Privacy Policy

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This Policy (the "Policy") explains the kind of information to be collected in the course of using the application service, Acloset (and its web site). The Policy also explains the way of their treatment.

The company regards personal information of the users as important. The company is obliged to inform them of 1) the purpose of collecting the information, 2) method of company's usage of the personal information, and 3) the measures taken by the company for protection of those personal information.

By using our services and submitting information, you are agreeing to the terms outlined in this Privacy Policy, our Terms of Service, and any other relevant documentation. If you do not agree to these terms, you should stop using the services immediately. Looko reserves the right to deny or suspend access to anyone we believe has violated any part of this Privacy Policy.

This Policy will be effective on the 20th day of January, 2023 and, in case of modification thereof, the company will make public notice through posting it on the bulletin board of the service (or individual notice through sending e-mails).

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1. Information to be collected and method of collection

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(1) Personal information items to be collected

Personal information items to be collected by the Company are as follows:

• Information provided by the users

The Company collects the information directly provided by the users.

• Contact data: name, address, phone number, and etc.

• Profile data: nickname, birthdate, email address (ID), password, phone number, gender, picture, interests, preferences, merchandise sizing, and etc.

• Payment data: name, address, phone number, email address, account number, card number, and etc.

• Uploaded data: text, photo, audio, video, and their metadata

• Submitted data: any data you provide when you participate in a promotion or competition

• Information collected while the users use services

Besides of information directly provided by the users, the Company may collect information in the course that the users use the service provided by the Company.

• Equipment information: Equipment identifier, and use information of website or application, operating system and its version, device information.

• Your activities: Profiles you have viewed; Your views, likes, saves, searches; Users you follow (and users who follow you); The time you access our Service and for how long; The website you came to our website from, or went after leaving our website; In-app messages and comments; Item description; Preferences and notification settings; Any choices you make when using our Service.

• Log information: IP address, log data, use time, internet protocol address, cookie and web beacon

• Location information

• Other Information

In following circumstances, we may also collect and use your data.

• When they are legally required

• When we acquired your consent

• We may use your data for legitimate business purposes, as long as our use does not outweigh your interests and rights.

• Sensitive Information

We may collect sensitive information, such as information about your religious beliefs, racial or ethnic origin, physical and mental health details, or sexual orientation, with your express consent, for example when you complete a survey.

We may also use this information for marketing and publicity purposes, with your permission. The provision of sensitive data for these purposes is completely voluntary. Additionally, we may collect and use sensitive data to comply with government regulations.

If you choose to share sensitive data on our service, you acknowledge that you are making this information publicly available at your own discretion and that we may use it for the purposes mentioned above. We reserve the right to remove sensitive data from our service or request that you remove it at any time.

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(2) Method of collection

The Company collects the information of users in a way of the followings:

• application, webpage, written form, fax, telephone calling, e-mailing.

• provided by partner companies

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2. Use of collected information

The Company may use the collected information of users for the following purposes:

• Member management and identification

• To detect and deter unauthorized or fraudulent use of or abuse of the service

• Performance of contract, service fee payment and service fee settlement regarding provision of services demanded by the users

• To provide service

• Improvement of existing services and development of new services

• To enhance user experience

  • Show you your feed and search results on our Service and order the results in a way that is relevant to you. We use technology (an algorithm) that uses your preferences and, where you have consented to us using your location data, your location to do this.

  • Display your items to the most relevant potential buyers. We use technology (an algorithm) to do this.

  • Send you tips and other notifications we think will improve your experience of the Service.

  • Assess if our marketing campaigns or promotions have been successful.

  • Send you marketing (including via email) about products and services we think may be of interest to you.

• Making notice of function of company sites or applications or matters on policy change

• To help you connect with other users you already know and to allow other users to connect with you (only with your permission)

• To make statistics on member’s service usage, to provide services and place advertisements based on statistical characteristics

• To provide information on promotional events as well as opportunity to participate

• To comply with applicable laws or legal obligation

• Use of information with prior consent of the users (for example, utilization of marketing advertisement)

• To communicate with users and send marketing materials

• To enable security features, such as remembering devices and sending security codes

• To process orders

• To prevent fraudulent activity

• To resolve conflicts between users

• To take any other necessary actions to provide the services offered by Poshmark

If the Company desires to use the information other than those expressly stated in this Policy, the Company will obtain a consent from the users.

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3. Disclosure of collected information

Except for the following cases, the Company will not disclose personal information with a 3rd party:

• when the Company disclosing the information with its affiliates, partners and service providers;

  • When the Company's affiliates, partners and service providers carry out services such as bill payment, execution of orders, products delivery and dispute resolution (including disputes on payment and delivery) for and on behalf of the Company

  • We may need to share your data with the following types of entities:

    • Shipping companies, if you have chosen to use their services for items you sell or purchase.

    • Payment processing companies, to complete sales transactions.

    • Identification verification service providers, to verify your access to the service and prevent fraudulent activity on your account.

    • Moderators who monitor our service, to ensure our terms of service are being followed and to prevent any criminal activity on our platform.

    • Analytics providers, to help us understand how our service is being used.

    • Third-party service providers that help us improve the functionality of our service, such as providers of image tagging services that allow you to share images through our service.

    • Advertising partners, to better target ads and understand the effectiveness of our advertising.

    • Our subsidiaries and ultimate holding company, and any subsidiaries they own. Companies within our group will only use your data to provide the service and for other purposes described in this privacy policy.

  • Please note that Poshmark does not control how our business partners may use your personal information. They are responsible for managing the use of personal information collected in these circumstances. We may also share your personal data with our corporate parent, subsidiaries, and affiliates for purposes consistent with this privacy policy, as well as other Poshmark services which you may not be a user of.

  • If you use features or functionality that connects our service to a third-party platform, such as a social media network, we may share your information with that third party. We do not control how they use your information. We may also share information about you with additional third parties in the course of providing our services, whether or not you have authorized such sharing.

• When a user provide information to share

  • Most of the information you provide to us when you register, update your profile, or list an item is intended to be shared with other users and displayed on your profile. This includes your photos, outfit ideas, posts, comments, and other content. We may display this content through our services and further distribute it to a wider audience through third-party sites and services. However, please keep in mind that once this information is displayed on publicly viewable web pages, it can be collected and used by others. We cannot control who reads your postings or what other users may do with the information that you voluntarily post, so it's very important that you do not include any sensitive, confidential, or other information you do not wish to share in your posts. Once you have posted information publicly, while you will still be able to edit and delete it on the service, you will not be able to edit or delete it from cached, collected, and stored copies of the information elsewhere.

  • If you make a purchase using our service, the seller will be provided with certain information, including your username, name, delivery address, email address, and phone number that you provide during the checkout process. This information is necessary for the seller to complete your order.

• When a user publishes feedback

  • We may share and publish any feedback we receive from you and may identify you by your first and last name and may also indicate your home city. If you make any comments on a blog or forum associated with Poshmark, or on the Poshmark Service, you should be aware that you have no expectation of privacy and any personal data you submit there can be read, collected, or used by other users of these forums, or the Service, and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit in these blogs and forums or on the Service.

• when the users consent to disclose in advance;

  • When the user selects to allow his or her personal information to be shared with the sites or platform of other companies such as social networking sites

  • Other cases where the user gives prior consent for sharing his or her personal information

• when there is a business reorganization;

  • Should Depop go through any business transition, like a sale, acquisition, liquidation, receivership or assets transfer, We may share your personal information with the involved parties as it is in our legitimate interest to do so.

• when disclosure is required by the laws:

  • if required to be disclosed by the laws and regulations; or

  • if required to be disclosed by the investigative agencies for detecting crimes in accordance with the procedure and method as prescribed in the laws and regulations.

 

4. Cookies, Beacons and Similar Technologies

The Company may collect collective and impersonal information through 'cookies', 'web beacons', ‘pixel tracking technology’, and the like.

Cookies are very small text files to be sent to the browser of the users by the server used for operation of the websites of the Company and will be stored in hard-disks of the users' computer.

Web beacon is a small quantity of code which exists on the websites and e-mails. By using web beacons, we may know whether a user has interacted with certain web pages or the contents of email.

Information collected via cookies and web beacons are used for evaluating, improving services and setting-up users' experiences so that the company can improve service quality to the users.

The items of cookies to be collected by the Company and the purpose of such collection are as follows:

• strictly necessary cookies

This cookie is a kind of indispensible cookie for the users to use the functions of the services of the Company. Unless the users allow this cookie, the services such as shopping cart or electronic bill payment cannot be provided. This cookie does not collect any information which may be used for marketing or memorizing the pages visited by the users

(Examples of necessary cookies)

• Memorize the information entered in an order form while searching other pages during web browser session

• For the page of products and check-out, memorize ordered services

• Check whether login is made on service

• Check whether the users are connected with correct services of the Company while the Company changes the way of operating its services

• Connect the users with certain application or server of the services

• performance cookies

These cookies collect information how the users use the services of the Company such as the information of the pages which are visited by the users most. This data helps the Company to optimize its services so that the users can use the services more comfortably. This cookie does not collect any information who are the users. Any and all the information collected by this cookie will be processed collectively and the anonymity will be guaranteed.

(Examples of performance cookies)

• Web analysis: provide statistical data on the ways of using the services

• Advertisement response fee: check the effect of advertisement of the Company

• Management of error: measure an error which may occur so as to give a help for improving website

• Design testing: test other designs of the website of the Company

• functionality cookies

These cookies are used for memorizing the set-ups so that the Company provides services and improves visit of users. Any information collected by this cookie do not identify the users individually.

(Examples of functionality cookies)

• Memorize set-ups applied such as layout, text size, basic set-up and colors

• Memorize when the customer responds to a survey conducted by the Company

• targeting cookies or advertising cookies

These cookies are connected with the services provided by a 3rd party such as the buttons of 'good' and 'share'. The 3rd party provides these services by recognizing that the users visits the website of the Company.

(Examples of targeting cookies or advertising cookies)

• They carry out PR to the users as targets in other websites by connecting through social networks and these networks use the information of users' visit

• They provide the information of users' visit to ad agencies so that they can suggest an ad which may attract the interest of the users

The users have an option for cookie installation. So, they may either allow all cookies by setting option in web browser, make each cookie checked whenever it is saved, or refuses all cookies to be saved. Provided that, if the user rejects the installation of cookies, it may be difficult for that user to use the parts of services provided by the Company. Please note that you can manage the settings of your browser, mobile device, or other applications that govern automated data collection. It is your responsibility to check and set up your preferences.

 

5. User’s right

The users or their legal representatives, as main agents of the information, may exercise the following rights regarding the collection, use and sharing of personal information by the Company:

• access to, make corrections on, and delete personal information

  • You have the right to access, review, update, and delete your personal information or account on our service at any time through the Service. You may can also contact us via support@acloset.app so that we can assist you on this matter.

  • Verification of requests may be required, and a fee may be charged, if allowable by law. In some cases, the requests may be unable to be fulfilled or rejected, and an explanation will be provided.

  • Please be aware that some information may be required to be retained by law and cannot be deleted. We will retain certain data indefinitely unless you delete it or ask for its deletion.

  • We keep your personal data only for as long as it is necessary for the purpose it was collected, and in line with legal requirements. We may retain your information to comply with legal obligations, investigations, proceedings or for backup, archival, audit, or other similar purposes.

• request the withdrawal of their consent provided before

  • You have the ability to withdraw any consent you have provided Poshmark at any time, however, this may limit or restrict your use or access of our Services.

• unsubscribe to our email communications

  • We may send you various types of emails, including marketing and promotional messages as well as third-party related communications. You have the option to unsubscribe or opt-out from these emails at any time through our Services. However, please keep in mind that you might need to do this for each Poshmark Service individually. Despite your preference, we may still need to send you service-related communications such as updates to our terms of service or this Policy.

In order to exercise the above rights, a user can use the menu of customer service or contact the Company by sending a document or -mails, or using telephone to the company, the Company will take necessary measures without delay. The Company may reject the request of you only to the extent that there exists either proper cause as prescribed in the laws or equivalent cause.

To process requests concerning your access or deletion rights to your information, we reserve the right to verify your identity using methods we deem appropriate. Your authorized agent, armed with a valid power of attorney, their own valid government-issued identification and your valid government-issued identification, may also make a request on your behalf. However, without sufficient detail provided by you, it may be difficult for us to comprehend and respond to your request.

You are entitled to exercise these rights without incurring any cost. However, in certain circumstances, we may be allowed by law to charge a reasonable fee or decline to comply with your request if it is found to be excessive, repetitive or unjustified.

 

6. Security

The Company regard the security of personal information of uses as very important.

The company constructs the following security measures to protect the users' personal information from any unauthorized access, release, use, or modification.

• Encryption of personal information

  • Transmits users' personal information by using encrypted communication zone

  • Stores important information such as passwords only after encrypting it

• Countermeasures against hacking

  • Installs a system in the zone the external access to which is controlled so as to prevent leakage or damage of users' personal information by hacking or computer virus

• Establish and execute internal management plan

• Operate access control system

 

7. Protection of personal information of children

The service will not be provided to the children age under 13. The company collect personal information of children only when to validate a user’s age. Information collected in the process of validation will be discarded immediately after the validation. Company does not intentionally collect any personal information from children other than validation.

(Additional procedure for collecting personal information from children) However, if the Company collects any personal information from children under 13 or equivalent minimum age as prescribed in the laws in relevant jurisdiction for the services for unavoidable reason, the Company will go through the additional procedure of the followings for protecting that personal information of children:

• verify, to the extent that efforts are reasonably made, whether they are children of the age at which consent from their guardian is required and the consenting person is an authorized one.

• obtain consent from the parents or guardian of children so as to collect personal information of children or directly send the information of products and services of the Company

• give the parents or guardian of children a notice of Company's policy of privacy protection for children including the items, purpose and sharing of personal information collected

• grant to legal representatives of children a right to 1) access to personal information of that children, 2) correction or deletion of personal information, 3) temporary suspend the treatment of personal information, 4) and request for withdrawal of their consent provided before

• limit the amount of personal information exceeding those necessary for participation in online activities.

Please reach out to us if you believe that a child under the age of 13 has provided us with their personal data. We will remove the data and deactivate the associated account.

 

8. Data That Does Not Belong to You

• Through the Service, you may share contact information or refer friends to third parties. When providing such data, it is your responsibility to ensure that you have the legal rights to upload it, and to obtain any required consents for us to use the information.

 

9. Modification of Privacy Protection Policy

The Company has the right to amend or modify this Policy from time to time and, in such case, the Company will make a public notice of it through bulletin board of its website or application service (or through individual notice such as written document, fax or e-mail) and obtain consent from the users if required by relevant laws. Nevertheless, you are ultimately responsible for consulting this Privacy Policy for regular changes.

Changes to this Privacy Policy will take effect upon update unless otherwise stated by us. Your continued use of our Services will indicate your acceptance of these changes and your agreement to be bound by the modified terms. If you do not agree with the changes, you should discontinue your use of the Services immediately.

 

10. Contact information of Company

Please use one of the following methods to contact the Company should you have any queries in respect to this policy or wish to update your information:

• Company name: Looko Inc.

• Address: 6th floor, 18, Teheran-ro 43-gil, Gangnam-gu, Seoul, Republic of Korea

• Tel.: 82-70-4473-6770

• E-mail: support@alcoset.app

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Effective December 1, 2020.

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Appendix of Privacy Protection Policy

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<1> Data transfer to other countries

Considering it engages in global businesses, the Company may provide the users' personal information to the companies located in other countries for the purpose as expressly stated in this Policy. The Company takes reasonable measures to protect personal information when it is transmitted, retained, or processed.

It's important to note that privacy laws that apply to recipients of this information may not be as protective as those in your jurisdiction, and we cannot guarantee that they comply with specific requirements of local privacy laws. We may also be required to disclose personal information in response to lawful requests by public authorities, including for national security or law enforcement purposes.

We will take all necessary steps to ensure that your data is handled securely and in line with this Privacy Policy and relevant privacy laws.

It's worth noting that, unfortunately, the internet can never be completely secure and as such, we cannot guarantee the security of your data during transmission through our Service and any transmission is done at your own risk. However, once we receive your data, we employ strict procedures and security features to prevent unauthorized access.

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<2> 3rd party's sites and services

The website, product or service of the Company may include the links to the ones of a 3rd party and the privacy protection policy of the site of 3rd party may be different. Thus, it is required for the users to check additionally that policy of a 3rd party site linked to the site of the Company. We are not responsible for these 3rd party’s websites or privacy policies.

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<3> Guide for users residing in California

If the user resides in California, certain rights may be given. The Company prepare preventive measures necessary for protecting personal information of members so that the Company can comply with online privacy protection laws of California.

In case of leakage of personal information, a user may request the Company to check the leakage. In addition, all the users can modify their information at any time by using the menu in the application service or the website by connecting their personal account.

Moreover, the Company does not trace the visitors of its website nor use any signals for 'tracing prevent'. The Company will not collect and provide any personal identification information through ad services without consent of users.

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<4> Guide for users residing in Korea

The Company guides several additional matters to be disclosed as required by the information network laws and personal information protection laws in the Republic of Korea. Please refer to the privacy policy terms written in Korean.