🔒 Privacy Policy

Article 1 (General Provisions)

This Privacy Policy sets forth how THINKPOL Inc. (hereinafter referred to as "the Company") collects, uses, and handles personal information in connection with the mobile application-based AI Poker Hand Review service (hereinafter referred to as "the Service").

The Company treats users' personal information as important information, manages it appropriately, and complies with the "Act on the Protection of Personal Information" and other related laws and regulations. This policy may be revised due to changes in laws, service content, or operation policies, and in such cases, advance notice will be provided.

Article 2 (Items and Methods of Collecting Personal Information)

① Items of Personal Information Collected

1. Membership Registration and Account Management
   • Required: Email address or social login identifier, nickname
   • Optional: None
2. Information Automatically Collected during Service Use
   • Service usage history
   • Hand review and analysis data
   • Credit usage history
   • Payment and subscription history
   • Access logs, IP address
   • Device information (OS, app version, etc.)
3. Inquiry Handling
   • Required: Email address
   • Optional: Information provided by the user depending on the inquiry content

※ The Company does not collect sensitive personal information such as resident registration numbers, real names, or phone numbers.

② Methods of Collecting Personal Information

• Direct entry by the user during membership registration and service use
• Automatically generated and collected during the service use process
• Voluntarily provided by the user during inquiries

Article 3 (Purpose of Use of Personal Information)

The Company uses collected personal information within the scope of the following purposes:

1. Service Provision and Operation
   • Member management and identity verification
   • Providing AI poker hand reviews and explanations
   • Credit usage and subscription management
2. Service Quality Improvement
   • Analysis of usage status
   • Improvement of AI explanation quality and functions
3. Customer Support
   • Handling inquiries
   • Providing information and notifications regarding the service
4. Legal Compliance
   • Fulfillment of legal obligations such as storage of payment records

Article 4 (Retention and Use Period of Personal Information)

In principle, the Company deletes or destroys personal information without delay once the purpose of collection and use has been achieved. However, it may be stored for the following periods based on relevant laws and regulations.

① Retention Periods Based on Laws

1. Acts related to specified commercial transactions, etc.
   • Records regarding contracts or withdrawal of applications: 5 years
   • Records regarding payments and service provision: 5 years
   • Records regarding complaint and dispute resolution: 3 years
2. Laws related to the secrecy of communications
   • Access logs, etc.: 3 months
3. Personal Information Protection Act
   • Email address and nickname after withdrawal: 30 days (to prevent unauthorized use and respond to disputes)

Article 5 (Provision of Personal Information to Third Parties and Entrustment of Handling)

① Third-Party Provision

The Company, in principle, does not provide users' personal information to third parties, except in the following cases:

• With the user's consent
• When required by laws and regulations

② Entrustment of Handling Personal Information

The Company may entrust the handling of personal information to external businesses for smooth service provision.

Article 6 (Safety Management Measures for Personal Information)

The Company takes the following measures to ensure the safety of personal information:

1. Technical Measures
   • Encrypted storage of personal information and encryption of communications
   • Operation of access control and security systems
2. Organizational Measures
   • Minimization of access authority to personal information
   • Periodic inspection of the internal management system
3. Physical Measures
   • Restricting physical access to servers
   • Preventing unauthorized external access

Article 7 (Personal Information Deletion Procedures and Methods)

1. Deletion Procedures
   • Appropriately deleted in accordance with the Company's internal regulations and relevant laws after the retention period has passed or the purpose of use has been achieved.
2. Deletion Methods
   • Electronic data: Completely deleted using a method that makes restoration impossible
   • Documents: Shredded or incinerated

Article 8 (Rights of Users)

Users have the following rights regarding their own personal information:

1. Request for disclosure, correction, or deletion of personal information
2. Request for suspension of use of personal information
3. Withdrawal of consent for the use of personal information

These requests can be made through the in-app settings or the inquiry window.

Article 9 (Personal Information Protection Officer)

• Personal Information Protection Officer: CTO Hyunbae Lee
• Contact: contact@thinkpol.io

The Company will respond sincerely and promptly to inquiries regarding personal information.

Article 10 (Changes to the Privacy Policy)

This policy may be revised due to legal changes or changes in service content. If there are changes, the Company will notify you at least 7 days in advance within the app or through official announcements.