PRIVACY POLICY
Last updated September 22, 2023
This privacy notice for Cresyn Co.,Ltd (doing business as CRESYN) ("we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our
services ("Services"), such as when you:
・ Download and use our mobile application (ODDICT), or any other application of ours that links to this privacy notice
・ Engage with us in other related ways, including any sales, marketing, or events
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you
still have any questions or concerns, please contact us at support@phiaton.com.
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below
to find the section you are looking for.
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you
make, and the products and features you use. Learn more about personal information you disclose to us.
Do we process any sensitive personal information? We do not process sensitive personal information.
Do we receive any information from third parties? We may receive information from public databases, marketing partners, social media platforms, and other outside sources. Learn more about information
collected from other sources.
How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We
may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.
In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share
your personal information.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy
rights.
How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with
applicable data protection laws.
Want to learn more about what we do with any information we collect? Review the privacy notice in full.
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate
in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features
you use. The personal information we collect may include the following:
・ email addresses
・ names
・ usernames
・ birthday
・ passwords
Sensitive Information. We do not process sensitive information.
Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, Twitter, or other social media account. If you choose to
register in this way, we will collect the information described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" below.
Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:
・ Geolocation Information. We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application(s), to provide
certain location-based services. If you wish to change our access or permissions, you may do so in your device's settings.
・ Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's bluetooth, social media accounts, and other features. If you wish to
change our access or permissions, you may do so in your device's settings.
・ Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device
and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our appli-
cation(s), we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s
unique device ID, and information about the features of our application(s) you accessed.
・ Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you
may turn them off in your device's settings.
This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device
and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when
you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
The information we collect includes:
・ Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log
files. Depending on how you interact with us, this log
data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files
viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).
・ Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include
information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating
system, and system configuration information.
・ Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of
the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt
out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to
use certain aspects of the Services.
Information collected from other sources
In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.
In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint
marketing partners, affiliate programs, data providers, social media platforms, and from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent
data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles, for purposes of targeted advertising and event promotion. If you interact with
us on a social media platform using your social media account (e.g., Facebook or Twitter), we receive personal information about you such as your name, email address, and gender. Any personal infor-
mation that we collect from your social media account depends on your social media account's privacy settings.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your
information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
・ To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in
working order.
・ To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences.
You can opt out of our marketing emails at any time. For more information, see "WHAT ARE YOUR PRIVACY RIGHTS?" below.
・ To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more.
・ To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are
most relevant to you.
・ To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply
with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the
following legal bases to process your personal information:
・ Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn
more about withdrawing your consent.
・ Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests
and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
Send users information about special offers and discounts on our products and services
Develop and display personalized and relevant advertising content for our users
Support our marketing activities
・ Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory
agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
・ Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to
the safety of any person.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can
be inferred (i.e., implied consent). You can withdraw your consent at any time.
・ In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
・ If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
・ For investigations and fraud detection and prevention
・ For business transactions provided certain conditions are met
・ If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
・ For identifying injured, ill, or deceased persons and communicating with next of kin
・ If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
・ If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating
a breach of an agreement or a contravention of the laws of Canada or a province
・ If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
・ If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
・ If the collection is solely for journalistic, artistic, or literary purposes
・ If the information is publicly available and is specified by the regulations
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short: We may share information in specific situations described in this section and/or with the following third parties.
We may need to share your personal information in the following situations:
・ Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion
of our business to another company.
・ When we use Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs (e.g., Google Maps API, Places API). We use certain Google Maps Platform
APIs to retrieve certain information when you make location-specific requests. This includes: Location; and other similar information. A full list of what we use information for can be found in this
section and in the previous section titled "HOW DO WE PROCESS YOUR INFORMATION?" We obtain and store on your device ("cache") your location. You may revoke your consent anytime
by contacting us at the contact details provided at the end of this document.
The Google Maps Platform APIs that we use store and access cookies and other information on your devices. If you are a user currently in the European Economic Area (EU countries, Iceland,
Liechtenstein, and Norway) or the United Kingdom, please take a look at our Cookie Notice.
・ Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries,
joint venture partners, or other companies that we control or that are under common control with us.
・ Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We may use cookies and other tracking technologies to collect and store your information.
We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can
refuse certain cookies is set out in our Cookie Notice.
6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.
Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain
profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name,
email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.
We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services. Please note that we do not
control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they
collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.
7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In Short: We may transfer, store, and process your information in countries other than your own.
Our servers are located in South Korea. If you are accessing our Services from outside South Korea, please be aware that your information may be transferred to, stored, and processed by us in
our facilities and by those third parties with whom we may share your personal information (see "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?" above), in South
Korea, United States, and other countries.
If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as
comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.
European Commission's Standard Contractual Clauses:
We have implemented measures to protect your personal information, including by using the European Commission's Standard Contractual Clauses for transfers of personal information between
our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in
accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our
third-party service providers and partners and further details can be provided upon request.
8. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as
tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because
your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
9. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your
personal information. You may review, change, or terminate your account at any time.
In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy
of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (vi) if applicable, to data portability; and (vii) not to be subject to
automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by
using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.
We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority
or UK data protection authority.
If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the
right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US
ABOUT THIS NOTICE?" below or updating your preferences.
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted
in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails
that we send, or by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing lists.
However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests,
or for other non-marketing purposes.
Account Information
If you would at any time like to review or change the information in your account or terminate your account, you can:
・ Log in to your account settings and update your user account.
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to
prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
If you have questions or comments about your privacy rights, you may email us at support@phiaton.com.
10. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data
about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not
currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must
follow in the future, we will inform you about that practice in a revised version of this privacy notice.
11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: If you are a resident of California, Virginia, Colorado or Connecticut, you are granted specific rights regarding access to your personal information.
What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve (12) months:
CATEGORY |
EXAMPLES |
COLLECTED |
A. Identifiers |
Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name |
YES |
B. Personal information as defined in the California Customer Records statute |
Name, contact information, education, employment, employment history, and financial information |
YES |
C. Protected classification characteristics under state or federal law |
Gender and date of birth |
YES |
D. Commercial information |
Transaction information, purchase history, financial details, and payment information |
NO |
E. Biometric information |
Fingerprints and voiceprints |
NO |
F. Internet or other similar network activity |
Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements |
NO |
G. Geolocation data |
Device location |
YES |
H. Audio, electronic, visual, thermal, olfactory, or similar information |
Images and audio, video or call recordings created in connection with our business activities |
NO |
I. Professional or employment-related information |
Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us |
NO |
J. Education Information |
Student records and directory information |
NO |
K. Inferences drawn from collected personal information |
Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics |
NO |
L. Sensitive personal Information |
|
NO |
We will use and retain the collected personal information as needed to provide the Services or for:
・ Category A - As long as the user has an account with us
・ Category B - As long as the user has an account with us
・ Category C - As long as the user has an account with us
・ Category G - As long as the user has an account with us
We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
Receiving help through our customer support channels;
Participation in customer surveys or contests; and
Facilitation in the delivery of our Services and to respond to your inquiries.
How do we use and share your personal information?
Learn about how we use your personal information in the section, "HOW DO WE PROCESS YOUR INFORMATION?"
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal
information to in the section, "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered
to be "selling" of your personal information.
We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share
personal information in the future belonging to website visitors, users, and other consumers.
California Residents
California Civil Code Section 1798.83, also known as the "Shine The Light" law permits our users who are California residents to request and obtain from us, once a year and free of charge,
information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared
personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the
contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the
Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that
you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all
our systems (e.g., backups, etc.).
CCPA Privacy Notice
This section applies only to California residents. Under the California Consumer Privacy Act (CCPA), you have the rights listed below.
The California Code of Regulations defines a "residents" as:
(1) every individual who is in the State of California for other than a temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose
All other individuals are defined as "non-residents."
If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.
Your rights with respect to your personal data
Right to request deletion of the data — Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain
exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any
processing that may be required to protect against illegal activities.
Right to be informed — Request to know
Depending on the circumstances, you have a right to know:
・ whether we collect and use your personal information;
・ the categories of personal information that we collect;
・ the purposes for which the collected personal information is used;
・ whether we sell or share personal information to third parties;
・ the categories of personal information that we sold, shared, or disclosed for a business purpose;
・ the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
・ the business or commercial purpose for collecting, selling, or sharing personal information; and
・ the specific pieces of personal information we collected about you.
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual
data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Right to Limit Use and Disclosure of Sensitive Personal Information
We do not process consumer's sensitive personal information.
Verification process
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require
us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you
to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g.,
phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information
from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for
the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
Other privacy rights
・ You may object to the processing of your personal information.
・ You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
・ You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have
been validly authorized to act on your behalf in accordance with the CCPA.
・ You may request to opt out from future selling or sharing of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly
possible, but no later than fifteen (15) days from the date of the request submission.
・ To exercise these rights, you can contact us by submitting a data subject access request, by email at support@phiaton.com, by calling toll-free at 1-866-313-3203, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.
Colorado Residents
This section applies only to Colorado residents. Under the Colorado Privacy Act (CPA), you have the rights listed below. However, these rights are not absolute, and in certain cases we may
decline your request as permitted by law.
・ Right to be informed whether or not we are processing your personal data
・ Right to access your personal data
・ Right to correct inaccuracies in your personal data
・ Right to request deletion of your personal data
・ Right to obtain a copy of the personal data you previously shared with us
・ Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly
significant effects ("profiling")
To submit a request to exercise these rights described above, please email support@phiaton.com or submit a data subject access request.
If we decline to take action regarding your request and you wish to appeal our decision, please email us at support@phiaton.com. Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.
Connecticut Residents
This section applies only to Connecticut residents. Under the Connecticut Data Privacy Act (CTDPA), you have the rights listed below. However, these rights are not absolute, and in certain cases
we may decline your request as permitted by law.
・ Right to be informed whether or not we are processing your personal data
・ Right to access your personal data
・ Right to correct inaccuracies in your personal data
・ Right to request deletion of your personal data
・ Right to obtain a copy of the personal data you previously shared with us
・ Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly
significant effects ("profiling")
・ To submit a request to exercise these rights described above, please email support@phiaton.com or submit a data subject access request.
If we decline to take action regarding your request and you wish to appeal our decision, please email us at support@phiaton.com. Within sixty (60) days of receipt of an appeal, we will inform you
in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.
Virginia Residents
Under the Virginia Consumer Data Protection Act (VCDPA):
"Consumer" means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or
employment context.
"Personal data" means any information that is linked or reasonably linkable to an identified or identifiable natural person. "Personal data" does not include de-identified data or publicly available
information.
"Sale of personal data" means the exchange of personal data for monetary consideration.
If this definition of "consumer" applies to you, we must adhere to certain rights and obligations regarding your personal data.
Your rights with respect to your personal data
・ Right to be informed whether or not we are processing your personal data
・ Right to access your personal data
・ Right to correct inaccuracies in your personal data
・ Right to request deletion of your personal data
・ Right to obtain a copy of the personal data you previously shared with us
・ Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly
significant effects ("profiling")
Exercise your rights provided under the Virginia VCDPA
You may contact us by email at support@phiaton.com or submit a data subject access request.
If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
Verification process
We may request that you provide additional information reasonably necessary to verify you and your consumer's request. If you submit the request through an authorized agent, we may
need to collect additional information to verify your identity before processing your request.
Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional
days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.
Right to appeal
If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at support@phiaton.com.
Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the
decisions. If your appeal is denied, you may contact the Attorney General to submit a complaint.
12. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: You may have additional rights based on the country you reside in.
Australia and New Zealand
We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (Privacy Act).
This privacy notice satisfies the notice requirements defined in both Privacy Acts, in particular: what personal information we collect from you, from which sources, for which purposes,
and other recipients of your personal information.
If you do not wish to provide the personal information necessary to fulfill their applicable purpose, it may affect our ability to provide our services, in particular:
・ offer you the products or services that you want
・ respond to or help with your requests
・ manage your account with us
・ confirm your identity and protect your account
At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section
"HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?"
If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian
Information Commissioner and a breach of New Zealand's Privacy Principles to the Office of New Zealand Privacy Commissioner.
Republic of South Africa
At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section
"HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?"
If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the office of the regulator, the details of which are:
The Information Regulator (South Africa)
General enquiries: enquiries@inforegulator.org.za
Complaints (complete POPIA/PAIA form 5): PAIAComplaints@inforegulator.org.za & POPIAComplaints@inforegulator.org.za
13. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible.
If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review
this privacy notice frequently to be informed of how we are protecting your information.
14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at support@phiaton.com or contact us by post at:
Cresyn Co.,Ltd
5 Gangnam-daero 107-gil, Seocho-gu
Seoul 06524
South Korea
15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to
review, update, or delete your personal information, please fill out and submit a data subject access request.
This privacy policy was created using Termly's Privacy Policy Generator.