment to protecting our users’ privacy. The terms “Onnuri,” ‘we,” and “our” include the Company. The terms “you” and “your” refer to any individuals and entities (including our Publisher Partners, Advertising Demand Partners and other users) who use our Exelbid services or visits our Exelbid website (collectively, the “Exelbid Services”). This Privacy Policy is based on the standards provided under the domestic laws, including without limitation, the Act on Promotion of Information and Communications Network Utilization and Information Protection, etc. (“Information and Communications Network Act”) and Personal Information Protection Act, Protection of Communications Secret Act, Telecommunications Business Act and other applicable international standards. This Privacy Policy explains how we collect, use, share, or otherwise processes personal information from the users of Exelbid Services.


1. Purposes of Collection and Use


We may collect and process personal information about you for the following purposes. We do not otherwise share your personal information with third parties or use your personal information for any other purposes unless otherwise expressly provided herein.
We may use your personal information in connection with responding to your inquiries and grievances. That is, we may process personal information about you to confirm your identity, to review your questions or complaints and to communicate to you with our responses.
We may process your personal information to develop new services or provide more personalized and streamlined services based on demographic information or information about your interest and also to monitor statistics for your use of our services.
We may use or process personal information about you to invite you to our special promotional events from time to time.
We may collect and use personal information about you as our Member (as defined in our “Exelbid Terms of Service”) to verify your identity and status, to prevent unauthorized use or intrusion to our services, to confirm your consent to join our services, , to verify registration status and prevent you from creating multiple accounts and also for our record keeping purposes in connection with dispute resolution and customer services.


2. Our Policy on Collection and Use of Personal Information


We may collect personal information about you in connection with providing the Exelbid Services through the following methods.

1). Collection Methods

We may use the following methods to collect personal information about you.
(1) through our website, on paper forms, via facsimile and phone, or Q&A board on our website or by your entrance to our promotional events;
(2) through our agents and third party partners; or
(3) via information collecting tools.

2). Collection and Use Policy Covering All Members

The following information about you may be collected on our website (www.onnuridmc.com) or our Exelbid website (www.exelbid.com) and we only use such information for the purposes set forth under “1. Purposes of Collection and Use.“
(1) Information collected: name and email address
(2) Other information automatically collected: cookie, IP address, usage history, visiting history, and device information (model number, operating
system and unique identifiers of the device)
(3) Change of Control Notice: In the event that we are involved in a bankruptcy, merger, acquisition, reorganization, or sale of assets, your personal
information may be sold or transferred as part of such transaction. This Privacy Policy will apply to your personal data as transferred to the new
entity.

3). Information We Collect Through Exelbid

Personal information collected by Exelbid also includes the data about our Publisher Partners and Advertising Demand Partners (as defined in our Exelbid Terms of Service) collected from their use of manage.exlebid.com and the Exelbid SDK.

(1) Terms of Privacy for Information collected from our Exelbid website (manage.exelbid.com, collectively with www.exelbid.com the “Website”)

(a) Personal information collected from our Publisher Partners, Advertising Demand Partners and employees of OnnuriDMC Inc.:
(i). Personal information that we require from our users who desire to apply for using Exelbid including, but not limited to, name, E-mail address,
physical address, phone number and the entity name.
(ii). You may be requested to provide additional information such as your ID and password for you to create an account on the Website.
Such information is only used to make the Exelbid Services available to you and to provide relevant information about Exelbid.
(iii). If you do not wish to receive promotional information, you may opt not to receive such information by following the instruction contained in
the promotional e-mails.

(iv). We may collect information about web pages you visited, popular search terms and whether you used a secured connection to provide optimized service. Also, during the course of your use of the Exelbid Services, our system may automatically record certain personal information about you such as IP address, usage history, visiting history and device information (model number, operating system and unique identifiers of the device) and cookie information. You may reject cookies or delete them at any time. However, you may not be able to use a certain portion of the Exelbid Services if you reject our use of cookies.

(b) Your Right to Review and Update Information on the Website.
You may access and review your personal information that you provided when you created your user account on the Website so that you can
update your information from time to time. If you wish to cancel and delete your account, you may login and follow the instructions contained on
our Website.
Unless we have a legal basis to store your personal data to comply with tax or accounting rules and regulations, we will delete or de-identify
the personal
information we have collected about you upon your request to delete or cancel your account.

(c) Sharing of Personal Information of Our Users
We may disclose personal information about you if necessary to respond to the inquiries or verification requests that we receive in connection
with the Exelbid Services. We may also share information about our users within the Company to provide, understand, or improve our services.

(2) Information Collected through Ad Inventory

We may collect the following personal information about the users of Ad Inventory (as defined in our Exelbid Terms of Service) that uses the Exelbid SDK.

(i). IP address, iOS identifier for advertising (IDFA), Android advertisement ID or Exelbid unique identifier.
(ii). Precise geographic location if location services are enabled. You should be aware that even if the location services are disabled, we can still infer location data based on your IP address.
(iii). demographical information collected by Exelbid Publisher Partners (e.g., your age or gender) or information about your personal interests.
(iv). information about your device, such as the type, model number, manufacturer, operating system (e.g. iOS or Android), mobile carrier, browser (e.g. Chrome or Safari), screen resolution and other relevant information about your device.
(v). Information about ad inventory and its version, the start/stop time of the ad inventory, your current time zone and network connection type (e.g. WiFi, celluar)
(vi). Information about the type of Ad Content (as defined in our Exelbid Terms of Service), the location of the Ad Content within the Ad Inventory, whether or not it has been viewed or clicked, whether the user visited the Advertising Demand Partner’s website or used its services.

(a) Our Use of Personal Information Collected through Ad Inventory

We use personal information collected through Ad Inventory that use the Exelbid SDK for the following purposes.

(i). Publish Ad: To allow Publisher Partners to offer advertising space on their Ad Inventory so that Advertising Demand Partners may bid on such Ad Inventory to deliver their Ad Content.
(ii). Interest based advertising: provide targeted advertising content based on personal interests information collected by Advertising Demand Partners.
(iii). Location Targeting: Advertising Demand Partners may utilize the location data collected to provide targeted advertising based on prior or current location information.
(iv). Reporting: We may share the ad content data (e.g. how many time it was displayed) to Advertising Demand Partners.
(v). Setting Frequency: We monitor activities so to prevent users from seeing the same ad content repeatedly.
(vi). Detect and Prevent Fraud: We use personal information to detect fraudulent clicks thus protecting our Publisher Partners and Advertising Demand Partners from fraud and also to improve our services.
(vi). Maintenance: We audit, study and analyze personal information to maintain, protect and improve our services, and to ensure that our system runs properly. In doing so, we may share personal information with our third party partners for additional support.

(b) Processing of Personal Information for Personalized Advertising

We have the following policy in place to monitor and control processing of personal information collected from users of AD Inventory for providing personalized advertising.
(i). (GDPR) European Economic Area, the United Kingdom and Switzerland

a. Consent: If you are a Publisher Partner and would like to provide personalized advertising to users in the European Economic Area, the United Kingdom, or Switzerland, then you must first obtain the prior consent of such users. Some Publisher Partners may be required to obtain the prior consent of their users for this purpose even if the users are located outside of these regions. If the Publisher Partner obtained such consent, Exelbid and our Advertising Demand Partners will collect, use, share, and otherwise process all of the personal information described above for the purposes of serving personalized advertising.
If you do not wish to offer personalized advertising, then we will not process personal information of your users for this purpose. That is, we will not collect, use, or share your users’ iOS Identifier for Advertising or Android Advertising Identifier, precise location data, or your demographic or interest information. We can and will still serve your users with contextual advertising, that is advertisements targeted to the content or type of app your users are using (for example, serving an ad for a video game to a gaming app).


b. Withdrawal of Consent: You may withdraw your consent to our personalized advertising experience at any time.
Publisher Partners may provide a way for their users to withdraw the consent previously given directly from the Ad Inventory. If a user withdrew its consent from within the Ad inventory, we will no longer collect, use, share, or otherwise process personal data from such Ad Inventory to personalize the user’s advertising experience.
Also, a user may change his/her device settings to withdraw the consent to Exelbid’s personalized advertising experience for all apps on that device.
On iOS, you can do so by enabling the “Limit Ad Tracking” setting.
On Android devices, you may do so by enabling the “Opt out of Ads Personalization” setting.
You may reject cookies or delete them at any time by change settings on your mobile or PC browser. However, you may not be able to use a certain portion of the Exelbid Services if you reject our use of cookies
After the user enabled the respective settings on the device as provided above, we will no longer collect, use, share, or otherwise process personal information from that device for personalized advertising experience.
Unless we have another legal basis for keeping the user’s personal data, we will also delete or de-identify the personal information we have collected about such user within 30 days from the date on which the user applied one of the above methods to withdraw consent.
Even if the users of Ad Inventory do not consent to a personalized advertising experience, or later withdraw their consent, we will still process personal information about the users when and as necessary to comply with applicable laws or to support our legitimate interests.


c. Where Legally Required: We will process personal information as necessary to comply with applicable laws. For example, we will collect from the users of Ad Inventory, IP addresses to identify a country location so that we know whether such users are located in the European Economic Area, the United Kingdom, or Switzerland, but we will not share the users’ full IP addresses or retain the same internally. Similarly, if the users consent to our personalized advertising experience, but later withdraw such consent, we will continue to retain a record of the iOS Identifiers for Advertising or Android Advertising IDs of their devices for the purpose of recording when they consented and withdrew their consent to our processing of personal information. As part of processing the users’ withdrawal of consent requests, we will shares the iOS Identifiers for Advertising or Android Advertising IDs of the withdrawing users’ devices to the respective Exelbid Publisher Partners and Advertiser Partners so that they can also be informed of the withdrawal.


(ii). Minors Under the Age of 13 (COPPA)

We are not permitted to collect information from Ad Inventory directed to children under the age of 13 for purposes of personalized advertising. We may, however, collect information from Ad Inventory directed to children for other purposes, such as serving advertisements based on contextual information, like the content or type of app they are using (for example, serving an ad for a video game to a gaming app).
In addition, if a user resides in the European Economic Area, the United Kingdom, or Switzerland, then the user must be at least 16 years of age to give his/her consent to Exelbid’s personalized advertising experience. We do not collect or otherwise process personal data from individuals in the European Economic Area, the United Kingdom, and Switzerland whom we know are under the age of 16, except to comply with apply laws or to support our legitimate interests.


3. When We Share Personal Information with Third Parties


We use personal Information about our users only to the extent provided under “2. Policy on Collection and Use of Personal Information.” Except where we are required to disclose or submit personal information to comply with applicable laws, regulations, legal processes, governmental requests or court orders, we will not use or disclose to any third party personal data about the users for any other purposes without their prior consent.


4. Retention and Use of Personal Information


We will promptly delete or de-identify the personal data we have stored about our users once we have accomplished the purposes for collecting and storing the personal data as provided above with exception of the following reasons (and no other reasons) in which cases, we may store the personal information for the duration set forth below.
Storing Personal Information Pursuant to Applicable Laws
To the extent required under applicable laws, including, without limitation, the Commercial Act and the Act on the Consumer Protection in Electronic Commerce, etc., we may store personal information about you for certain period of time. We store such information only to be in compliance with applicable laws and only for the time period set forth below. In no case we use the information stored hereunder for any other purpose.

가. Pages Visited

(1) Applicable Law: Protection of Communications Secret Act
(2) Retention Period: 3 months

나. Records on Customer Complaints or Disputes

(1) Applicable Law: Act on the Consumer Protection in Electronic Commerce, Etc.
(2) Retention Period: 3 years

다. Records on Payments Made and Collected for Supply of Goods

(1) Applicable Law: Act on the Consumer Protection in Electronic Commerce, Etc.
(2) Retention Period: 5 years

라. Records on Entering into or Withdrawing from Contractual Relationship

(1) Applicable Law: Act on the Consumer Protection in Electronic Commerce, Etc.
(2) Retention Period: 5 years

마. Records on Collection and/or Processing of Credit Information

(1) Applicable Law: Credit Information Use and Protection Act
(2) Retention Period: 3 years

바. Records on Advertising and Display

(1) Applicable Law: Act on the Consumer Protection in Electronic Commerce, Etc.
(2) Retention Period: 6 months


5. Destruction of Personal Information and The Methods Used


We will promptly destroy personal information that is no longer required to fulfil the identified purposes stated above. We apply the following procedures in destroying such personal data.

1). Destruction Procedures

We will move such personal information that is no longer required to fulfil the identified purposes to a separate DB (separate files in case of information in hard copies) and maintain it for set duration of time or promptly destroy as required by applicable laws. We will not use the personal information that is maintained in separate DB for any reasons except to comply with applicable laws.

2). Disposal Method
(1) Personal information stored in electronic format will be deleted by using a technical approach to prevent it from being restored.
(2) Information on paper form will be shredded or incinerated.


6. Rights of Users and Their Legal Guardians


Users of Exelbid can login in to check and update their personal information registered on our system at any time. If they wish to withdraw their consent to our processing of personal information about them, then the users can either withdraw their consent or request for cancellation of their accounts (please note that you may not be able to use our services or any part thereof upon your withdrawal of your consent or cancellation). To access or modify your personal information, you can login to your account and click on ‘update member information’ and to cancel your account (or to withdraw your consent), you can click on ‘closing account’ and follow the instructions. You can also write to us or call or e-mail us and make your request to modify or cancel. If you request a correction of your personal information registered on our system, we will not use or share your information until the correction is completed. Also, if we have already shared the personal data containing an error with any third party, we will promptly notify the third party of the correction.


7. How We Protect Your Personal Information


We strive to safeguard personal information of our users by utilizing technology and management system as follows.
1). Encryption of Personal Data
Sensitive and critical information such as your password is encrypted and only you can check and modify such information.
2). Protection from Security Threats
We are doing our best to safeguard personal information of our users from being leaked or damaged by hacking or computer viruses. In order to prevent the loss of personal information, we back up our data on a regular basis, use the latest anti-virus program, and use encryption technology to securely transmit personal information on our network. In addition, we use firewall to block unauthorized access from the outside, and we try to equip all possible technical devices to secure our system.
3). Limiting Access to Your Personal Information
To reduce the risk of security breach, we are limiting access to personal information of our users to only those employees who are specifically trained for handling of such information. We also change the password to the access periodically and place emphasis on the importance of safeguarding the personal information and compliance with applicable laws and policies by training our employees on a regular basis.
4). Special Force Dedicated for Protection of Personal Information
We have a special task force dedicated solely for protection of personal information of our users. We continuously monitor our compliance with applicable laws and regulations and we strive to correct any breach or problem immediately upon notice.


8. Responsible Personnel


We have designated the following persons as administrators of personal information that we collect and process. You many direct your inquiries or complaints on our processing of your personal information to them.
Personal Information Administrator (Chief)
Name: YoonKyu Kim
Title: Director of Platform Business Division
E-MAIL: yoonkyu@onnuridmc.com
Personal Information Administrator (Assistant Chief)
Name: YongChan Bae
Title: Head of Exelbid
E-MAIL: yongchanb@onnuridmc.com
You may contact the above named administrators with all your inquiries on personal information. We will attempt to respond to your inquiries in a timely manner.

You may also contact the following agencies to report any personal information breach or other related inquiries.
Privacy Infringement Report Center (http://www.118.or.kr, or dial 118)
Cyber Crime Investigation Unit, Supreme Prosecutor’s Office (http://www.spo.go.kr, or dial 1301)
Cyber Terror Response Center, National Police Agency (http://www.ctrc.go.kr, or dial 182)


9. Applicability of this Privacy Policy


Please note, this Privacy Policy does not apply to any personal information collected by other websites that you may access through the links provided on our services.


10. Our Obligation to Notify You of any Changes to this Policy


We will provide at least 7 days prior notice, either on the notice tab on our Website or via E-mail, for any planned changes or modifications to this Privacy Policy. Any changes will be effective as of the effective date on the notice. If, however, we make any changes to signification provisions such as the purposes for collecting and using personal information about you and the circumstances on which we share such information with third parties, then we will provide at least 30 days prior notice for such signification changes. If any changes require your prior consent under applicable laws, including, without limitation, the Act on Promotion of Information and Communications Network Utilization and Information Protection, Etc. and Personal Information Protection Act, then we will request your consent prior to making any such changes.

Version: 1.1
Effective : August 21, 2019 (version 1.1)
Effective: November 1, 2016 (version 1.0)