PRIVACY POLICY HIGHLIGHTS

Version 1

Introduction

PowApp ("Company", “we”, “our”, or “us”) Seoul, Republic of Korea respects your concerns about privacy. This Privacy Policy applies to the personal information we collect online through our AI based social network service PoW ("Service") and is incorporated into and is subject to our Terms of Service which can be found at which can be found here. Please find below a summary of the key topics addressed in this Privacy Policy. For more detailed information on how we process your information, please click on the headings or continue to read below. Your use of the Service signifies that you agree with the terms of this Privacy Policy. If you do not agree with the terms of this Privacy Policy, you may not use the Service and must immediately terminate your use of the Service.

Note that the "Supplementary Terms" contain specific additional regulations for certain jurisdictions such as Singapore.

PRIVACY POLICY

Effective Date: January 1, 2022

Personal Information We Collect

When we refer to “personal information” in this Privacy Policy, we mean information that relates to an identifiable individual. The following types of personal information are collected in connection with our Service:

Information You Provide Directly to Us or Third Parties

We may collect information directly from you or from other companies with whom you have a relationship. For example:

When you create an account and register for or use our Service, you will provide us with information such as, email address, job title, company name, nickname/alias
When you login with a third-party account, we receive information about you from third parties including from other companies such as Facebook, Apple and Google. For example, we will get access to information such as your Social Network Service (SNS) account information, email address, date of birth, gender (depending on your choices).
When you start using the Service, we will collect user-generated contents, including comments, short messages, that you choose to share, transmit, broadcast and/or upload on our platform.

Information about Your Use of Our Service

In addition to the information you provide, we will collect information about your use of our Service through software on your devices and by other electronic means, including by the use of cookies. This includes:

Device information: OS platform of your device, device information including type of device, brand, model and version of OS, IP address, advertising identifier, device language, device time zone, version of application that you are using, locale country and language of the device, the location (country and city) where you log in, your purchase history in application store, available languages, device capability, bandwidth, network type, and traffic to and from our websites, error-reporting information, the time the error occurred, the feature being used and the state of the Application when the error occurred.
Log information: Usage information, such as, URL, redirected URL, performance timing, referrer, network type, network info, charge status, ad block info, cookies and access history.
Service usage information: History of service usage, details of your interactions with other users, details of interaction between you and the Service or you and our website, and other information about your use of our Service, such as bookmarks and visit history.
Payment data: We may collect data necessary to process your payment if you make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is stored by Google. You may find their privacy notice link(s) here: https://policies.google.com/privacy.
Application data: If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

Geolocation Information. We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application(s), to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device's settings.
Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's calendar, camera, microphone, social media accounts, and other features. If you wish to change our access or permissions, you may do so in your device's settings.
Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our application(s) you accessed.
Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Links to Other Websites, Devices, Apps and Features

Our Service may enable you to connect to other websites, devices, apps and other features, which may operate independently from us and have their own privacy notices or policies. If you accessed a website, product or service provided by a third party, including through the Service or Company's website, such third party may also collect information about you. Please see the privacy policies of each such third party for more information about how they use the information they collect. This Privacy Policy does not apply to any exchange of information between you and any third party.

How We Use this Information

Provision of our Service based on your contractual relationship with us

We process your personal information when this is necessary under our contract with you, to:

Provide you with our Service, and specific features you select when using our Service, which may require personalizing the content of our Service;
Identify and authenticate you so that you may use our Service and to prevent illegal or inappropriate use of the Service;
Restrict the collection of personal information of children under certain age as defined in this Privacy Policy;
Deliver to you any administrative notices, alerts and communications relevant to your use of the Service;
Effectively manage our relationship with our customers, including by communicating with you, responding to your queries, resolving technical issues, providing you with customer care support and sending you necessary information relating to our Services

Use of information for further purpose (Information can be processed by AI systems)

To improve the Service, and to develop and offer new services;
To provide information about various events and opportunities to participate in the events, to provide advertising information;
To contact you via email or otherwise for the purpose of informing you about new products, services or promotions offered by the Company (you can opt-out of such emails by sending an email to help@thepowapp.com);
To collect statistics on the use of Service including Service usage history, access frequency and interaction between users, to analyze customer behaviors, build up customer usage patterns and profiles in order to identify regional and global user trends and optimize our offering to customers globally and to improve the Service and its environments using the statistics;
To protect against, identify, monitor and prevent fraud and other criminal activities, any other activities that may violate our Terms of Service or other applicable laws, or lead to claims or other liabilities.
To restrict use of Service that violates laws and our Terms of Service, to prevent use of Service that interfere with the operation of the Service, including fraudulent use, and to prevent account theft.

Other

Comply with and enforce requirements under applicable laws, relevant industry standards and our policies, including this Privacy Policy.
Comply with court orders and subpoenas, and respond to legally binding requests from government, law enforcement agencies, public authorities and/or regulators.
Protect our legal rights, including by handling complaints, obtaining legal advice and establishing, exercising or defending legal claims relating to us or other companies in our group and our Service;

Sharing of Information

We transfer or disclose your personal information to third parties as described below:

Affiliates, subsidiaries and personnel: We share your information with our personnel, including contractors and agents, and other companies in our group, to the extent this is necessary to provide our Service and to fulfil the purposes set out in Section 2 above.
Service providers: We also transfer or disclose your information to carefully selected companies that provide services on our behalf; for example companies that help us develop and operate systems for our Service, providers of IT services, security, hosting, analytics, mailing, billing or marketing services. These entities are only authorized to access and use your personal information to the extent this is necessary for them to provide us with their services and they are not allowed to use this information for other purposes.
Business advisors: We may share, for example, your information with our lawyers, accountants, business consultants, insurers, and auditors, to the extent it is necessary for them to provide us with their services.
Government authorities, judicial authorities, regulators or other third parties where required: We will disclose personal information to government authorities, judicial authorities, regulators or other third parties where we have a legal requirement to do so or where we believe this is necessary:

to comply with the law or respond to compulsory legal processes (such as a search warrant, subpoena or court order);
to verify or enforce compliance with the terms and policies governing our Service and to investigate fraud or other unlawful activity relating to the use of our Service or affecting our business, to the extent such disclosure is permitted by applicable data protection laws; and
to protect and defend our rights, property, and the security or safety of our business operations and those of any of our respective affiliates, staff, business partners, our customers or members of the public.

Corporate transactions: We may disclose your information to a third party (and their business advisors) in connection with any reorganization, restructuring, merger, acquisition or sale (including in the context of negotiations), dissolution, other transfer of assets, or in the event of a bankruptcy.
Other parties with your consent or on your request. In addition to the disclosures described in this Privacy Policy, we may share information about you with third parties when you separately consent to or request such sharing.
Offer wall. Our application(s) may display a third-party hosted "offer wall." Such an offer wall allows third-party advertisers to offer virtual currency, gifts, or other items to users in return for the acceptance and completion of an advertisement offer. Such an offer wall may appear in our application(s) and be displayed to you based on certain data, such as your geographic area or demographic information. When you click on an offer wall, you will be brought to an external website belonging to other persons and will leave our application(s). A unique identifier, such as your user ID, will be shared with the offer wall provider in order to prevent fraud and properly credit your account with the relevant reward.

We are not responsible for the safety of any information that you share with third parties that we may link to or who advertise on our Services, but are not affiliated with, our Services.

The Services, including our offer wall, may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. The inclusion of a link towards a third-party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy notice. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.

Any information or content that you voluntarily disclose for posting to the Service ("User Contents") may become available to the public. Once you have shared User Contents or made it public, that User Contents may be re-shared by others. This Privacy Policy does not apply to such public information.

Retention of Personal Information

We take appropriate steps to ensure that we process and retain information in accordance with the following principles:

at least for the duration for which the information is used to provide you with our Service;
as required under law, a contract, or with regard to our statutory obligations (e.g., tax laws); or
only for as long as it is necessary for the purpose for which it was collected, is processed, or longer if required under any contract, by applicable law, or, in anonymized form, for statistical purposes, subject to appropriate safeguards. For example, if a dispute arises between you and Company or you fail to make payment for our Service, we may retain relevant information until such dispute is resolved or until such payment is made, respectively.
Where we process your information with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of your requests in order to respect them in future.

Please note that if you unsubscribe from our marketing communications, we will still send you service messages to provide you with necessary information in relation to your contract and the Service you use (for example, to update you on changes to our Terms of Use).

Your Choices

Where permitted we may contact you via email, phone call, text messages or push notifications through our mobile apps. To submit a request concerning the receipt of such communications from us, please contact us using the information specified in the “Contact Us” Section below.

You can unsubscribe from our marketing communications at any time by contacting us directly (see “Contact Us” section below). As noted in the Your Rights section below, you have the right to object to use of personal data for direct marketing purposes at any time.

Your Rights

To the extent provided by applicable law, you can request access to your personal information, or correct or update out-of-date or inaccurate personal information we hold about you. You may also have the right to request that we delete personal information that we hold about you. You may access and update some of your information through your account settings. You are responsible for keeping your personal information up-to-date.

To the extent provided by applicable laws, you can also ask us to restrict or limit the processing of your personal information, as well as to provide you with personal information that we have collected from you so that you may use it for your own purposes, and to ask us to share (port) this data to another controller.

In addition, to the extent provided by applicable law, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement).

You also may have the right under applicable law to object at any time to the use of your personal information for direct marketing purposes, including profiling relating to direct marketing.

However, these rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. We will inform you of relevant exemptions we rely upon when responding to any request you make. To make a request concerning your rights or to make an inquiry, use the contact details under the “Contact Us” section below.

How We Protect Personal Information

We take the protection of your information seriously and we have in place safeguards designed to protect the information we collect through our Service. However, please note that although we take reasonable steps to protect your information, no website, Internet transmission, computer system, or wireless connection is completely secure.

Please note, however, that the Service allows you to share text messages and other communications in the Service with other users, and if you choose to share these items with other Service users, we may not be able to remove them from our servers or make them unavailable to anyone you have shared them with. Sending and sharing text messages or other communications in the Service is your decision. By choosing to share that information, you should understand that you may no longer be able to control how that information is used and that it may become publicly available (depending in part on your actions or the actions of others with whom you have shared the information). The Service is not responsible for any use or misuse of information you share.

Personal Information of Children

The Service is not directed to children under the age of eighteen (18) and we do not knowingly solicit or collect personally identifiable information from children under the age of eighteen (18) as part of the Service. Additionally, we do not knowingly sell the personal information of children under the age of eighteen (18). If we become aware that we have inadvertently received personally identifiable information from a user under the age of eighteen (18) as part of the Service, we will immediately delete such information from our records. If you believe that a child under the age of eighteen (18) may have provided us with personal information, please contact us using the information specified in the “Contact Us” section below.

Contact Us

For more information about our privacy practices, or to exercise any rights you may have pursuant to applicable law, please contact us at help@thepowapp.com. In addition, our Data Protection Officer can be contacted DPO@thepowapp.com.

Updates to Our Privacy Policy

We reserve the right at our discretion to make changes to this Privacy Policy from time to time. We will notify you before we make changes to this Privacy Policy. You may also review updates to our Privacy Policy at any time via links on our website. You agree to accept electronic communications and/or postings of a revised Privacy Policy on the Service and our website, and you agree that such electronic communications or postings constitute notice to you of the Privacy Policy.

If we make material changes to this policy, we will notify you by publishing a revised Privacy Policy or by means of a notice on our website, or as required by law. You agree that your continued use of the Service after we publish a revised Privacy Policy or provide a notice on our website constitutes your acceptance of the revised Privacy Policy. If you do not agree with the terms of the Privacy Policy, you may not use the Service at any time.

Our platform is committed to protecting your privacy and personal information. The information provided on this platform, including any language model used by the platform, is for reference purposes only and should not be construed as legal, financial, or professional advice. We make no representations or warranties of any kind and shall not be liable for any damages arising from the use of or reliance on any information provided.

By using this platform, including any language model used by the platform, you consent to the collection, use, and disclosure of your personal information as outlined in our privacy policy. We collect personal information when you provide it to us, such as your name, email address, and other contact information. We use this information to provide you with the products or services you have requested, to communicate with you, and to improve our products and services.

We may also collect non-personal information such as your IP address, browser type, and operating system for analytical purposes. We do not sell or rent your personal information to third parties. However, we may share your information with trusted third-party service providers who help us provide our products and services.

We take reasonable measures to protect your personal information from unauthorized access, disclosure, or use. However, we cannot guarantee the security of your information transmitted over the internet.

By using our products or services, you agree to our privacy policy and consent to the collection, use, and disclosure of your personal information as outlined in this policy. We reserve the right to modify or update this policy at any time without prior notice.

If you have any questions or concerns about our privacy policy or the use of the platform, including any language model used by the platform, please contact us at help@thepowapp.com.

Supplementary Terms

The following additional terms apply respectively to users having residence in or nationality of certain countries. In the event of any conflict between the following additional terms and the provisions of the main body of this Privacy Policy, the following terms shall prevail.

For Singapore

This section supplements this Privacy Policy and applies solely to any collection, use and disclosure of personal information to which the Singapore Personal Data Protection Act (No. 26 of 2012) applies:

The first sentence of Section 1 of the Privacy Policy shall be deleted and replaced with: "When we refer to "personal information" in this Privacy Policy, we mean data, whether true or not, about an individual who can be identified from that data alone or with other information which we have or are likely to have access to".