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Privacy Processing Policy of molim Inc.

molim Inc. (hereinafter, the “Company”) establishes and discloses the following Privacy Processing Policy in accordance with Article 30 of the Personal Information Protection Act, to protect the personal information of data subjects and to ensure that related grievances are handled swiftly and appropriately.


Article 1 (Purposes of Processing Personal Information)
The Company processes personal information for the following purposes. Personal information collected for these purposes will not be used for any other purposes, and if the purpose of use changes, the Company will obtain separate consent in accordance with Article 18 of the Personal Information Protection Act and take other required measures.

  1. Website Membership Registration and Management

    • To confirm intent to register, provide member services, identify and authenticate members, maintain and manage membership, implement limited identity verification, prevent fraudulent use of services, verify guardian consent for users under age 14, issue notices and announcements, and handle grievances.

  2. Provision of Goods or Services

    • To deliver goods, provide services, issue contracts and invoices, supply content, offer customized services, perform identity and age verification, settle payments and billing, and collect receivables.

  3. Grievance Handling

    • To verify the identity of complainants, review grievance details, contact for fact-finding, and notify complainants of outcomes.

Article 2 (Retention and Use Period of Personal Information)

  1. The Company processes and retains personal information within the period required by law or the period agreed upon by the data subject at the time of collection.

  2. The specific retention periods are as follows:

    1. Website Membership Registration and Management: Until membership withdrawal.

      • Exception: If an investigation under applicable law is in progress, until the conclusion of such investigation.

      • Exception: If there remain outstanding claims or obligations related to site use, until settlement.

    2. Provision of Goods or Services: Until delivery of goods or completion of service and payment settlement.

      • Exception: Under the Consumer Protection in Electronic Commerce Act, records of transactions must be kept as follows:

        • Records of advertisements: 6 months

        • Records of contracts, payment, and supply of goods: 5 years

        • Records of consumer complaints and dispute handling: 3 years

      • Exception: Under the Communications Privacy Protection Act, logs must be kept as follows:

        • Subscriber telecommunication date/time, start/end times, counterpart subscriber numbers, usage frequency, base station location data: 1 year

        • Computer communication and internet log data, access trace data: 3 months

Article 3 (Provision of Personal Information to Third Parties)

  1. The Company processes personal information only within the purposes set forth in Article 1. Personal information will not be provided to third parties except with the data subject’s consent, under statutory provisions, or otherwise in accordance with Articles 17 and 18 of the Personal Information Protection Act.

  2. Where necessary for smooth service provision, the Company may provide the minimum required personal information to third parties with the data subject’s consent under Article 17 1 of the Personal Information Protection Act. The details are as follows:

    • Recipient: (e.g.) OOO Card Co., Ltd.

    • Purpose: Joint event hosting, affiliate credit card issuance

    • Items Provided: Name, address, telephone number, email address, payment account details

    • Retention Period by Recipient: Duration of credit card contract

Article 4 (Outsourcing of Personal Information Processing)

  1. To ensure efficient handling of personal information, the Company outsources the following tasks:

    • Service Host & Marketing: I’mWeb Co., Ltd. – hosting, mobile app, marketing, notifications

    • Payment & Escrow: OOO PG – payment and escrow services

    • Delivery: OOO Courier – logistics and delivery

    • Customer Support: OOO Customer Center – customer inquiry handling

    • Identity Verification: OOO Verification Co.

    • Re-outsourcing:

      • I’mWeb Co., Ltd. → Infobip Ltd.: SMS and KakaoTalk notification dispatch

      • I’mWeb Co., Ltd. → LunaSoft Co.: SMS, KakaoTalk notification, and friend-talk dispatch

  2. The Company ensures that each outsourcing contract stipulates, in accordance with Article 25 of the Personal Information Protection Act, limitations on use, technical and managerial protections, restrictions on re-outsourcing, supervision of service providers, and liability for damages. The Company supervises outsourced parties to ensure safe handling of personal information.

  3. Any changes to outsourcing tasks or service providers will be promptly published in this Privacy Processing Policy.

Article 5 (Rights of Data Subjects and Exercise Methods)

  1. Data subjects may exercise the following rights at any time by submitting a request to the Company:

    1. Request access to their personal information

    2. Request correction of errors

    3. Request deletion of information

    4. Request suspension of processing

  2. Requests may be made in writing, by telephone, email, or fax; the Company will act promptly.

  3. If correction or deletion is requested, the Company will not use or provide the relevant personal information until the request is fulfilled.

  4. Rights may be exercised by a legal representative or an authorized agent, upon submission of a power of attorney in the prescribed form.

  5. Data subjects must not infringe the privacy of themselves or others when exercising their rights.

Article 6 (Categories of Processed Personal Information)
The Company processes the following personal information:

  1. Website Membership Registration and Management

    • Required: Name, date of birth, ID, password, address, phone number, gender, email address, i-PIN number

    • Optional: Marital status, interests

  2. Provision of Goods or Services

    • Required: Name, date of birth, ID, password, address, phone number, email address, i-PIN number, credit card number, bank account details

    • Optional: Purchase history, interests

Article 7 (Destruction of Personal Information)

  1. When the retention period expires or the processing purpose is achieved, the Company destroys the personal information without delay.

  2. If the information must be retained under other laws despite the lapse of retention period or achievement of purpose, it is moved to a separate database and stored securely.

  3. Destruction procedures and methods:

    1. Procedure: Identify data to be destroyed, obtain approval from the Company’s privacy officer, and carry out destruction.

    2. Method: Electronic data is irreversibly deleted; paper records are shredded or incinerated.

Article 8 (Measures to Ensure Security of Personal Information)
The Company implements the following measures to secure personal information:

  1. Administrative: Internal management plans, periodic employee training

  2. Technical: Access control systems, encryption of unique identifiers, installation of security software

  3. Physical: Access controls for data centers and storage rooms

Article 9 (Installation and Operation of Automatic Collection Devices, and Refusal Rights)

  1. The Company uses “cookies” to store and retrieve user information for personalized services.

  2. Cookies are small pieces of data sent by the web server to the user’s browser and stored on the user’s device.

  3. Users can configure their browsers to allow or block cookies; blocking cookies may impair personalized services.

    • Browser Settings:

      • Chrome: Settings > Privacy and security > Clear browsing data

      • Edge: Settings > Cookies and site permissions > Manage and delete cookies

    • Mobile Settings:

      • Chrome (mobile): Settings > Privacy and security > Clear browsing data

      • Safari (mobile): Settings > Safari > Advanced > Block all cookies

      • Samsung Internet: Settings > Clear browsing data

  4. The Company collects usage data (visited services, popular searches, secure connections, etc.) to optimize information delivery.

Article 10 (Person Responsible for Personal Information Protection)

  1. The Company designates the following personal information protection officer to oversee processing and handle related complaints:

    • Officer: Hyunsoo Park, CEO

      • Phone: +82-31-711-2806

      • Email: contact@molim.xyz

    • Privacy Team: Support Team

      • Phone: +82-31-711-2806

      • Email: contact@molim.xyz

  2. Data subjects may direct any privacy inquiries or complaints to the officer or Support Team; the Company will respond promptly.

Article 11 (Requests for Access to Personal Information)
Data subjects may submit access requests under Article 35 of the Personal Information Protection Act to:

  • Support Team (Phone: +82-31-711-2806, Email: contact@molim.xyz)

Article 12 (Remedies for Rights Violations)
Data subjects may contact the following bodies for remedies:

  1. Personal Information Dispute Mediation Committee: 1833-6972 (www.kopico.go.kr)

  2. Personal Information Infringement Report Center: 118 (privacy.kisa.or.kr)

  3. Supreme Prosecutors’ Office: 1301 (www.spo.go.kr)

  4. National Police Agency: 182 (ecrm.police.go.kr/minwon/main)

Article 13 (Effective Date and Revisions)
This Privacy Processing Policy takes effect on April 1, 2022, and will be revised as necessary.