Privacy Policy

Applies to: Shashot and Shot Trainer

Underpara Lab Co., Ltd. ("Company") maintains this unified Privacy Policy in connection with the Shashot and Shot Trainer applications and related services (collectively, the "Services"), in compliance with the Personal Information Protection Act, the Act on Promotion of Information and Communications Network Utilization and Information Protection, the Protection of Communications Secrets Act, the Telecommunications Business Act, and other applicable laws. The Company will announce any revision of this Privacy Policy through in-app notices or website notices.

Article 1 [Purposes of Processing Personal Information]

1. Member management — verifying intent to register, identity authentication, age verification, confirming consent of legal guardians for users under 14, sending notices, preventing fraudulent use, and preserving records for dispute resolution.
2. Complaint handling — verifying identity, confirming the substance of complaints, conducting fact-finding, and notifying users of outcomes.
3. Provision of goods or services — delivering content, providing personalized services, processing payments and settlements, and conducting financial authentication.
4. Service development and marketing/advertising — developing new features, delivering event and promotional information, demographic-based service delivery, measuring service effectiveness, and analyzing access frequency.
5. Fraud prevention — preventing abuse such as duplicate point claims upon re-registration.
6. On-device content — with your consent, accessing text, images, and videos in your clipboard.
7. Purchase information — when you subscribe or purchase content, collecting payment card information, billing/shipping/contact information, and details of purchased items.
8. Image, video, audio, and sensor data — to provide service features such as Shashot's shot trajectory analysis and Shot Trainer's swing/posture analysis, the Company may collect and process images, videos, audio, and (with permission) motion sensor data such as gyroscope and accelerometer readings from your user content.

Article 2 [Categories of Data Collected]

1. Upon registration and use

• Required: name, gender, contact (email, phone), ID and password, for users under 14 the legal guardian's information, service usage records, chat message contents.
• Optional: address, payment information, customer inquiry information, golf-related profile such as handicap and years of experience.

2. During service use

• Required: usage records, access logs, cookies, IP address, videos and images produced through the Services, swing/shot analysis results.

3. During payment

• Card payments: transaction records, card number, expiry date, etc.
• Bank transfers: transaction records, bank, account number, account holder.
• In-app purchases (IAP): payment data processed under Apple App Store / Google Play policies.

Article 3 [Retention Period]

1. Personal information is processed and retained within the retention/use period consented to at the time of collection.
2. Information for registration, service provision, complaint handling, and marketing is in principle retained until the member withdraws.
3. Retention periods required by applicable laws:
   • Records on display/advertising: 6 months
   • Consumer complaints or dispute records: 3 years
   • Records on contracts, withdrawal, payment, supply of goods: 5 years
   • Electronic financial transaction records: 5 years
   • Communication confirmation data (IP, etc.): 3 months

Article 4 [Entrustment of Processing]

Article 5 [Provision to Third Parties]

The Company does not provide your personal information to third parties without your consent, except where governmental authorities request the information in accordance with procedures prescribed by law.

Article 6 [Rights of the Data Subject]

1. You may request access to, correction of, deletion of, or suspension of processing of your personal information.
2. Such requests may be made in writing or by email, and the Company will act without undue delay.
3. You can view, correct, or delete your personal information through features within the Shashot or Shot Trainer app.

Article 7 [Destruction of Personal Information]

1. Procedure — destroyed without undue delay once the processing purpose is achieved. Where retention is required by law, the data is moved to a separate database and destroyed after the legal period.
2. Method — electronic files are permanently deleted using methods that prevent recovery; printed materials are shredded or incinerated.

Article 8 [Automatically Collected Information]

1. Cookies — used to provide personalized service. You can disable cookies through your browser's settings.
2. Personalized advertising — behavioral data is collected and processed by Meta (Facebook/Instagram), Google, Naver, and Kakao.

Article 9 [Security Measures]

1. Minimizing and regularly training staff who handle personal information.
2. Encryption of passwords and sensitive data at rest and in transit.
3. Access control to databases containing personal information.

Article 10 [Data Protection Officer]

Article 11 [Remedies for Infringement]

1. Personal Information Infringement Reporting Center (KISA): privacy.kisa.or.kr / 118
2. Personal Information Dispute Mediation Committee: kopico.go.kr / 1833-6972
3. Supreme Prosecutors' Office Cyber Investigation Division: 02-3480-3573
4. Korean National Police Agency Cyber Bureau: 182

Article 12 [Changes to This Privacy Policy]

This Privacy Policy is effective as of March 21, 2024. Material changes will be announced through in-service notices.

Article 13 [Account and Data Deletion]

1. In-app deletion — you can delete your account directly from the Shashot or Shot Trainer app via [My Page] → [Settings] → [Delete Account]. Personal data linked to your account will be deleted without undue delay, except data we are legally required to retain.
2. Out-of-app deletion request — send an email to support@underparlab.com with the subject "Data Deletion Request", including the email address or user ID used to sign up, your nickname (if any), the login method/platform, and which app (Shashot or Shot Trainer) you are requesting deletion for.
3. Processing time — we will complete deletion within 30 days of receiving your request and send a confirmation email.
4. Note — uninstalling the app alone does not delete the account or data stored on our servers. You must use the procedures above.