Polanotes Privacy Policy

1. General Provisions

Polaris Office Co., Ltd. ("Company") complies with the Personal Information Protection Act and related laws to protect users' privacy and rights, and to legally and safely process personal information. In accordance with Article 30 of the Personal Information Protection Act, the Company establishes and discloses the following Privacy Policy to inform users of the procedures and standards for processing and protecting personal information, and to facilitate prompt and smooth handling of related complaints.

Separate privacy policies for residents of the EU, Japan, and the United States are available at the end of this document.

2. Purpose of Processing Personal Information

The Company processes personal information for the following purposes

  1. Identification of members and confirmation of intention to join, as well as verification of identity and age
  2. Verification of legal representative consent when collecting personal information of children under 14 years of age, and confirmation of identity when exercising legal representative rights
  3. Handling user inquiries or complaints, and delivering notices
  4. Transmission, delivery, and billing of contents and fees related to paid services
  5. Recording usage of digital goods and services, and compiling related usage frequency and statistical data
  6. Preventing and sanctioning acts that interfere with the smooth operation of the service, including account misuse and fraudulent activity
  7. Estimating demographic characteristics and analyzing user interests, preferences, and behavior to recommend customized content and for use in marketing, event, and advertisement planning
  8. Developing new services and enhancing service features, including the provision of personalized services and building a privacy-protective service environment
  9. Collecting service usage records and access frequency, and compiling overall service usage statistics

3. Items and Methods of Personal Information Collection

(1) Items Collected

The Company may collect the following personal information

Purpose Category Items
Sign up for social login in app or web
Google
Required ID(Email), name(or nickname)
Sign up for social login in app or web
Apple
Required ID(Email), name(or nickname)
Use of services Required device info(platform, device model, OS, browser type, etc.), IP address, service usage records, cookies, language, referral path, access token, session ID
ustomer Support Required Email, device info(platform, device model, OS, browser type, etc.), feedback and inquiries to help us improve our services
Optional Attachments related to the inquiry
To earn points Required Email, device info(platform, device model, OS, browser type, etc.), name(or nickname), service usage records
Send advertising information to
(utilized for marketing)
Optional Email, name(or nickname), device token information, ADID
Consent of legal guardian under 14 Required Applicant: Full name, account, date of birth, contact
Legal representative information: Full name, relationship to the applicant, contact (mobile phone number), family relationship certificate, certified copy
Manage eventbr />Giveaway Required Email, name(or nickname), mobile phone number
Manage event
Airdrop
Required Email, cryptocurrency wallet address, mobile phone number

(2) Collection Methods

  1. Social login at signup
  2. Automatic collection via cookies
  3. When using customer support services
  4. When you consent to the collection of personal information in the course of using the Service and enter the information yourself
  5. When participating in an event/occasion, whether online or offline

4. Processing of Children's Personal Information (Under 14)

  1. If consent is required to process the personal information of a child under the age of 14, the Company shall obtain consent from the child's legal representative.
  2. When the Company obtains the consent of the child's legal representative to process the personal information of a child under the age of 14, the Company may require the child to provide the minimum amount of information, such as the name and contact information of the legal representative, and the child shall provide the Company with written consent and a written document certifying that he or she is the person obligated to protect the personal information by attaching it to an email. The Company shall send an email confirming that it has received the consent indication.

Personal Information Protection and Access Request Handling Department

5. Retention and Destruction of Personal Information

(1) Retention period

  1. Account deletion

    If you delete your account, we will deactivate your account for up to 30 days. When your account is deactivated, you will no longer be able to see your name (or nickname), ID and service usage records, and your data will be pending deletion. You have up to 30 days from the date your account is deactivated to recover your account. If you do not do so, your personal data will be destroyed immediately. The exception is information that must be retained for a certain period of time in accordance with applicable laws and regulations.

    1. If there is an ongoing investigation or inquiry into a violation of applicable laws, we may retain your personal information until the investigation or inquiry is concluded.
    2. If there are any debts or liabilities related to the use of the Service, until settlement
    3. Data of members due to unauthorized use of the service shall be separately stored for up to a year and then destroyed.
  2. Withdrawal of consent to collection and use
  3. Achievement of the purpose of collection and use
  4. Legal retention period:
    1. Records related to contract or withdrawal of subscription: 5 years (Electronic Commerce Act)
    2. Records of consumer complaints or dispute handling: 3 years (Electronic Commerce Act)
    3. Records of electronic financial transactions: 5 years (Electronic Financial Transactions Act)
    4. Log-in records, IP: 3 months (Act on the Protection of Communications Secrets)

(2) Procedures and methods for destroying personal information

  1. In the form of electronic files: Permanently deleted in an irrecoverable manner
  2. In the form of paper documents: Shredded or incinerated

6. Provision to Third Parties and Entrustment

(1) Third-Party Provision

Only with user consent or in accordance with law

  1. If the member has consented in advance

    When providing personal information to a third party, the Company shall notify the user in advance of the recipient of the personal information, the purpose of use, the items of personal information provided, and the period of retention and use of personal information, and obtain express and individual consent.

Status of provision of personal information to a third party
Recipient Purpose of Provision Items Retention and Usage Period
DECOMPANY GLOBAL, INC. PTE. LTD. Verification of user information related to the service involving POLA tokens. [Required] Email, name(or nickname), service usage records, country, mobile phone number, cryptocurrency wallet address Retention for five years after using the service related to POLA tokens, followed by deletion.
PolarisShareTech
PolarisShareTech Send advertising information to (utilized for marketing) [Optional] Email, name(or nickname), service usage records, device token information, ADID Until account deletion or withdrawal of consent
  1. If there are special provisions in the relevant laws and regulations, or if requested by investigative and supervisory authorities in accordance with the procedures and methods prescribed by laws and regulations for the purpose of investigations and investigations

(2) Entrusted Processing

In order to ensure the smooth handling of personal information, the Company entrusts the processing of personal information to third parties as follows.

Service Provider Entrusted Tasks
PolarisShareTech Fraud prevention, data storage and analytics, login process, drive delivery and operations

In accordance with Article 26 of the Personal Information Protection Act, when entering into an outsourcing agreement, the Company specifies in writing—such as in contracts—the prohibition of processing personal information beyond the scope of the entrusted task, the implementation of technical and administrative protection measures, restrictions on sub-entrustment, management and supervision of the entrusted party, and liability for damages. The Company also supervises entrusted parties to ensure they handle personal information safely. Pursuant to Article 26(6) of the Personal Information Protection Act, the Company's prior consent is required when an entrusted party subcontracts the entrusted tasks. If there are any changes to the content of the entrusted tasks or the entrusted party, such changes will be disclosed promptly through this Privacy Policy.

7. Overseas Transfer of Personal Information

(1) International Transfers

May store personal information overseas in order to provide global services.

f you wish to object to the transfer of your personal information overseas, please contact us at [contact email: support@polarisoffice.com].

However, if it is technically necessary to provide the Service, you may be restricted from using some features.

Recipient Contact Date and Method of Transfer Purpose of Transfer Personal Information Items Transferred Destination Country Retention and Usage Period of Personal Information
Amazon Web Service aws-korea-privacy@amazon.com Transferred over the network whenever data is updated Infrastructure operation and data storage for service provision service usage records United States Until account deletion or termination of the outsourcing contract
Sendgrid privacy@twilio.com Transferred over the network whenever data is updated Send advertising information to (utilized for marketing) Email United States Until account deletion or withdrawal of consent
Twilio privacy@twilio.com Transferred over the network whenever data is updated Verification code sent for mobile phone number authentication Mobile phone number United States Until account deletion or termination of the outsourcing contract
DECOMPANY GLOBAL, INC. PTE. LTD. connect@polarishare.com Transferred over the network whenever data is updated Verification of user information related to the service involving POLA tokens. Email, service usage records Singapore Until account deletion or termination of the outsourcing contract

8. User Rights and How to Exercise Them

You may exercise the following rights with respect to your Personal Data at any time.

  1. Right to be informed
    1. The Company will provide you with legal notices and obtain your consent before processing your personal information. You can always check this Privacy Policy for general information about the processing of your personal information.
  2. Right to access and modify personal information
    1. You can access and modify your personal information on [My Page].
  3. Right to delete personal information and withdraw consent
    1. You may delete your personal information or withdraw your consent to the collection and use of personal information at any time from [My Page].
  4. Right to request account deletion and suspension of processing
    1. Users can delete account through “Delete Account” in [My Page] > [Account Settings] > [Account Information]. The personal information of the withdrawn member will be processed as specified in “4. Storage and Destruction of Personal Information”.
    2. You may request the suspension of the processing of your personal information.

You may make a request via [inquiry email: support@polarisoffice.com], and the Company will respond appropriately in accordance with relevant laws and regulations.

9. Security Measures

The Company have implemented the following measures to protect your personal information.

  1. Technical: Encryption, firewalls, access control
  2. Administrative: Staff training, access rights management
  3. Physical: Server room access restrictions

10. Cookies

The Company may use cookies and similar technologies to improve your experience. You can refuse the storage of cookies through your browser settings.

Our cookie policy can be found in our Cookie Policy.

11. ontact for Privacy Inquiries

If you have any questions or inquiries regarding privacy or need customer support, please contact us at the contact information listed below.

Privacy Officer

Personal Information Officer and Access Request Processing Department

Complaints and Supervisory Authority Contact

12. Violation Remedies

The information subject may apply for dispute resolution or consultation to the Personal Information Dispute Mediation Committee or the Personal Information Infringement Report Center of the Korea Internet & Security Agency to receive relief from personal information infringement. In addition, please contact the following organizations for other personal information infringement reports and consultations.

  1. Personal Information Dispute Mediation Committee: (without area code) 1833-6972 (www.kopico.go.kr)
  2. Personal Information Infringement Report Center: (without area code) 118 (privacy.kisa.or.kr)
  3. Supreme Prosecutors' Office: (without area code) 1301 (Supreme Prosecutors' Office)
  4. National Police Agency: (without area code) 182 (Cybercrime Reporting System (ECRM))

The Company is committed to ensuring the right of information subjects to self-determination of personal information, and to counseling and damage relief due to personal information infringement, and if you need to report or consult, please contact the following departments.

Customer consultation and report on personal information protection

13. Policy Updates and Notifications

Changes will be notified via email; latest version available on the website

Last Modified: [2025-04-04]

[Appendix: EU Residents – GDPR Compliance]

1. Legal basis

processes personal data in accordance with the European Union General Data Protection Regulation (GDPR), and we collect and process information based on the following legal bases

2. International Transfers of Personal Information

3. Your rights (based on Articles 15~21 of the GDPR)

You have the following rights under the GDPR.

The exercise of your rights is governed by "8. Your Rights and How to Exercise Them" and other items can be requested by contacting support@polarisoffice.com

[Appendix: Japan Residents – APPI Compliance]

1. Compliance with the Personal Information Protection Act (APPI)

The Company comply with the Japanese Personal Information Protection Act (APPI) and handle your information securely in accordance with the guidelines of the Personal Information Protection Commission (PPC).

2. International Transfer of Personal Information

3. Your Rights

You may have the following rights under the APPI.

The exercise of your rights is governed by "8. Your Rights and How to Exercise Them", and other items can be requested by contacting support@polarisoffice.com

4. Processing of Anonymous Processed Data

The Company may create and utilize anonymous processed data, which is processed in such a way that no specific individual can be identified.

[Appendix: US Residents – CCPA & CPRA Compliance]

1. Compliance with the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA)

The Company comply with the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA) to protect your information.

2. Types of Personal Information We Collect

Please see "3. What Personal Information We Collect and How We Collect It" for more information about the personal information we have collected in the past year and how we collect it. For the purposes for which we collect the personal information we collect, see "2. Purposes of Processing Personal Information". For details on who we share it with and how long we keep it, see "6. Provision of Personal Information to Third Parties and Outsourcing of Processing".

3. International Transfers of Personal Information

4. Your Rights (under the CCPA & CPRA)

California residents have the following rights.

To exercise your rights, please refer to "8. Your Rights and How to Exercise Them" and for other information, please contact support@polarisoffice.com

5. 'Do Not Sell My Personal Information'

The Service does not sell your personal information; however, we may share some data with our advertising partners (e.g., Google, Meta, etc.) to provide personalized advertising, which you can opt out of by using the 'Do Not Sell or Share My Personal Information' option.