Article 1 (Overview)
Florix Co,. Ltd. (hereinafter referred to
as the "Company") values the protection of personal information and
the respect for users' rights as its highest priority when providing mobile
games and related services to users worldwide.
The Company complies with the Personal
Information Protection Act of the Republic of Korea, as well as global privacy
regulations including the General Data Protection Regulation (GDPR) of the
European Union, the California Consumer Privacy Act (CCPA), Brazil's General
Data Protection Law (LGPD), Japan's Act on the Protection of Personal
Information (PIPA), Taiwan s Personal Data Protection Act, and applicable
privacy laws in Southeast Asia. Accordingly, the Company takes all necessary
measures to ensure that users' personal data is handled safely and lawfully.
This Privacy Policy clearly explains how
personal information is collected, used, stored, and shared during the use of
the Company s mobile games, websites, customer support, events, and other
services. It also outlines the rights of users and how those rights may be
exercised. Furthermore, it stipulates the Company s commitment to addressing
any concerns or complaints regarding personal data in a timely and appropriate
manner.
This policy may be amended due to changes
in applicable laws, international guidelines, or the Company s internal
policies. Any such changes will be announced through the Company s official
communication channels.
Article 2 (Personal Information
Collected and Collection Methods)
The Company collects only the minimum
necessary personal information required to provide services, fulfill legal
obligations, respond to customer inquiries, prevent misuse, improve content,
and conduct marketing. The types of personal information collected
and methods of collection are as follows:
- Upon account registration and linkage
- [Required] External platform account information: External
platform ID (Google, Apple, Facebook, etc.)
- [Required] Nationality status (used for verifying legal age
and youth protection)
- Automatically collected information during use of game services
- [Required] Game and service usage data: Nickname, download
history, login timestamps and logs, IP address, game version, payment
history, in-game activity logs, records of misuse
- [Required] Device information: Device model name, operating
system (OS), language setting, country information, device identifiers
(e.g., UUID, device ID), advertising identifiers (GAID/IDFA), location
information (country level)
This
information may be automatically collected through the game client or SDK.
- When using customer support services
- [Required] Basic information for inquiry handling: Email
address, game title, game ID, UID, nickname
- [Optional] Additional verification information: Device
information (OS, version, model), payment history, inquiry-related
screenshots and logs
- When requesting a refund or filing a payment-related complaint
- [Required] Identity verification and refund processing: Email
address, game title, game ID, nickname
- [Optional] Documents for verifying minority status or payment
method: Real name, family relationship certificate, mobile carrier
subscription certificate, payment statements, etc.
If needed,
separate notice and consent will be obtained before collection, and the data
will be promptly destroyed after the purpose is fulfilled.
- When participating in marketing, events, or promotions
- [Optional] Information for receiving marketing materials or
prize delivery: Email address, phone number, mailing address (for
SMS/prize delivery)
Marketing
communications and advertisements are sent only to users who have provided
prior consent.
- Methods of collection
- When installing or launching the game app
- When linking or logging in through an external platform
- When submitting a customer support inquiry
- When entering a promotion or event
- Automatically during service usage (SDK, logs, cookies, etc.)
The Company does not collect sensitive
personal information (e.g., race, religion, health information) without
explicit user consent. The collected data will not be used beyond the purposes
specified.
Article 3 (Purpose of Using Personal
Information)
The Company uses the collected personal
information only for the following purposes and does not use it beyond these
purposes without obtaining the user s prior consent:
- User Management
- User identification, authentication, and account management
- Prevention of duplicate registration and verification of
external platform linkage
- Prevention of policy violations and misconduct (e.g., hacking,
abuse)
- Verification of minor status and execution of legal guardian
consent process
- Identity verification and response in the event of disputes
- Provision and Operation of Services
- Provision and storage of game content and data synchronization
- Support for multiplayer and community features (e.g., friend
invitations, guilds)
- Response to user inquiries and customer support
- Delivery of service-related notices and announcements
- Confirmation of paid purchases, refund processing, and other
transaction-related services
- Development of New Services and Quality Improvement
- Statistical analysis and user feedback for service enhancement
- Updates and optimization of game features
- System error handling and bug fixes
- Marketing and Event Operations (with user consent)
- Notification and verification for events, promotions,
campaigns, etc.
- Sending promotional materials (SMS, email, push notifications)
- Delivery of prizes and handling of tax-related administrative
matters
- Providing personalized content and targeted advertising based
on online identifiers
- Fulfillment of Legal Obligations and Dispute Resolution
- Compliance with domestic and international laws, regulations,
and administrative requests
- Collection of necessary data for legal responsibilities and
dispute handling
Article 4 (Retention and Use Period of
Personal Information)
- The Company retains and uses personal information for as long
as the user maintains their status or until the purpose of collection and
use has been fulfilled. If the user deletes their account or the
information is no longer required, the data will be destroyed without
delay.
However, information may be retained for a certain period if specified for
the following purposes:
|
Purpose of Retention
|
Data Retained
|
Retention Period
|
|
Response to customer disputes and
prevention of misuse after service withdrawal
|
External platform ID, access records(including IP), download history, misuse records,
device information
|
30 days
|
|
Event or promotion prize verification
|
UID, Nickname, etc.
|
Immediately deleted after winner
announcement
|
- Additionally, in accordance with applicable laws, certain
information may be retained for the period specified below. This data is
only used for the purposes stated and is securely destroyed after the
retention period.
|
Data Retained
|
Legal Basis
|
Retention Period
|
|
Records of advertisement display
|
Act on Consumer Protection in Electronic
Commerce
|
6 months
|
|
Records related to contracts or
withdrawals
|
Electronic Transactions Act
|
5 years
|
|
Records of payments and supply of goods
|
Electronic Transactions Act
|
5 years
|
|
Records of consumer complaints or dispute
resolution
|
Electronic Transactions Act
|
3 years
|
|
Communication fact confirmation data,
such as access logs and access IPs
|
Protection of Communications Secrets Act
|
1 year (based on Korean law), subject to
local regulations
|
- For users in countries or regions with separate data protection
laws, such as the European Union (EU), Brazil, and California, USA, their
retention standards and periods may be adjusted according to the laws of
that region. For example, under the GDPR, data is retained only for the
minimum necessary period, and users may request access, correction, or
deletion at any time.
Article 5 (Procedures and Methods for
the Destruction of Personal Information)
- The Company will promptly destroy personal information without
delay once the retention period has expired or the purpose of processing
has been achieved, in accordance with applicable laws.
However, even if the user deletes the mobile game application
(hereinafter referred to as "app"), if they do not request
membership withdrawal or personal information deletion, the personal
information will not be immediately destroyed and may be stored for a
certain period in accordance with relevant laws and the personal
information processing policy.
- The Company s procedures for the destruction of personal
information are as follows:
- Personal information is classified as subject to destruction
according to internal management policies at the time a reason for
destruction occurs, and is destroyed immediately
or after a certain grace period upon expiration of the retention period
or achievement of the processing purpose.
- The relevant personal information is deleted without delay and
without separate storage, except in cases stipulated by law, and is not
used for any other purpose.
- The methods of destruction are as follows:
- Electronic files: Data is
permanently deleted using technical methods that prevent recovery (e.g.,
overwriting, secure deletion, encryption followed by deletion).
- Paper documents: Physical
documents are destroyed using shredders or through incineration.
- Users residing in certain jurisdictions, including the European
Union (EU), Brazil, and California, may request the deletion of their
personal data in accordance with local laws (e.g., GDPR, LGPD, CCPA). The
Company will comply with such requests unless retention is required by
law.
Users may request deletion at any time via customer support or the
designated Data Protection Officer.
Article 6 (Provision of Personal
Information to Third Parties)
- The Company processes personal information only within the
scope described in Article 3 (Purpose of Using Personal Information) and
does not disclose personal information to third parties without the user s
prior consent. However, exceptions apply in the following cases:
- When the user has provided explicit prior consent
- Where there are special provisions in the law, or to fulfill
legal obligations
- When required by a court judgment, administrative order, or
lawful request from law enforcement or a government agency
- Where it is inevitably necessary to prevent imminent danger to
the life, body, or property of the user or a third party
- In emergencies such as disasters, epidemics, or accidents, the
Company may provide minimal personal information to authorities without
the user s prior consent, in accordance with relevant government
guidelines (e.g., Emergency Personal Information Handling and Protection
Guidelines ). In such cases, the Company will handle the data lawfully and
notify the user when feasible.
- If the Company transfers personal data outside the country or
shares it with a third party located in another country, it will take
appropriate protective measures in accordance with applicable laws (e.g.,
GDPR, LGPD) and notify the user in advance to obtain consent where
necessary.
- The Company ensures that third-party recipients handle personal
information securely. Where required, contractual obligations regarding
data protection will be included in the service agreements.
Note: If any
provision of data to a third party occurs, the Company will clearly inform the
user of the recipient, the data items shared, the purpose of provision, and the
retention period, and obtain separate consent if required.
In accordance with applicable laws,
users have the right to access or withdraw their consent to the provision of
their personal data to third parties at any time.
Article 7 (Outsourcing of Personal
Information Processing)
- The Company may entrust the handling of personal information to
specialized service providers to ensure the safe and efficient provision
of services. The Company properly manages and supervises its contractors
to ensure compliance with personal data protection laws.
- The current outsourcing arrangements are as follows:
|
Service Provider
|
Outsourced Task Description
|
Retention and Use Period
|
|
Amazon Web Services, Inc. (AWS)
|
Operation of global servers and storage
of game data
|
Until termination of service or
outsourcing agreement
|
|
Google Firebase
|
User authentication, cloud database, and
push notifications
|
Until termination of service or
outsourcing agreement
|
|
Tencent Cloud
|
Server infrastructure operation in China
and other regions
|
Until termination of service or
outsourcing agreement
|
|
Google LLC / Apple Inc.
|
App store operation, payment processing,
and purchase tracking
|
As required by applicable laws and app
store policies
|
|
Adjust GmbH
|
Advertising performance analysis and
marketing tracking
|
Until withdrawal of consent or
fulfillment of the purpose
|
|
Google AdMob
|
Delivery of personalized ads and revenue
analysis
|
Until withdrawal of consent or
fulfillment of the purpose
|
|
Oqupie
|
Operation of customer support system and
inquiry handling
|
Until termination of service or
outsourcing agreement
|
- The Company includes the following safeguards in its contracts
with data processors:
- Prohibition on the use of personal information for purposes
other than the contracted services
- Implementation of technical and administrative safeguards
- Obligation to return or destroy personal data after contract
termination
- Immediate notification and liability in the event of a data
breach
- Some of the subcontractors are located overseas. When
transferring data internationally, the Company complies with relevant laws
(e.g., the Personal Information Protection Act, GDPR, LGPD) and informs
users of the following:
- Countries of transfer: United
States (Google Firebase, Google LLC, AdMob, AWS, Adjust), China (Tencent
Cloud)
- Timing and method of transfer:
Real-time transmission at the time of service
use via networks
- Purpose of transfer: Cloud
operation, user authentication, advertising, and payment services
- Retention and use period: Until
the purpose of outsourcing is achieved, service is terminated, or consent
is withdrawn
Article 8 (Rights of Users and Legal
Representatives and How to Exercise Them)
- Users may exercise the following rights regarding their
personal data at any time. In the case of users under the age of 14, their
legal guardian holds the same rights on their behalf:
- Request access to personal data (of self or a minor)
- Request correction or deletion of personal data
- Request suspension of personal data processing
- Withdraw consent for receiving marketing communications
- Request full account deletion and erasure of personal data
- Request data portability (applicable under certain laws such
as the GDPR and LGPD)
- These rights can be exercised through the following channels,
and the Company will promptly respond after verifying the user s identity:
- Email inquiry: florix@florix.co.kr
- In-app customer support or settings menu
- Inquiry form or customer service on the official website
- Any other official methods provided by the Company
- If a request is made through a legal representative, the
Company may require documentation proving the representative relationship
(e.g., certificate of family relationship) and will proceed once the
request is verified as legitimate.
- The exercise of rights may be restricted in the following cases
under relevant laws:
- If access or suspension of processing is restricted under
Article 35(4) or Article 37(2) of the Personal Information Protection Act
- Where deletion is not possible because the preservation of
personal information is stipulated by other laws
- If exercising the rights would likely infringe on the rights
of a third party
- Users residing in jurisdictions such as the European Union
(EU), Brazil, or the state of California in the United States may also
have specific rights under local laws, including the right to data
portability, objection to automated processing, and the right to lodge a
complaint with a supervisory authority.
Users or
their legal representatives may request updates on the status or results of
their rights-related requests, and the Company will make every effort to support these rights to the fullest extent.
Article 9 (Measures to Ensure the
Security of Personal Information)
The Company implements the following
administrative, technical, and physical safeguards to ensure that users'
personal information is not lost, stolen, leaked, altered, or damaged, in
accordance with applicable laws:
- Administrative Safeguards
- Establishment and implementation of an internal management
plan for personal data protection
- Regular security training for personal information handlers
and employees
- Minimization of access privileges to personal data
- Storage of personal information handling records and internal
audits
- Technical Safeguards
- Access permission management and two-factor authentication
application for personal information processing systems, etc.
- Measures to store access logs and prevent forgery or
alteration
- Installation and maintenance of up-to-date antivirus/security
programs on all company PCs and servers
- Application of encryption technology (passwords,
authentication information, etc.)
- Operation of firewalls and intrusion detection systems (IDS)
to prevent external intrusion
- Physical Safeguards
- Access control to server rooms and information storage
facilities
- Secure storage and destruction of documents and media (e.g.,
USB drives) with personal data
- Logging and monitoring of physical access to server
infrastructure
The Company maintains an internal
incident response system to swiftly address any security breaches and protect
user data.
Article 10 (Matters concerning the
installation, operation, and refusal of automatic personal information
collection devices)
- The Company allows for the automatic collection of user
behavior information through the SDK or technology of online targeted
advertising businesses, based on data such as user's website visit history
and app usage patterns, to provide targeted advertising and statistical
analysis services.
- The Company itself does not use web browser-based cookies, and automatically collected behavior
information is collected through external advertising partners or
analytical tools.
[Behavioral Information Collection
Notice]
- Data Collectors: Google, Facebook,
AdMob, and other online advertising service providers
- Collected Items: App usage history,
access time, search keywords, content interactions, ad impressions and
responses, advertising identifiers (e.g., ADID, IDFA)
- Collection Method: Automatically
collected when the app is launched or when ads are viewed or clicked
- Purpose: Providing personalized
advertising, user interest-based marketing, analysis for service
improvement
- The Company and its advertising partners may analyze users
behavior to provide targeted advertisements. This is based on anonymized
or pseudonymized data and does not directly identify individual users.
- Users can disable the collection of advertising identifiers or
opt out of personalized ads through the following methods:
How to Disable Advertising Identifiers:
- Android:
- Settings > Google > Ads > Opt
out of Ads Personalization
- or Settings > Privacy > Ads
- iOS:
- Settings > Privacy > Tracking > Disable "Allow
Apps to Request to Track"
- or Settings > Privacy > Apple Advertising > Turn off
Personalized Ads
Note: The
specific path may vary depending on OS or device version.
- Even if you disable the advertising identifier, general ads may
still be displayed, and only personalized ads will not be provided.
If any automatically collected data is
combined with personal information that can identify an individual, the Company
will obtain explicit consent in accordance with applicable laws prior to
processing such information.
Article 11 (Personal Information
Protection Officer and Contact Information)
The Company designates a Personal
Information Protection Officer and a department in charge of personal
information protection, as follows, in order to
protect user's personal information and smoothly handle inquiries, complaints,
and damage relief related to personal information, etc.
Personal Information Protection
Officer (Data Protection Officer, DPO)
- Name: Hyunseok Choi
- Department: Business Strategy Office
- Email: florix@florix.co.kr
- Phone: +82-10-9238-3333
Personal Information Protection
Department
- Department Name: Customer Support Team
- Email: info@florix.co.kr
- Business Hours: Weekdays 10:00 AM – 6:00 PM (KST, excluding
public holidays)
Users may contact the above personnel or
department for any inquiries or requests related to the protection of their
personal data, including access, correction, deletion, and suspension of
processing. The Company will respond sincerely and promptly to all user
requests.
Users in the European Union (EU) or
other countries where data protection laws apply can make inquiries through the
designated DPO or local representative in accordance with the regulations of
that region, and can directly file a complaint with
the supervisory authority if necessary.
Article 12 (Remedies for Infringement of
Rights)
- Users may request consultation or dispute resolution from the
institutions below to seek relief for damages caused by personal
information infringement.
Furthermore, if they disagree with the company's processing of personal
information, they may file a complaint with the supervisory authority in
the relevant country.
For users residing in the Republic of
Korea:
- Personal Information Infringement Report Center (operated by
Korea Internet & Security Agency)
- Website: https://privacy.kisa.or.kr
- Phone: 118 (no area code)
- Personal Information Dispute Mediation Committee
- Website: https://www.kopico.go.kr
- Phone: 1833-6972
- Supreme Prosecutors Office Cyber Investigation Division
- Website: http://www.spo.go.kr
- Phone: 1301
- KNPA (Korean National Police Agency) ECRM
- Website: http://ecrm.cyber.go.kr
For users residing in the European Union
(EU):
- Users may file complaints with the data protection authority
(DPA) in their country or region of residence (e.g., CNIL in France, BfDI in Germany, DPC in Ireland).
For users in Brazil:
- ANPD (Autoridade Nacional de Proteção de Dados)
- Website: https://www.gov.br/anpd
For users in the State of California,
USA:
- California Attorney General s Office
- Website: https://oag.ca.gov/privacy
- If a dispute or request related to personal information arises,
the Company will make every effort to resolve the issue quickly and
sincerely. Users may contact the Customer Support Team or the Personal
Information Protection Officer to check the progress and results of their
case.
Article 13 (Changes to the Privacy
Policy)
- The Company may amend this Privacy Policy in accordance with
relevant laws, policies, or changes to its services. When changes are
made, the Company will clearly indicate the details and effective date of
the changes and provide prior notice to users.
- Notification of changes to the Privacy Policy will be made
through one or more of the following methods:
- Posting in the notices section of the official website or
within the game app
- In-app pop-up notifications or messages
- Email or push notifications, if consented by the user
- The changed personal information processing policy will take
effect 7 days after the date of announcement, unless there are special
circumstances. However, matters related to significant changes in user
rights or strengthening of obligations will be announced 30 days prior
to enforcement.
- If a user does not agree to the revised Privacy Policy, they
may discontinue the use of the service and delete their account. If the
user continues to use the service without explicitly expressing
disagreement, the Company will regard this as consent to the revised
policy.
The Company maintains a record of
changes to the Privacy Policy and ensures that previous versions remain
accessible to users.
(California Consumer Privacy Act – CCPA
Notice)
This appendix applies only to users
residing in the State of California.
Under the California Consumer Privacy Act
(CCPA), users residing in California have the following rights:
- Notice Regarding the Collection and Use of Personal Information
The Company
collects and processes personal information as described in Article 2
(Categories of Personal Information Collected and Method of Collection) and
Article 3 (Purpose of Using Personal Information), for the following purposes:
- Providing and operating the service
- User support and troubleshooting
- Advertising and marketing performance analysis (based on user
consent)
- User Rights
California
residents may exercise the following rights:
- Request to access the categories of personal information
collected and the history of use
- Request for deletion of personal information
- Request to opt-out of the sale or sharing of personal
information ("Do Not Sell or Share My Personal Information")
The Company does
not sell users personal information as defined under the CCPA. If any data is
shared with third parties, the Company will obtain prior consent in accordance
with the law.
- How to Exercise The Rights
To exercise any
of the CCPA rights, users may contact the Company through the following
methods:
- Email: florix@florix.co.kr
- Customer Support: In-app inquiry or the official website
The Company will
complete the verification process and respond within a reasonable timeframe as
prescribed by applicable law.
This appendix is for the purpose of
additional notice under CCPA and applies in conjunction with this Personal
Information Processing Policy.
Effective Date
This Privacy Policy is effective as of Jan
4, 2026.
- Date of Announcement: Jan 4, 2026
- Date of Enforcement: Jan 4, 2026