Your privacy is important to Dot Incorporation (“Dot”). Thus, we strive to be clear about how we collect, use, disclose, transfer and store your information. This Privacy Policy (“Privacy Policy”) provides an overview of our information practices. The Privacy Policy applies to Dot devices, websites or online applications that refer to or link to the Privacy Policy (collectively, our “Services”).

While this Privacy Policy applies to all our Services, we also have provided certain specific privacy supplements that contain additional information about our practices in connection with particular Services. These supplements apply to your use of the Services they cover. Additional consent will be obtained for certain data processing activities.  

Please note that the Privacy Policy applies to your usage of Dot devices (which are, among the Services, covered by this Privacy Policy, along with our websites and online applications). It also applies regardless of whether you use a computer, mobile phone, tablet, TV, or other devices to access our Services.

It is important that you read the Privacy Policy carefully. By using Dot devices, a computer, mobile phone, tablet, TV, or other devices to access our Services, you consent to the practices we describe in the Privacy Policy and the supplements. If you do not agree to give such consent, you are not allowed to use our Services.

It also is important that you check back often for updates to the Privacy Policy.If we update the Privacy Policy, we will inform you of the changes that we consider to be material by placing a note on relevant Services. By accessing or using our Services after we have placed such a note, you consent to the new practice(s) identified in the update. The most current version of the Privacy Policy will always be available at Dot’s official website (https://dotincorp.com/page/privacy). You can check the “effective date” posted at the top to see when the Privacy Policy was last updated.

What information do we collect about you?

Information you provide directly. Some Services enable you to give us information directly. For example:

• A number of our Services enable users to create accounts or profiles. In connection with these Services, we may ask you to provide certain information (e.g., your personal information such as your name and email address, etc.) about yourself to set up an account or profile on the internet (“Dot Account”).
• If you order a product or paid service from us, we may request your name, contact information, shipping and billing address(es), and credit card information in order to process your order.
• Some of our Services enable you to communicate with third party persons or entities. For example, Dot may delegate our Services, or the handling of our Services, to third parties when it is necessary. In general, those communications will be transmitted through, or stored, on our systems, while you would be sometimes required to directly communicate with these third parties.

Information about your use of the Services. In addition to the information you provide, we may collect information about your use of our Services through software on your device and other means. For example, we may collect the following, but not limited to:

• Device information, such as your hardware model, IMEI number and other unique device identifiers, MAC address, IP address, operating system version, and settings of the device you use to access the Services;
• Log information, such as the time and duration of your use of the Service, search query terms you enter through the Services, and any information stored in cookies that we have set on your device;
• Location information, such as your device’s GPS signal or information about nearby WiFi access points and cell towers that may be transmitted to us when you use certain Services.
• Other information about your use of the Services, such as the apps you use, the websites you visit, and how you interact with content offered through a Service.

Information from third-party sources. We may receive information about you from publicly and commercially available sources (as permitted by law), which we may combine with other information we receive from or about you. We also may receive information about you from third-party social networking services when you choose to connect with those services. 

Other Information We Collect. We also may collect other information about you, your device, or your use of the services in ways that we describe to you at the point of collection or otherwise with your consent.

You can choose not to provide us with certain types of information (e.g., information we request during Dot Account registration), but doing so may affect your ability to use some Services. 

How do we use your information?

We may use information we collect for the following purposes:

• to register you or your device for a Service;
• to provide a Service or feature you request;
• to provide customized content and provide personalized services based on your past activities on our Services;
• for advertising, such as providing customized advertisements, sponsored content and sending you promotional communications;
• for assessment and analysis of our market, customers, products, and services (including asking you for your opinions on our products and services and carrying out customer surveys);
• to understand the way people use our Services so that we can improve them and develop new products and services;
• to provide maintenance services for your device;
• to conduct free prize draws, prize competitions or promotions, as permitted by law; and
• otherwise with your consent.

We may combine information we collect from you and use it for purposes consistent with this Privacy Policy. We may request your additional consent with respect to such combination. 

To whom do we disclose your information?

We will not disclose your information to third parties for their own independent marketing or business purposes without your consent. However, we may disclose your information to the following entities: 

Affiliates. Your information may be shared among Dot affiliates for the purposes described in this Privacy Policy. 

Business Partners. We also may share your information with trusted business partners, including wireless carriers. These entities may use your information to provide you with services you request, make predictions about your interests and may provide you with promotional materials, advertisements and other materials. 

Service providers. We also may disclose your information to companies that provide services for or on behalf of us, such as companies that help us with billing or that send emails on our behalf. These entities are limited in their ability to use your information for purposes other than providing such services for us. 

Other Parties When Required by Law or as Necessary to Protect Our Services. There may be instances when we disclose your information to other parties:

• to comply with the law or respond to compulsory legal procedures (such as a search warrant or other court order);
• to verify or enforce compliance with the policies governing our Services; and
• to protect the rights, property, or safety of Dot, or anyof our respective affiliates, business partners, or customers.

Other Parties in Connection With Corporate Transactions. We may disclose your information to a third party as part of a merger or transfer, or in the event of a bankruptcy.

Other Parties With Your Consent or At Your Direction. In addition to the disclosures described in this Privacy Policy, we may share information about you with third parties when you consent to or request such disclosure. 

Also, Dot may delegate the handling of your personal information to applicable third parties(the “Service Providers”) when it is necessary to ensure optimal Services with your product.

These Service Providers will be authorized by Dot to perform specialized tasks such as, but not limited to: product development, customer service, user experience improvement, user specific promotions, and Dot’s marketing efforts.

Your personal information will be discarded without delay after fulfilling the purpose of collection and use unless it is required to retain such information under the applicable laws or Dot’s internal policies.

After fulfilling the purpose of collection and use of your personal information to which you have consented, your personal information will be placed in a separate database (or a filing cabinet in case of paper records) and retained for a certain period of time stipulated under the applicable laws and regulations before being discarded. Paper records will be either shredded or incinerated, and electronic records will be discarded in an irreversible manner using technical methods. However, your email address (to send out emails regarding the deletion of your Dot Account and respond to user inquiries) and records pertaining to improper use of Services (to prevent any disputes arising from improper use of the Services) will be retained for the period as required by relevant laws before being discarded in the manners as set forth above in accordance with Dot’s internal policies to prevent any disputes arising from improper use of the Services.

In particular, personal information required to be retained by Dot under Korean law is as follows:

• Information to be retained: Records on contracts and withdrawal of offers, etc.
• Applicable laws: Act on the Consumer Protection in the Electronic Commerce Transactions, etc.
• Term of retention:5 years

• Information to be retained: Records on payment and supply of goods, etc.
• Applicable laws: Act on the Consumer Protection in the Electronic Commerce Transactions, etc.
• Term of retention: 5 years

• Information to be retained: Records on customer complaints and resolution of disputes
• Applicable laws: Act on the Consumer Protection in the Electronic Commerce Transactions, etc.
• Term of retention: 3 years

• Information to be retained: Records on marks and advertisements

• Applicable laws: Act on the Consumer Protection in the Electronic Commerce Transactions, etc.
• Term of retention: 6 months

• Information to be retained: Records on collecting and processing credit information
• Applicable laws: Credit Information Use and ProtectionAct
• Term of retention: 3 years

• Information to be retained: Records on a user’s Internet log or the data on tracing a location where a user connected to a network
• Applicable laws: Protection of Communications Secrets Act
• Term of retention: 3 months

• Information to be retained: Other records on communications
• Applicable laws: Protection of Communications Secrets Act
• Term of retention: 12 months

Your Choices

We offer a variety of choices about how we use your information. You can make choices about whether to receive promotional communications from us by following the unsubscribe instructions included in the communication. In addition, you can also make choices by changing your settings for specific Services or when we give you a just-in-time notice, or by visiting relevant web pages.

What do we do to keep your information secure?

We have put in place reasonable physical and technical measures to safeguard the information we collect in connection with the Services. 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.

Third-Party Links and Products on Our Services

Our Services may link to third-party websites and services that are outside our control. We are not responsible for the security or privacy of any information collected by websites or other services. You should exercise caution, and review the privacy statements applicable to the third-party websites and services you use. 

We also may make available to you certain products or services (e.g., apps available through Dot Apps)developed by third parties. Dot is not responsible for these third-party products or services. 

Third Parties that Provide Content, Advertising or Functionality on Our Services

Some of the content, advertising, and functionality on our Services may be provided by third parties that are not affiliated with us. For example:

• We enable you to watch video content provided by content providers;
• Third parties develop apps that we make available through the Dot App Store;
• Certain third parties may serve advertising or keep track of which advertisements users see, how often they see those advertisements, and what users do in response to them; and
• We enable you to share certain materials on the Services with others through social networking services such as Facebook, Twitter, Google +, and LinkedIn.

These third parties may collect or receive certain information about your use of the Services, including through the use of cookies, beacons, and similar technologies, and this information may be collected over time and combined with information collected across different websites and online services. Some of these companies participate in industry-developed programs designed to provide consumers choices about whether to receive targeted advertising. Please visit the websites operated by the Network Advertising Initiative (http://networkadvertising.org) and Digital Advertising Alliance (http://www.aboutads.info/) to learn more. 

If you connect with a social networking service, we may receive and store authentication information from that service to enable you to log in, as well as other information that you allow us to receive when you connect with these services. 

Also, please note that if you choose to connect with a social networking service on a device used by people in addition to you, those other users may be able to see information stored or displayed in connection with your account on the social networking service(s) with which you connect. 

Children

We do not knowingly collect any personal information from children under the age of thirteen (13) without parental consent, unless permitted by law. If we learn that a child under the age of thirteen (13) has provided us with personal information, we will delete it in accordance with applicable law.

Cookies, Beacons and Similar Technologies

We, as well as certain third parties that provide content, advertising, or other functionality on our Services, may use cookies, beacons, and other technologies in certain areas of our Services.

Cookies. Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognize you across different websites, services, devices, and/or browsing sessions. Cookies serve many useful purposes. For example:

• Cookies can remember your sign-in credentials so that you do not have to enter those credentials again each time you log on to a service.
• Cookies help us and third parties understand which parts of our Services are the most popular because they help us to see which pages and features visitors are accessing and how much time they are spending on the pages. By studying this kind of information, we are better able to adapt the Services and provide you with a better experience.
• Cookies help us and third parties understand which ads you have seen so that you do not receive the same ad each time you access a Service.
• Cookies help us and third parties provide you with relevant content and advertising by collecting information about your use of our Services and other websites and apps.

When you use a web browser to access the Services, you can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences. The operating system of your device may contain additional controls for cookies.

Please note, however, that some Services may be designed to work using cookies and that disabling cookies may affect your ability to use those Services, or certain parts of them.

Other Local Storage. We, along with certain third parties, may use other kinds of local storage technologies, such as Local Shared Objects(also referred to as “Flash cookies”) and HTML5 local storage, in connection with our Services. These technologies are similar to the cookies discussed above in that they are stored on your device and can be used to store certain information about your activities and preferences. However, as these technologies may make use of different parts of your device from standard cookies, you might not be able to control them using standard browser tools and settings. For information about disabling or deleting information contained in Flash cookies, please visit the following website: http://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html.

Beacons. We, along with certain third parties, also may use technologies called beacons (or “pixels”) that communicate information from your device to a server. Beacons can be embedded in online content, videos, and emails, and can allow a server to read certain types of information from your device, know when you have viewed particular content or a particular email message, determine the time and date on which you viewed the beacon, and the IP address of your device. We and certain third parties use beacons for a variety of purposes, for example, to analyze the use of our Services and (in conjunction with cookies) to provide content and ads that are more relevant to you. 

By accessing and using our Services, you consent to the storage of cookies, other local storage technologies, beacons and other information on your devices. You also consent to the access of such cookies, local storage technologies, beacons and information by us and by the third parties mentioned above.

Do Not Track Signals and Similar Mechanisms

Some web browsers may transmit “do-not-track” signals to the websites with which the user communicates, although web browsers incorporate and activate this functionality in different ways, and it is not always clear whether users intend for these signals to be transmitted. There currently is disagreement, including among participants in the leading Internet standards-setting organization, concerning what, if anything, websites should do when they receive such signals. Dot currently does not take action in response to these signals, but, if and when a standard is established and accepted, we may reassess how to respond to these signals.

Further information

If you have any specific questions, please contact us at:

Dot Incorporation

Geumcheon-gu, 146, Gasan digital 1-ro, 4F #403 (08507)

Phone:   [+82 2 8641113]

Fax:        [+82 2864 1989]

Email:     Click on “Contact us” at Dot’s website (dotincorp.com/51/write)

Any changes to our Privacy Policy will be notified separately.

Dot may amend this Privacy Policy to, for example, reflect changes to the Services or applicable law. We will post a notice about any Privacy Policy changes, and the updated Privacy Policy will become effective 7 days from the day on which the notice is posted. However, if changes to our Privacy Policy materially affect your rights due to unavoidable reasons, we will give you a 30-day prior notice.

• Date of Announcement: February 24, 2017
• Date of Implementation: February 24, 2017