Refinder Privacy Policy
Last modified June 18, 2024
Thinkfree Inc. (hereinafter referred to as ‘Thinkfree’ or the ‘Company’) complies with laws, regulations, and guidelines for personal information protection and establishes and publishes a personal information processing policy to protect users’ personal information and rights and to smoothly handle complaints related to personal information.
The Company complies with the relevant laws and personal information protection regulations and guidelines of the Republic of Korea that are mandatory for personal information controllers and establishes the Privacy Policy and opens it to the public.
This Privacy Policy applies to the services based on the Thinkfree Service (hereinafter referred to as ‘Service’) Account, offered by the Company.
Matters not specified in this Privacy Policy shall be governed by the operation policy and rules that complete the package service and relevant laws, and the terms of use for the subsequent services and the operation policy regulations for each service in the Privacy Policy.
Also, if this Privacy Policy is inconsistent with a specific guideline, the operation policy and the specific guideline will prevail.
1. Purpose of Personal Information Collection and Utilization
The company collects personal information as follows for membership, smooth communication, service application, and consultation.
In terms of member management, personal information is used to confirm subscription intention, handle requests such as complaints and inquiries, and give notices.
In terms of service provision, personal information is used for purposes such as sending estimates, contracts, and invoices, providing contents, self-certification, age authentication, payment/settlement, and debt collection.
In addition, your personal information such as email address, name, profile image etc. may be displayed within the service under circumstances where personal information needs to be viewed, for example, when other users share their files with you or your post is published.
Personal information is used to provide event information for marketing activities or to analyze user access frequency or service usage statistics.
2. List of Personal Information, and Personal Information Retention and Utilization Period
The Company processes and retains personal information within the retention period agreed upon when collecting personal information from users or within the retention period in accordance with the law.
Service | Items of collection | Retention and Utilization Period |
| Sign up | [For Email ID member sign-up][Required] Email (User ID), password, date of birth[Optional] Profile information setting: Profile image, Email (User ID) to consent to marketing and promotions [For Social Login member Sign-on]
[OAuth information for social networking service account log-in] [Required] Email (User ID), email, name (nickname), Token received from OAuth service provider [Consent by the legal guardian provided for signing up of a user under 14][Required] Consent and agreement by the legal guardian | For membership withdrawal and termination of service agreement(However, an exception applies when the information is stored separately for a certain period according to the relevant laws.) |
| Phone number verification | [Required] mobile number | |
| Recovery email registration | [Required] Email | |
| Inquiry | [Required] Information required for customer consultation: Name, email, product information |
Service | Items of collection | Retention and Utilization Period |
| Refinder | [Service usage] [Required] Name, Email [Product inquiry] [Required] Company name, Product information[Optional] Phone number | For membership withdrawal and termination of service agreement(However, an exception applies when the information is stored separately for a certain period according to the relevant laws.) |
Retention period according to related laws
Retention items | Relevant statutory provisions | Retention period |
| Records of contracts or revocation of subscriptions | Act on the consumer protection regarding e-commerce | 5 years |
| Record of payment and supply of goods | 5 years | |
| Record of consumer complaint or dispute resolution | 5 years | |
| Visit history | Protection of Communications Secrets Act | 3 months |
| Record of electronic documents using certified electronic address | Framework Act on electronic documents and transactions | 10 years |
3. Provision of Personal Information to Third Parties
The Company processes the users’ personal information only within the scope specified in the purpose of processing and provides personal information to a third party only when the information subject consents or the situation falls under special provisions of the law, and otherwise the Company shall not provide the users’ personal information to a third party.
4. Procedure and Method of Personal Information Destruction
In principle, information shall be destroyed without delay after the purpose of collecting and using personal information is achieved. Destruction procedures and methods are as follows.
5. Consignment of Personal Information Processing
The company entrusts and operates your personal information to an external professional company to provide services and stipulates necessary matters for the safe management of personal information during consignment contracts in accordance with the relevant statutes. The details of the company’s personal information consignment processing agency and consignment work are as follows.
Consignee | Details of consignment | Personal Information Retentionand Utilization Period |
| Amazon Web Service | System development, operation, and data storage for service offer | Until membership withdrawalor termination of consignment contract |
The Company establishes stipulating matters necessary for safe management of personal information when entering into a consignment contract and supervises whether the consignee handles personal information safely.If the information of the entrusted business or the consignee is changed, the Company will disclose it through this Privacy Policy without delay.
6. Right of User and Legal Representative and Right Exercise
Service users can exercise the right to the Company at any time, such as viewing, correcting, deleting, or requesting suspension of processing of personal information. Right can be exercised through a legal representative or a delegated proxy by submitting the document of delegation, Annex “the Enforcement Regulation of Personal Information Protection.” The Inspection Request team for personal information will provide the form of the document of delegation upon the form request.
1. You can exercise your rights regarding personal information by sending a document or e-mail, or via fax, etc. in accordance with the relevant laws and regulations, and the Company will take action without delay.
- Rights can also be exercised through an agent, such as the user’s legal representative or a person authorized to do so. In this case, you must submit a power of attorney in accordance with the “Notice on Personal Information Processing Methods.”
- The user’s right to request access to and suspension of processing of personal information may be restricted in accordance with relevant laws and regulations.
- Requests for correction or deletion of personal information cannot be requested if the personal information is specified as the subject of collection in other laws and regulations.
- The Company shall verify the identity of the user or their representative when they request access, correction, deletion, suspension of treatment based on the rights of the user.
- Users can access, view, modify, or delete their own personal information at any time via [My Page].
- If the user no longer intends to use the Company’s services, he/she can terminate the service agreement through [Membership withdrawal].
7. Matters concerning the installation, operation, and refusal of automatic personal information collection devices
A. Guides on the use of Cookie for membership.
- What is a cookie?
The Company uses and saves cookies in the member authentication section where you log in to provide a customized service for you. Cookies are text files that are automatically generated in your web browser when you access the website. This cookie will be automatically deleted when you log out (Log-out) and close your web browser. - Purpose of use
Cookies store and utilize your visit and usage behavior of the Thinkfree services and websites, IP address, browser type, connection server, server location, and response to certain ads. When a customized service is provided, the user’s personal information is not provided. - How to Refuse to Save Cookies
Users reserve the right to choose to install cookies. Users can adjust web browser settings to accept or refuse cookies. However, refusing to save cookies may limit the use of some services.
- How to access cookie settings in Internet Explorer
* Tools → Internet Options → Privacy → Advanced → Cookies in Settings - How to access cookie settings in Microsoft Edge
* At the top of the web browser, select [Settings and more] → [Settings] → [Site permissions] → [Cookies and site data] - How to access cookie settings in Chrome
* At the top of the web browser, click on the three dots and [Settings] → [Privacy and security] → [Cookies and other sate data]
- The Company uses Google Analytics, a web analytics service provided by Google LLC (hereinafter referred to as “Google”) to better serve customers. Through this, we analyze how you use the service and identify demand to improve the service and product.
- Google Analytics uses the Cookie key to collect how you use your website.
- Google sends and stores information collected through cookies to Google servers in the United States.
- Google may provide this information to third parties, if required by law, or to third parties that process it on behalf of Google.
- Google does not associate your IP address with any other data it has.
- Unless you specifically refuse to use cookies, you agree to use all information generated through Google Analytics and cookies created during your company’s service use.
- Information on Google’s privacy can be found here.
- If you want to refuse data collection by Google Analytics, you can either set it up on Google’s site or refuse to save cookies via [How to Refuse to Save Cookies] above. However, please note that refusing to save cookies may limit the use of some services that require login, and that you are solely responsible for them.
- Microsoft Edge: [Settings] → [Cookies and site permissions] → [Allow sites to store and read cookie data] uncheck
- Chrome: Select [Settings] → [Privacy & Security] → [Cookies and other site data] → [Block all cookies] at the top of the web browser
- Android: Select [Settings] → [Google] → [Ads] → [Disable Ads Personalization]
- iOS: Select [Settings] → [Privacy & Security] → [Tracking] → [App recommends tracking]
8. Criteria for Determining Additional Use and Provision of Personal Information
Category | Purpose of use | Retention and utilization period |
| For identity proofing infomation(DI) | Identity proofing for account ID and password recovery | Until membership Withdrawal After Identity proofing |
- The company describes separate use and provision without the consent of the information subject.
- Whether the purpose of using and providing personal information is clearly related by checking whether it is related to the first purpose of collection
- In the case of confirming and predicting whether there is predictability of additional provision when considering the circumstances in which personal information was collected or applied to the processing measures
- Where the provision of additional use of personal information does not enable the information subject to enjoy the benefits by checking whether the provision of additional use of personal information can enable the information subject’s property
- In the case of taking necessary measures for parts such as pseudonymization or plug-ins
9. Matters Concerning Anonymized Information Processing
Category | Purpose of use | Purpose of item | Retention and utilization period |
| Usage statistics | Improve the performance and functionality of the Service | Statistics such as usage time and services to improve the performance and function of service | Until analysis of combined statistical data is completed or membership withdrawal |
10. Customer Service Regarding Personal Information
- Name: Park Jihoon
- Affiliated and Position: Division Manager / Strategic Growth Division
- Name: Park Jihoon
- Affiliated and Position: Division Manager / Strategic Growth Division
- Email: [email protected]
- Phone number: 1566-5192
- Personal Information Dispute Mediation Committee (http://kopico.go.kr/ (82)1833-6972)
- Personal Information Infringement Reporting Center (http://privacy.kisa.or.kr/ (82)118)
- Cyber Investigation Department of the Supreme Prosecutors’ Office (http://www.spo.go.kr/ (82)1301)
- Cyber Investigation Bureau of National Police Agency (https://ecrm.cyber.go.kr/ (82)182 caller-paid)