BUGSCRAFT

TheOne pixel Mobile Service Private Information Policy

One pixel (the Company) shall protect a user’s private information and abide by ‘the encouragement of internet network use and protection of private information’, ‘Privacy protection act’ that related organizations establish for protection of an User’s right.

The Company would inform users how their private information shall be used hereby and how the Company makes efforts by the One pixel Mobile Service Private Information Policy.

Article 1. Purpose of Private Information Collection

The Company shall collect optional/essential information for provision of the Service after acquirement of a user’s agreement with following purposes.

Under the information shall be gathered when users shall submit their information on events / marketing programs or the use of the Service.

Classification	Purpose	Essential/ optional	Collection
Membership Join	Membership Join	Essential	Onepixel	Name (if a nickname exists, a nickname may be replaced)
			Facebook	Name (if a nickname exists, a nickname may be replaced), Profile Image URL (If a user reveals the image), Facebook friends list, date of birth, nationality, Locale, Gender
			Google	GooglePlus ID, Profile, Nickname
			Apple	Apple Game Center ID, Profile, Nickname
			Naver	Naver ID
User verification	User confirmation	Essential	Name, birth of date, gender, nationality, telecommunication company, phone number, connection information (CI), double information (DI)
	Legal representative confirmation	Essential	birth of date, gender, nationality, telecommunication company, phone number, connection information (CI), double information (DI)
		Optional	legal representative ID
Events	Events Participation	Optional	SNS ID Email address, phone number, SNS ID
	Double Participation Check	Optional	Advertisement identifier, service record, Cookie
	Giveaway Shipment	Essential	Name, Phone number, Address
	taxes and the public utilities charge	Essential	Name, Phone number, Address, Account Number, name of back, depositor
Marketing	New Service Notification and Brochure	Optional	Email Address, Phone number, SNS ID
	Customized Advertisement	Optional	Advertisement Identifier, Service Record, Cookie
Customer Counseling	User Identification and contacts	Essential	Email Address, Contact Address (Mobile number, phone number)
	Confirmation on Counseling Contents	Optional	ID, Name, Nick Name, Necessary Information for Counseling
Provision of Service	Location Information	Optional	location information check
	Related Information	Essential	Service record, Connection log, payment record, IP address, Mobile Phone number, Mobile Model Name, Telecommunication Company information, OS information and version, Equipment Identifier, Language and region information in Terminals.

Payment and refund shall be processed through payment service of the Google and Applestore and the Company shall neither collect nor provide payment information.

Article 2. Provision of private information to the third parties.

The Company shall neither open nor provide users’ private information to third parties without permission.

However, the following are exceptional cases to be allowed.

1) If a User agrees to open or provide privacy in advance

2) If there is duty submitting private information in accordance to related laws.

(If there is legal obligation submitting documentation or court, investigative agencies, administrative agencies make request by due process of law.)

3) if private information is necessary for calculating charge of the Service.

4) If private information is necessary for statistics figures, academic research, or market research where a certain individual shall not be identified.

Article 3. Private Information Entrustment

The Company shall commit private information processing as the following for providing gaming services and improving convenience and enacting provisions for managing private information safely upon the contract of consignment.

The Company’s Consignment organization and details of it job are as follows.

Consignment	Consignment jobs
Junny soft	Game Service Operation and support customer counseling.

Article 4. Private information Preservation and Period of Using Information.

The Company shall preserve or use a user’s private information only during the valid period notified to customers and destruct the information when a userwithdraws from the agreement, the valid term expires, or when the purpose is achieved.

Users who don’t have a service or log in record 1 year after the final log in, the service contractmay be terminatedand private information will be deleted in accordance to relative policies. In this case, the Company shall inform Users the end date of the preservation period and private information. Provided that Users continue to use Onepixel’s service, it is recommended for users to log in in 1 year after the final log in.

The Company shall preserve a Member’s name, phone number that are acquired during membership subscriptionfor a maximum of 14 days and ID, which may be used for affiliated services, in 30 days from the day of releasing private information and then delete information in a way that cannot be restored. However, there are exceptional case considered as follows.

The private information shall be preserved for the duration specified in the “preservation basis” and relative laws.

1) Information gathered for Events and Marketing

- The Company shall preserve information for 3 months after purpose is achieved.

(The preservation period may be differing and the period specified herein shall be applied)

2) If the Company shall preserve private information for a certain period by related laws.

Related laws	Information Collection	Preservation Period.
Act on the Encouragement of Information Network System and Protection of Privacy	Log in Information	1 year
Communications Privacy Act	Information regarding the use of Service	3 months
Ecommerce Consumer Protection Law	Information filing and solving consumer complaints	3 years
	Information aboutjoining and cancelling Contracts	5 years
	Information regarding cost settlement and supply of goods	5 years
National Tax Basic Laws	ledgers and documentary evidence of taxes	5 years

Article 5. Destruction of personal information and Procedure.

An User’s private information shall be destructed as soon as the purpose of information is achieved and the destruction procedure and method are as follows.

1) Destruction procedure

The Company shall preserve private information submitted for membership subscription during the period specified in related laws and the Company policy and destructs the private information.

2) DestructionMethod

①physical copy: Use of a paper grinder or a paper incinerator.

②Electronic file: Delete records in a way that cannot be restored.

Article 6. A Member and Legal Representative’s Exercise of Right

A member and legal representative may cancel the agreement of providing personal information (close their personal account). They may click “close my account” or “delete my account” for withdrawal of a motion. Furthermore, Users including children under 18, may exercise legal right of private record query and amendment.

The Company shall take action when questions are sent by means of letters, 1:1 chatting of Contents, or Mobile Customer Service 1:1 chatting (http://www.bugscraft.net).

The Company shall neither provide nor use private information until correction is made upon errors that are claimed by Members. Furthermore, if incorrect private information is given to third parties, the Company shall inform the third party of such corrected information.

Children under 14 (Children) shall acquire a legal representative’s agreement before his or her private information is collected. A legal representative’s information will be used in the purpose of customer service checking agreement and reading a private information and correction etc.

The Company shall notify or explain fair reasons of rejection when part of or the whole private information is asked to revise.

Article 7. Service Record Analysis.

The Company uses Advertisement identifier and analyzing software for offering the better quality of service.

Advertisement Identifier modifies set up environment in mobile as impermanent and impersonalized identifier such as Android Advertisement ID, Apple Advertising ID.To present advertisement based on people’s interest, Advertisement Identifier may be rejected and reset. However, it shall not be used to identify individual customers.

Analysis software may be used to analyze automatically formed information while using mobile service or visiting web platform and users may reject to use analysis software.

①Rejection of Advertisement Identifier Collection

■For Android, [Set Up->Google>Advertisement] or [Set Up->General->Account and Synchronization -> Google->Personal Information and Personal Information Protection ->Advertisement Set Up]

■For IOS, [Set Up->Personal Information-> Advertisement]

②Rejection of Service Record Analysis

■For Internet Explorer, “Tool” upper menu of a web browser > “Safety” menu > “Turn On Do Not Track”

■For Chrome, “ " upper right icon of a web browser > Choose “Set Up” >Choose “Advance Setup” at the bottom of screen > Choose “Transmit Request ‘No Tracking’ due to web traffic.

Article 8. Technical / Managerial/ PhysicalPrivate Information

The Company shall carry out technical and administrative alternatives for preventing identity theft including loss, leakage, and damageof private information. However, the Company is not liable for any information loss incurred from a member’s carelessness.

1) Technical Alternatives.

①The Company shall preserve and encode a private information specified in related laws and confirmation and modification is possible only when a Member makes a request.

②The Company shall transmit private information safely in a network via cryptographic communication.

③The Company establishes and updates the system regularly in a restricted area equipped with around the clock surveillancetechnologically and physically to prevent any lossor damage of private information via hacking and computer viruses.

④The Company backs up a private information regularly for and emergencies and takes precautions against possible accidents by using a vaccine program.

⑤Company grants, changes, terminates the right to access with a regular examination and controls unauthorized access internally and externally by network level firewall system

2) Managerial Alternatives

①The Companylimits the least number of people who have accessto private information and those who are entitled to do so are as follows.

■Those in marketing, customer service, and make direct shipments to customers.

■Those who are in charge of private information protection including the person in charge

■Thosewhose job is related to handling personal information

②The Company keeps the duty of private information protection on update for private information handlers and trustees.

③The Company establishes internal managerial plans for handling information at the department, which holds exclusive charge in handling private information. Provided that problems are discovered by regular inspection, the Company maximizes its power to set it right.

3) Physical Alternatives

①Entrance and exit Control upon unauthorized person

The Company designated a storage place and established entrance and exit control procedure.

②Locking Device for Document Security.

The Company preserves documentation and additional storage media in a secure place which is equipped with locking device.

Article 9. The Person in charge and a responsible department for handling private information.

The Company specifies the person in charge and a department to hold responsibility for handlingprivate information to claims related to private information.

private information protection

Name / Department: Kim Kyung Suk / Operate Planning Department

Phone: 070-4231-3743

Email:privacy-help@1pxsft.com

Article 10. Duty of Notification

The Company informs customers of anyamendments to be placed 7days before such amendment is carried out via “Notification,” and if such amendment is disadvantageous to customers, a notice is made 30 days before the amendment is carried out.

<Supplementary Provisions>

This policy shall be carried out from December, 28th in 2017.

All contents included in the user’s agreement (privacy policy) follows the Korean user’s agreement published in the 2017 Bugscraft game and the Bugscraft website for the legal/non-legal dispute between the distributing One Pixel Co., Ltd. and the user, the conflict of interest for any language used in the user’s agreement, and the standard to interpret any service (with charge and free of charge) provided by One Pixel.

Private Information Policy Private Information Policy