Privacy Policy

K-friends Privacy Policy

  • Last Updated: September 21, 2020

TABLE OF CONTENTS:

  1. 1. INTRODUCTION
  2. 2. INFORMATION WE COLLECT
  3. 3. HOW WE USE THE INFORMATION WE COLLECT
  4. 4. SHARING & DISCLOSURE
  5. 5. OTHER IMPORTANT INFORMATION
  6. 6. YOUR RIGHTS
  7. 7. OPERATING GLOBALLY & INTERNATIONAL TRANSFERS
  8. 8. SECURITY
  9. 9. CHANGES TO THIS PRIVACY POLICY
  10. 10. CONTACT US
  1. 1. INTRODUCTION

    Thank you for using K-friends! Your trust is important to us and we’re committed to protecting the privacy and security of your personal information. The information that’s shared with us helps us to provide a great experience with K-friends. We have a dedicated privacy team that’s committed to protecting all the personal information we collect and help ensure that personal information is handled properly worldwide.

    This Privacy Policy describes how we collect, use, process, and disclose your personal information, in conjunction with your access to and use of the K-friends. This privacy policy describes our privacy practices for K-friends website and services.

    Note that other Korean Tourism Organization websites (webpages) or mobile applications may be governed by other privacy policies.

    1. 1.1 Definitions

      If you see an undefined term in this Privacy Policy (such as “K-friends Platform”), it has the same definition as in our Terms of Service (“Terms”)

    2. 1.2 Data Controller

      When this policy mentions “K-friends,” “we,” “us,” or “our,” it refers to the Korea Tourism Organization that is responsible for your information under this Privacy Policy (the “Data Controller”). The Data Controller, regardless of your country of residence, is the Korea Tourism Organization.

  2. 2. INFORMATION WE COLLECT

    There are three general categories of information we collect.

    1. 2.1 Information You Give to Us.

      1. 2.1.1 Information that is necessary for the use of the K-friends.

        We ask for and collect the following personal information about you when you use the K-friends. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested services.

        • Account Information. When you sign up for a K-friends Account, we require certain information such as your first name, last name, email address, date of birth, mobile and stationary phone numbers, your country and region of residence, and preferred language(s), and your home address.

          We require this information to enable use of certain features of the K-friends Platform (such as supporting a certain channel, participating in events and receiving gifts) and to process shipment of gifts and prizes.

        • Communications with K-friends. When you communicate with K-friends Platform (such as using K-friends Chatbot or 1:1 Inquiries), we collect information about your communication and any information you choose to provide.

      2. 2.1.2 Information you choose to give us.

        You may choose to provide us with additional personal information in order to obtain a better user experience when using K-friends. This additional information will be processed based on our legitimate interest or when applicable, your consent.

        • Additional Information. You may choose to provide us information when you fill in a form, update or add information to your K-friends Account, respond to surveys, participate in promotions, communicate with our customer care team, share your experience with us (such as through 1:1 Inquiries), or use other features of the K-friends Platform.

      3. 2.1.3 Information We Automatically Collect from Your Use of the K-friends Platform.

        When you use the K-friends Platform, we automatically collect personal information about the services you use and how you use them. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of the K-friends Platform.

        • Geo-location Information. When you use certain features of the K-friends Platform, we may collect information about your precise or approximate location as determined through data such as your IP address or mobile device’s GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu. K-friends may also collect this information even when you are not using the app if this connection is enabled through your settings or device permissions.

        • Usage Information. We collect information about your interactions with the K-friends Platform such as the pages or content you view, your searches for events, and other actions on the K-friends Platform.

        • Log Data and Device Information. We automatically collect log data and device information when you access and use the K-friends Platform, even if you have not created a K-friends Account or logged in. That information includes, among other things: details about how you’ve used the K-friends Platform (including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the K-friends Platform.

        • Cookies and Similar Technologies. We use cookies and other similar technologies when you use our platform, use our mobile app, or engage with our links or email communications. We may collect certain information by automated means using technologies such as cookies, web beacons, pixels, browser analysis tools, server logs, and mobile identifiers. In many cases the information we collect using cookies and other tools is only used in a non-identifiable manner without reference to personal information. For example, we may use information we collect to better understand website traffic patterns and to optimize our website experience. In some cases, we associate the information we collect using cookies and other technology with your personal information. Our business partners may also use these tracking technologies on the K-friends Platform or engage others to track your behavior on our behalf.

      4. 2.1.4 Information We Collect from Third Parties.

        Korea Tourism Organization and K-friends may collect information, including personal information, that others provide about you when they use the K-friends Platform, or obtain information from other sources and combine that with information we collect through the K-friends Platform. We do not control, supervise or respond to how the third parties providing your information process your Personal Information, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.

        • Third Party Services. If you link, connect, or login to your K-friends Account with a third party service (e.g. Google, Facebook, WeChat), the third party service may send us information such as your registration, friends list, and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.

        • Referrals. If you are invited to K-friends, the person who invited you may submit personal information about you such as your email address or other contact information.

    2. 2.2 Children’s Data.

      Our websites and applications are not directed to children under 16 and we do not knowingly collect any personal information directly from children under 16. If you believe that we are processing the personal information pertaining to a child inappropriately, we take this very seriously and urge you to contact us using the information provided under the “Contact Us” section below.

  3. 3. HOW WE USE INFORMATION WE COLLECT

    We may use, store, and process personal information to (1) provide, understand, improve, and develop the K-friends Platform, (2) create and maintain a trusted and safer environment (such as to comply with our legal obligations and ensure compliance with K-friends Policies) and (3) provide, personalize, measure, and improve our marketing.

    1. 3.1 Provide, Improve, and Develop the K-friends Platform.

      We may use the personal information to provide, improve, and develop the K-friends Platform such as to:

        • enable you to access and use the K-friends Platform,

        • operate, protect, improve, and optimize the K-friends Platform and experience, such as by performing analytics and conducting research,

        • provide customer service,

        • send you service or support messages, updates, security alerts, and account notifications,

        • if you provide us with your contacts’ information, we may process this information: (i) to facilitate your referral invitations, (ii) send your requests for references, (iii) for fraud detection and prevention, and (iv) for any purpose you authorize at the time of collection,

        We process this personal information for these purposes given our legitimate interest in improving the K-friends Platform and our Users’ experience with it, and where it is necessary for the adequate performance of the contract with you.

    2. 3.2 Create and Maintain a Trusted and Safer Environment.

      We may use the personal information to create and maintain a trusted and safer environment such as to:

        • detect and prevent fraud, spam, abuse, security incidents, and other harmful activity,

        • comply with our legal obligations,

        • Resolve any disputes with any of our Users and enforce our agreements with third parties, and

        • enforce our Terms of Service and other policies.

        We process this personal information for these purposes given our legitimate interest in protecting the K-friends Platform, to measure the adequate performance of our contract with you, and to comply with applicable laws.

    3. 3.3 Provide, Personalize, Measure, and Improve our Marketing.

      We may use the personal information to provide, personalize, measure, and improve our marketing such as to:

        • send you promotional messages, marketing, and other information that may be of interest to you based on your preferences (including information about K-friends or partner campaigns and services),

        • Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Korea Tourism Organization, K-friends or its third party partners,

        • conduct profiling on your characteristics and preferences (based on the information you provide to us, your interactions with the K-friends Platform, information obtained from third parties, and your search history) to send you promotional messages, marketing, and other information that we think may be of interest to you,

        • enrolling in an email subscription will not affect the frequency of administrative emails that we may send in connection with any K-friends Account. No fee is charged for sending promotional emails to you, but third-party data rates may apply. Note that you may not be able to take advantage of certain promotions if you do not have a K-friends Account, and

        • invite you to events and relevant opportunities (for example, when you achieve a certain rank on the K-friends Platform, we may use the information provided to reach out to you to invite you to relevant events).

        We will process your personal information for the purposes listed in this section given our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest.

    4. 3.4 Your Choices

      You have choices on the promotional messages that you choose to receive.

        • You can limit the information you provide to K-friends. Participation in promotions and marketing programs is voluntary.

        • You can limit the communications that K-friends sends to you.

          • To opt-out of marketing emails, simply click the link labeled “unsubscribe” at the bottom of any marketing email we send you or access the notification settings in your K-friends Account.

          • You can always update your notification settings within your K-friends Account by visiting the Notifications section of your K-friends Account. Please note that even if you opt-out of marketing communications, we may still need to contact you with important information about your account. For example, even if you opt-out of emails, we may still send you activity confirmations or fraud alerts.

  4. 4. SHARING & DISCLOSURE

    1. 4.1 Social Media

      Where you have provided consent, we share your information, including personal information, as described at the time of consent, such as when you participate in promotional activities conducted by K-friends partners or third parties.

      The social media platforms with which we may share your personal information are not controlled or supervised by K-friends. Therefore, any questions regarding how your social media platform service provider processes your personal information should be directed to such a provider.

      Please note that you may, at any time, ask K-friends to cease processing your data for these direct marketing purposes by sending an e-mail to daninha@knto.or.kr.

    2. 4.2 Public Information.

      The K-friends Platform lets you publish information, including personal information, that may be visible to other users, such as your name and account ID. They will be publicly visible to others in the prize winners announcement, in case you have participated in the event conducted by K-friends or its third party partners and were chosen as a prize winner.

    3. 4.3 Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of Our Rights.

      K-friends may disclose your information, including personal information, to courts, law enforcement, governmental authorities, tax authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with a valid legal request or to respond to claims asserted against Korea Tourism Organization, (iii) to respond to a valid legal request relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability (See more information on Korea Tourism Organization’s Law Enforcement Guidelines here), (iv) to enforce and administer our Terms of Service or other agreements with Users, or (v) to protect the rights, property or personal safety of Korea Tourism Organization, its employees, its Users, or members of the public. For example, if permitted due to the forgoing circumstances, tax information may be shared with tax authorities or other governmental agencies.

      These disclosures may be necessary to comply with our legal obligations, for the protection of your or another person's vital interests or for the purposes of our or a third party’s legitimate interest in keeping the K-friends Platform secure, preventing harm or crime, enforcing or defending legal rights, facilitating the collection of taxes and prevention of tax fraud or preventing damage.

      Where appropriate, we may notify Members about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon Korea Tourism Organization’s property, its Users and the K-friends Platform. In instances where we comply with legal requests without notice for these reasons, we may attempt to notify that User about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.

    4. 4.4 Service Providers.

      K-friends uses a variety of third-party service providers to help us provide services related to the K-friends Platform. Service providers may be located inside or outside of the European Economic Area (“EEA”). In particular, our service providers are based in Europe, India, Asia Pacific and North and South America.

      For example, service providers may help us: (i) perform product development, maintenance and debugging, (ii) allow the provision of the K-friends Services through third party platforms and software tools (e.g. through the integration with APIs), (iii) provide customer service, or (iv) process, handle and provide shipment services (such as gifts and prizes). These providers have limited access to your personal information to perform these tasks on our behalf, and are contractually bound to protect the personal information and only use the personal information in accordance with our instructions.

      K-friends will need to share your information, including personal information, in order to ensure the adequate performance of our contract with you.

    5. 4.5 Aggregated Data.

      We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, research, demographic profiling, marketing and advertising, and other business purposes.

  5. 5. OTHER IMPORTANT INFORMATION

    1. 5.1 Analyzing your Communications.

      We may review, scan, or analyze your communications on the K-friends Platform for fraud prevention, product development, research, analytics, and customer support purposes. In some cases, we may also scan, review, or analyze messages to debug, improve, and expand product offerings. We will not review, scan, or analyze your messaging communications to send third party marketing messages to you, and we will not sell reviews or analyses of these communications.

      These activities are carried out based on K-friends' legitimate interest in ensuring compliance with applicable laws and our Terms, preventing fraud, promoting safety, and improving and ensuring the adequate performance of our services.

    2. 5.2 Linking Third Party Accounts.

      You may link your K-friends Account with your account at a third party social networking service. Your contacts on these third party services are referred to as “Friends.” When you create this link:

      • some of the information you provide to us from the linking of your accounts may be published on your K-friends Account profile;

      • your activities on the K-friends Platform may be displayed to your Friends on the K-friends Platform and/or that third party site;

      • a link to your public profile on that third party social networking service may be included in your K-friends public profile;

      • other K-friends users may be able to see any common Friends that you may have with them, or that you are a Friend of their Friend if applicable;

      • other K-friends users may be able to see any regions, hometowns or other groups you have in common with them as listed on your linked social networking service;

      • the information you provide to us from the linking of your accounts may be stored, processed and transmitted for fraud prevention and risk assessment purposes; and

      • the publication and display of information that you provide to K-friends through this linkage is subject to your settings and authorizations on the K-friends Platform and the third party site.

      We only collect your information from linked third party accounts to the extent necessary to ensure the adequate performance of our contract with you, or to ensure that we comply with applicable laws, or with your consent.

    3. 5.3 Third Party Partners & Integrations

      The K-friends Platform may contain links to third party websites or services, such as third party integrations, co-branded services, or third party-branded services (“Third Party Partners”). K-friends doesn’t own or control these Third Party Partners and when you interact with them, you may be providing information directly to the Third Party Partner, K-friends, or both. These Third Party Partners will have their own rules about the collection, use, and disclosure of information. We encourage you to review the privacy policies of the other websites you visit.

  6. 6. YOUR RIGHTS

    Consistent with applicable law, you may exercise any of the rights described in this section before Data Controller. Please note that we may ask you to verify your identity and request before taking further action on your request.

    1. 6.1 Managing Your Information.

      You may access and update some of your information through your Account settings. If you have chosen to connect your K-friends Account to a third-party application, like Facebook or Weibo, you can change your settings and remove permission for the app by changing your Account settings. You are responsible for keeping your personal information up-to-date.

    2. 6.2 Rectification of Inaccurate or Incomplete Information.

      You have the right to ask us to correct inaccurate or incomplete personal information about you (and which you cannot update yourself within your K-friends Account).

    3. 6.3 Data Access and Portability.

      In some jurisdictions, applicable law may entitle you to request certain copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).

    4. 6.4 Data Retention and Erasure.

      We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. In certain jurisdictions, you can request to have all your personal information deleted entirely." Please note that if you request the erasure of your personal information:

      • We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend a K-friends Account for fraud or safety reasons, we may retain certain information from that K-friends Account to prevent that User from opening a new K-friends Account in the future.

      • We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, K-friends may keep some of your information for tax, legal reporting and auditing obligations.

      • Personal information (such as your name and ID) may continue to be publicly visible on the K-friends Platform in events winners announcement section, even after your K-friends Account is cancelled. Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.

      • Because we maintain the K-friends Platform to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

    5. 6.5 Withdrawing Consent and Restriction of Processing.

      If we are processing your personal information based on your consent you may withdraw your consent at any time by changing your Account settings or by sending a communication to K-friends specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing pursuant to Section 6.6 and pending the verification whether the legitimate grounds of K-friends override your own.

    6. 6.6 Objection to Processing.

      In some jurisdictions, applicable law may entitle you to require K-friends not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing K-friends will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims.

      Where your personal information is processed for direct marketing purposes, you may, at any time ask K-friends to cease processing your data for these direct marketing purposes by sending an e-mail to daninha@knto.or.kr.

    7. 6.7 Lodging Complaints.

      You have the right to lodge complaints about our data processing activities by filing a complaint with our Data Protection Officer who can be reached by the “Contact Us” section below or with a supervisory authority.

  7. 7. OPERATING GLOBALLY & INTERNATIONAL TRANSFERS

    To facilitate our global operations K-friends may transfer, store, and process your information within KTO and its subsidiaries, affiliates, partners, and service providers based in Europe, India, Asia Pacific and North and South America. Laws in these countries may differ from the laws applicable to your country of residence. For example, information collected within the EEA may be transferred, stored, and processed outside of the EEA for the purposes described in this Privacy Policy. Where we transfer, store, and process your personal information outside of the EEA we have ensured that appropriate safeguards are in place to ensure an adequate level of data protection.

    We do not sell personal information to third parties. We do allow third parties to collect personal information through our Service and share personal information with third parties for the business purposes described in this Privacy Policy, including without limitation advertising and marketing on our Service and elsewhere based on users’ online activities over time and across different sites, services, and devices.

  8. 8. SECURITY

    We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. If you know or have reason to believe that your K-friends Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your K-friends Account, please contact us following the instructions in the Contact Us section below.

  9. 9. CHANGES TO THIS PRIVACY POLICY

    K-friends reserves the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the K-friends Platform and update the “Last Updated” date at the top of this Privacy Policy. We will also provide you with notice of the modification by email at least thirty (30) days before the date they become effective. If you disagree with the revised Privacy Policy, you may delete your Account. If you do not delete your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of the K-friends Platform will be subject to the revised Privacy Policy.

  10. 10. CONTACT US

    If you have any questions or complaints about this Privacy Policy or K-friends’ information handling practices, you may email us at the email addresses provided in the relevant sections above or contact us via mail at:

    • Korea Tourism Organization Headquarters, 10, Segye-ro, Wonju-si, Gangwon-do 26464,

      Korea

    • Data Protection Officer:

      Smart Tourism Department Executive Director

      Name: Park Chul Hyun

    • Data Protection Practitioner:

      Department : Smart Tourism Planning Team

      Name: Kim Dan Ah

      Email: daninha@knto.or.kr

      Tel: +82-33-738-3489

    © 2020 Korea Tourism Organization. All rights reserved.