PL4Y Privacy Policy

1. Overview

• PL4Y places the highest priority on the protection of users' personal information and designs, builds, and operates its services and products on this basis. We strive to enable users to form meaningful connections with peace of mind, and all personal information provided is managed through a rigorous security system.
• PL4Y collects only the minimum personal information necessary to provide the Service and makes multifaceted efforts to protect user privacy, including preventing the excessive collection of information.
• This Privacy Policy clearly explains how user information is collected, used, shared, and protected across PL4Y's websites, application, events, and other services.
• PL4Y may amend this Privacy Policy, and any changes will be announced through in-app notices or push notifications no less than seven (7) days prior to the effective date. In the case of amendments that are materially adverse to users, no less than thirty (30) days' advance notice will be given.
• PL4Y's Service is intended for adult users aged 18 years and older. If a user is confirmed to be under the age of 18, the relevant account will be immediately deleted and all collected personal information will be destroyed.

2. Scope of Application

• This Privacy Policy applies to all websites, applications, events, and other services operated by PL4Y. Certain services may have separate privacy policies, in which case those policies shall take precedence.

3. Information We Collect

• PL4Y collects various categories of information in order to provide the Service and recommend meaningful connections to users.
• In the course of using the PL4Y Service, you may provide certain information, including:
  • Information required upon account creation: name, phone number, gender, date of birth, password, etc.
  • Information required for profile creation: nickname, preferences, region, experience, play style, photos, etc. (Note: information related to sexual preferences and play style constitutes sensitive personal information under Article 23 of the Personal Information Protection Act and is collected only upon separate and explicit consent.)
  • Payment information when using paid services
  • Information provided when participating in surveys or events
  • Information provided when contacting customer support
  • Chat content between you and other members, and content you post
• In the course of using the PL4Y Service, information about you provided by third parties may also be collected, including:
  • Information about you provided by other members
  • Information from advertising partners (e.g., marketing campaign results)
  • Information regarding individuals identified or suspected as problematic members
• The following information is generated or automatically collected when you use the Service:
  • Manner of Service use (usage time, feature usage records, activity records, information viewed, referring web page addresses, advertisements clicked)
  • User activity data regarding interactions with other members
  • Device information (e.g., IP address, device ID, application settings, cookies)
  • Access logs (IP address, date and time of access, service usage records, etc.) — retained for three (3) months pursuant to the Protection of Communications Secrets Act
  • Identity verification data (e.g., name, contact information, date of birth, gender)
  • Location information (e.g., latitude and longitude of the user's device). Octave Ltd. is registered as a location-based service provider pursuant to the Act on the Protection, Use, Etc. of Location Information (Registration No. 1244). Location information may differ from the user's actual location depending on the device, network environment, and GPS signal conditions, and the Company does not guarantee the accuracy of the location information collected.
• The legal basis for the collection of personal information is classified as follows pursuant to Article 15 of the Personal Information Protection Act:
  • Information essential to the provision of the Service (name, phone number, date of birth, gender, etc.): Article 15, Paragraph 1, Item 2 (performance of a contract)
  • Optional information for profile creation and personalized services: Article 15, Paragraph 1, Item 1 (consent of the data subject)
  • Automatically collected information such as IP addresses and access logs: Article 15, Paragraph 1, Item 6 (legitimate interest — security and service operation)
  • Information for compliance with statutory obligations: Article 15, Paragraph 1, Item 3 (compliance with a legal obligation)

4. Purpose of Use

• PL4Y collects mandatory information for member registration, smooth customer support, and the provision of specialized services, as well as optional information to provide personalized services and various other services.
• PL4Y uses the collected information for the following purposes:
  • Service Provision: Creating and managing profiles, connecting with other users, providing chat functionality, processing payments, providing customer support
  • Personalized Services: Providing personalized content and advertisements, offering recommendation features
  • Service Improvement: Analyzing and improving the Service, developing new features
  • Safety and Security: Fraud prevention, blocking problematic members, compliance with legal obligations, disclosure to investigative authorities upon lawful request in connection with crimes or other serious matters
  • Research and Development: Market research, development of new services

5. Sharing of Information

• Where PL4Y entrusts the processing of personal information to third parties, PL4Y clearly stipulates in the relevant agreements that the data processor must handle personal information securely in accordance with the Personal Information Protection Act, and PL4Y maintains such agreements in written or electronic form and provides oversight and supervision.
• PL4Y may share user information in the following circumstances:
  • With service providers (data processors) for the purpose of providing the Service (see table below)
  • Where required by law or where requested by investigative authorities through lawful procedures for investigative purposes

• Entrusted processing by data processors located outside of the Republic of Korea is separately described in the "International Transfer of Personal Information" section.

6. User Rights and How to Exercise Them

• Pursuant to Articles 35 through 38 of the Personal Information Protection Act, users may exercise the following rights:
  • Right of Access (Article 35): You may confirm whether and how your personal information is being processed.
  • Right to Rectification and Erasure (Article 36): You may request the correction or deletion of inaccurate or incomplete personal information.
  • Right to Restriction of Processing (Article 37): You may request a temporary suspension of the processing of your personal information. However, requests may be refused where there are legitimate grounds such as compliance with statutory obligations, in which case you will be notified of the reason.
  • Right to Withdraw Consent: You may withdraw your consent to the processing of personal information at any time.
• You may exercise your rights through the following methods:
  • You may directly modify or delete your information through the profile and account settings within the app.
  • You may permit or deny the collection of certain types of data and notifications, such as photos and push notifications.
  • You may immediately terminate the collection of your account and related information by using the membership withdrawal function.
  • You may request access, rectification, erasure, or restriction of processing through the in-app inquiry function or by email at us-help@pl4y.app. PL4Y will notify you of the outcome of your request within ten (10) days of receipt.
• PL4Y may conduct identity verification procedures before responding to rights exercise requests.
• Requests relating to the personal information of other members require the consent of the relevant member.
• Requests for restriction of processing may be refused where there are legitimate grounds, such as compliance with statutory obligations or the protection of the life, body, or property of another person, in which case you will be notified of the reason.

7. Retention and Destruction of Personal Information

• PL4Y retains information for legal data retention obligations, legitimate business interests, and unresolved or potential issues, claims, or disputes.
• Accounts for which user activity has not been detected for an extended period are not automatically deleted.
• Following account deletion or suspension, only your phone number and certain post and comment data are retained for the purpose of preventing fraudulent registration or use and responding to disputes, and are destroyed five (5) years after the date of withdrawal. (This period is identical to the maximum permanent restriction period (up to five (5) years) under the Terms of Service.)
• Where the Company imposes a permanent suspension due to a serious violation of the Terms of Service, use of the Service is restricted immediately; however, the relevant personal information is not destroyed during the appeal period (seven (7) days from the date of the restriction). If the appeal period expires or the appeal is rejected, the account is subject to forced withdrawal, and the relevant personal information is destroyed thirty (30) days after the end of the appeal period (or, where the appeal is rejected, the date of the rejection notice). However, information retained for purposes such as preventing fraudulent registration or use, as set forth in this section, remains subject to its respective retention period.
• The mandatory retention periods under applicable law are as follows:
  • Records relating to contracts or withdrawal of offers: 5 years (Act on Consumer Protection in Electronic Commerce)
  • Records relating to payment and supply of goods: 5 years (Act on Consumer Protection in Electronic Commerce)
  • Records relating to consumer complaints or dispute resolution: 3 years (Act on Consumer Protection in Electronic Commerce)
  • Access records (including IP addresses and access logs): 3 months (Protection of Communications Secrets Act)
  • Records relating to labeling and advertising: 6 months (Act on Consumer Protection in Electronic Commerce)
  • Books and supporting documents relating to all transactions prescribed by tax law: 5 years (Framework Act on National Taxes)
• The procedures and methods for the destruction of personal information are as follows:
  • Destruction Procedure: Personal information whose retention period has expired or whose collection and use purpose has been fulfilled is destroyed without delay. Where retention is required by law, the information is transferred to a separate database and destroyed upon expiration of the statutory period.
  • Electronic Files: Permanently deleted using technical means that render recovery impossible.
  • Personal Information in Paper Form: Destroyed by shredding or incineration.

8. How to Contact Us

• If you have any questions regarding this Privacy Policy, please contact us through the following methods:
  • You may submit an inquiry easily and quickly through the in-app inquiry function. After submitting your inquiry, you will receive a response within five (5) days.
  • You may send an email directly to our customer support team at us-help@pl4y.app, and you will receive a response within five (5) days.
• When submitting an inquiry, please write clearly and concisely, and attach any relevant information needed to resolve the issue (e.g., account information, screenshots) to receive a prompt and accurate response.

9. International Transfer of Personal Information

PL4Y transfers users' personal information outside of the Republic of Korea for the purposes of providing the Service and storing data, as set forth below.

To ensure the safe processing of personal information, PL4Y has entered into separate agreements regarding the processing and security of personal information with the above recipients and provides ongoing oversight and supervision. The above recipients hold international security certifications such as ISO/IEC 27001 and SOC 2, and PL4Y complies with Article 28-8 of the Personal Information Protection Act to ensure that users' personal information is safely stored and processed outside of the Republic of Korea.

You may refuse the international transfer of your personal information. However, as such transfers are essential to the provision of the Service, refusing the transfer may restrict your use of the Service. Requests to refuse international transfer may be submitted to our customer support email at us-help@pl4y.app.

10. Personal Information Protection Officer

• Pursuant to Article 31 of the Personal Information Protection Act, PL4Y has designated a Personal Information Protection Officer to oversee all matters relating to the processing of personal information and to handle inquiries and complaints from users regarding their personal information.

• The Location Information Protection Officer under the Act on the Protection, Use, Etc. of Location Information is the same person as the Personal Information Protection Officer (Junhyuck Choi) listed above.
• Users may contact the Personal Information Protection Officer with any inquiries, complaints, or requests for remedies relating to personal information protection arising in connection with the use of the PL4Y Service.
• For additional assistance regarding personal information, you may contact the following authorities:
  • Personal Information Protection Commission: www.pipc.go.kr / Helpline: 182
  • Korea Internet & Security Agency – Privacy Violation Report Center: privacy.kisa.or.kr / Helpline: 118
  • Supreme Prosecutors' Office – Cybercrime Investigation Division: www.spo.go.kr / Helpline: 1301
  • National Police Agency – Cyber Investigation Bureau: ecrm.cyber.go.kr / Helpline: 182

11. Cookie Policy

• PL4Y uses cookies to improve the user experience of its website and application services and to provide personalized services. Cookies are small data files stored by the Service's web server on your browser or device.
• PL4Y uses cookies for the following purposes:
  • Maintaining login status and managing sessions
  • Analyzing Service usage statistics and improving the Service
  • Delivering personalized content and advertisements
  • Detecting security threats and preventing fraud
• You may permit or refuse cookie storage through your browser settings. However, refusing cookies may restrict certain Service features, such as maintaining your login session.
• Cookie configuration instructions by browser are as follows:
  • Chrome: Settings → Privacy and Security → Cookies and other site data
  • Safari: Preferences → Privacy → Cookies and website data
  • Firefox: Settings → Privacy & Security → Cookies and Site Data

12. Governing Law and Dispute Resolution

• This Privacy Policy shall be interpreted and governed by the laws of the Republic of Korea.
• In the event of any dispute between PL4Y and a user arising in connection with this Privacy Policy, the parties shall first endeavor to resolve such dispute amicably through mutual consultation.
• If the dispute cannot be resolved through consultation, either party may file a claim with the competent court pursuant to the Civil Procedure Act of the Republic of Korea. The Seoul Western District Court, which has jurisdiction over the location of PL4Y's principal place of business in Mapo-gu, Seoul, shall be the court of agreed jurisdiction.

13. Notification of Changes to This Privacy Policy

• PL4Y may amend this Privacy Policy in response to changes in applicable law or the Service.
• Any amendments to this Privacy Policy will be announced through in-app notices or push notifications no less than seven (7) days prior to the effective date.
• In the case of amendments materially adverse to users (e.g., addition of categories of information collected, changes to the purpose of use, extension of the retention period), no less than thirty (30) days' advance notice will be given, with a clear comparison of the content before and after the change.
• Prior versions of this Privacy Policy may be obtained by submitting a request to our customer support email at us-help@pl4y.app.