BYSNAP Privacy Policy

BYSNAP Store, an Internet shopping mall service operated by Invincible Ventures, Inc. (hereinafter referred to as the "Invincible Ventures"), considers the protection of the customers’ personal information paramount and makes the best effort to protect the customers’ privacy.

BYSNAP Store complies with the provisions concerning the protection of personal information under any applicable laws and regulations regarding information and communications service providers, including the Telecommunications Security Protection Act, the Telecommunications Business Act, the Act on Promotion of Information and Communications Network Utilization and Information Protection, etc., the Personal Information Protection Act and its Enforcement Decree. In accordance with applicable laws,
Invincible Ventures has established this Privacy Policy (the"Policy"), which is disclosed in its homepage and mobile application (https://by-snap.com/) hereinafter referred to as "Homepage") for customer access.

This Policy may be, from time to time, revised according to amendments in relevant laws and regulations. In the event of any revisions or changes to this Policy, Invincible Ventures makes such changes on this page and where appropriate, will notify such changes to you by email to the email address you used for Member registration. Users are required to check for such revisions when visiting the BYSNAP Store mobile application.

Purpose of Collecting and Using Personal Information

Invincible Ventures collects and uses the personal information of BYSNAP Store users for the following purposes:

Classification	Purpose of Use
User management	◦ To identify members for providing membership services ◦ To prevent misuse by an unauthorized user ◦ To confirm user registrations ◦ To keep record for consultations, complaint handling procedures, and dispute settlements ◦ To deliver notices ◦ To prevent unauthorized use of ID ◦ To prevent fraudulent transactions
Execution of an agreement concerning service provision and payment	◦ To provide media contents and delivery updates ◦ For identity verification relating to financial transactions and financial services ◦ To send invoices, purchase and payment procedures, collection of payment notices
Marketing and advertisement	◦ To provide customized services for users ◦ To develop and specialize new services (products) ◦ To provide services and useful information for users ◦ For user analysis of BYSNAP Store services and products ◦ To send periodicals and notifications about new products or services ◦ To plan services and events corresponding to the user’s area of interests ◦ To conduct consumer research activities

Personal Information Collected

Invincible Ventures collects only the information required for providing the basic services. It obtains consent from users when collecting the necessary information for providing service. Even when users do not provide optional information, there are no restrictions on their use of service.

Invincible Ventures does not collect any sensitive personal information that may infringe the human rights of users (i.e., race, ideology, creed, political tendency, criminal records, health condition, sexual life, etc.) Under any circumstances, Invincible Ventures does not use or disclose to a third party the users’ information that did not obtain their consents in advance.

Invincible Ventures collects and uses personal information as follows:

Type	Category	Information collected/used
Mandatory	Sign-up & verification	Email address, password, phone number
	Registering through social accounts (Google, Apple)	Google	Name, Email address
		Apple	Name, Email address
	Purchasing products	Information of the purchaser (name, phone number, email address), Information of the recipient (name, phone number, address).	We use third-party payment processors, such as Stripe, to process your payments. These third parties will collect the information necessary to effectuate your transaction with us, such as credit/debit card number, security/CVV code, and expiration date. Our payment processors may handle your payment information in accordance with their own privacy policies. We do not have access to your full payment information.
	Use of service	IP address, device personal interests, cookies or other information tracking devices (together, “Information Collection Device”), date of visit to BYSNAP Store, service usage record, abnormal service usage record
Optional	Product review	Body size (height, weight, etc.), gender
	Marketing/advertising- The development of new services and products and the provision of customized services- Demography-based service and advertising posting	Date of birth, Preference
Research activities (i.e. surveys, interviews)	- Information that you give us when you agree to participate in any of our research activities, such as surveys or interviews. Information can include your name, location, email address, age, date of birth, gender, phone number and shopping preferences. - Your responses, audio and/or video recordings of surveys, interviews, workshops, device screenshots, and other information you choose to give by corresponding with us.

We may derive information or draw inferences about you based on information we collect about you. For example, we may use your browsing or purchasing history to determine your shopping preferences, or your IP address to estimate your general location.

We may collect other information that is not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Methods of Collecting Personal Information
Invincible Ventures collects personal information through the sign-up (registration) process, consultation, Help Center records, sales agencies or partner companies, consumer research activities, as well as through information collection tools (Information Collection Device) on mobile phones and wired/wireless internet services.

Personal Information Storage Period and Its Use
1. Invincible Ventures shall maintain and use the user’s personal information for the period which was notified by Invincible Ventures and agreed by the customer. The BYSNAP Store users’ personal information is destroyed after any of the following three: achieving the purpose of its collection and use, expiration of the information withholding period, or withdrawal of user’s consent.
1. BYSNAP Store reserves the right to possess the personal information of its Members for a certain period to confirm transaction-related rights or obligations in accordance with applicable laws and regulations as follows.
  - Records regarding execution of agreements or withdrawal of subscriptions, etc.: Five (5) years
  - Records regarding payment and provision of goods, etc.: Five (5) years
  - Records regarding consumer complaints or dispute resolution: Three (3) years
  - However, if the usage agreement between the member and Invincible Ventures is maintained (member has not withdrawn membership), the time information is stored may be longer than indicated above. Records of which the data storage period has passed shall be destroyed upon customer’s withdrawal of consent.
1. In the event any Member requests to inspect the transaction of the information Invincible Ventures acquired through the user’s permission, Invincible Ventures shall take necessary measures for the Member to inspect such information.
1. If a member has no record of using the service for one year, the personal information of such user shall be stored separately, and the user shall be notified separately.

International Data Transfer
1. Invincible Ventures may transfer and access the information it collects about you from United States and other countries in accordance with applicable laws. Please note that the laws of these countries may differ from those of your home jurisdiction. If you do not wish for your information to be collected and stored outside of your home jurisdiction, we recommend that you refrain from providing such information through our websites.

Use of the Collected Personal Information and Provision of such Information to a Third Party

Limited Domain of Personal Information Usage
1. Invincible Ventures shall use the personal information of users within the scope notified in the sign-up form and “Purpose of Collecting and Using Personal Information” under the Policy, and shall neither use it exceeding such scope nor provide it for other persons, companies, or institutions. However, requests made with consent of the customer and in accordance with procedures set by the law shall be excepted. In such case, personal information may be used and provided with due care.

Consent to Provide Personal Information to a Third Party

Recipient of personal information	Purpose of using personal information by the recipient	Personal information provided	Personal information storage and usage period by the recipient
Seller / Korea	Handling customer consultations and complaints	Name, address, contact information, email address	3 months after confirmation of purchase

When provision of personal information to a Third Party occurs, BYSNAP Store takes measures to notify the user and seek their consent in advance.

Users may refuse to provide their personal information to a third party. The refusal, however, may affect their membership registration and use of services.

Provision of Information to Both Parties
1. In the event any transaction is realized through services provided by BYSNAP Store, the necessary information relating to the transaction and delivery shall be provided to both parties.

Access to Personal Information
1. The access to personal information may change depending on the beginning or end of partnerships, and such changes shall be added to the list of partners upon provision of personal information and deleted from the list upon destruction of personal information due to end of the partnership, etc.

Inspection and Correction of Personal Information
1. Users may, at any time, inspect or correct their registered personal information. To do so, users can click on 'Account' and then inspect or change the relevant information themselves. Alternatively, they can contact the supervisor and the person responsible for managing personal information by email. In this case, the request will be processed without delay.
1. If a user requests the correction of any errors in personal information, the relevant personal information shall not be used or provided until the error has been corrected.
1. In the event any wrong personal information is provided to a third party, the corrected information shall be immediately notified to a third party.

Withdrawal of Consent to Collect, Use and Provide Personal Information
1. Users may, at any time, withdraw their consent to the collection, use and provision of personal information, which they consented to during sign-up. Users may immediately withdraw consent to collect, use and provide their personal information by clicking "Delete Account" under “App Settings” on the account page of the mobile application. If users contact the supervisor in charge of managing personal information in writing, e-mail, etc., Invincible Ventures shall immediately take necessary measures for the withdrawal without delay. In the event of withdrawal of consent or destruction of personal information, Invincible Ventures shall immediately notify the user thereof.
1. BYSNAP Store shall take necessary measures so that a withdrawal of the consent to collect personal information (withdrawal from membership) is easier than consenting to collect personal information.
1. When a user voluntarily withdraws from the membership, Invincible Ventures shall destroy personal information of the user one (1) month after the withdrawal for the purpose of prohibiting the user from illegally or expediently receiving any economic profits such as discount coupons, promotions, etc. through repetitive sign ups and withdrawals, or from using someone else’s identity illegally.

Procedure and Method of Destroying Personal Information
1. When the purpose of collecting and using personal information is achieved, BYSNAP Store shall immediately destroy the relevant information in accordance with the possession and usage period. The procedure, method and time of destruction shall be as follows:
  - Procedure and Time of Destruction
    Personal information entered by a user for Member registration shall be deleted or destroyed after the lapse of the period prescribed for privacy protection (see the “Personal Information Storage Period and Its Use” above) under Invincible Ventures’ bylaws and other applicable laws after the purpose of using personal information is achieved, such as termination of services. In general, if there are no remaining credits or debts, personal information collected upon user registration and then managed in the form of an electronic file shall be deleted immediately upon withdrawal from membership.
  - Method of Destruction Personal information printed on paper shall be destroyed by shredding, incineration, or dissolution by chemicals. Personal information stored as an electronic file shall be deleted by a technological method that makes it impossible to restore or reproduce it.

Protection of Children’s Personal Information
Invincible Ventures places great importance on the safety and privacy of children. Our services and memberships are designed for those aged 16 and above. We strictly follow the regulations established by the Children's Online Privacy Protection Act (COPPA). As a result, we never knowingly seek personally identifiable information from individuals under the age of sixteen (16) without obtaining verified parental consent in advance. In the event that we become aware of an individual under sixteen (16) providing personal information to Invincible Ventures without appropriate parental consent, we take immediate action to delete their information from our records.

Entrustment to Handle Personal Information

BYSNAP Store entrusts an outside company with the handling of personal information for better business performance including facilitating basic services, service improvement, convenience, etc., as follows:

Company	Purpose of Entrustment	Data Storage Period and Its Use
Stripe	Providing payment services	Until User Withdrawal and End of Consignment Contract
DHL Express	Mediating foreign logistics delivery, package tracking and delivery notification, attracting and managing sellers abroad, purchasing and warehousing direct imports, acting as a delivery agent
Amazon Web Service Inc.	System development and operation to provide services
Snippo Co., ltd.	Delivery of goods or invoices, system development and seller service operations, etc.
Twillio	Sending out SMS/LMS Phone Verification
Stripe	Processing payments.	Stripe may handle your payment information in accordance with their own privacy policies.

In addition to the above, Invincible Ventures use the Google Analytics Tool (a log analysis tool) for service use and statistical analysis.

In the business entrustment agreement, etc., Invincible Ventures prescribes the provisions concerning the compliance with laws and regulations related to the following: privacy protection, confidentiality of personal information, prohibition of providing personal information to a third party, responsibility in the event of accident, period of entrustment, and obligations to return or destroy personal information after handling personal information, etc. Invincible Ventures complies to the foregoing provisions.

Notification Method and Occasions
1. When Invincible Ventures seeks to obtain additional consent from users for the use of or provision to a third party of their personal information beyond the consented scope, Invincible Ventures shall notify the users of the relevant matter in advance in writing, by e-mail etc.
1. In the event Invincible Ventures entrusts collection, possession, disposition, use, provision, management or destruction, etc. of user’s personal information to a third party, Invincible Ventures shall inform the user thereof and obtain consent from the user by notifying such information on the sign-up page or the Privacy appearing on the Homepage, mobile application, etc.

Technical and Administrative Measure for Privacy Protection
1. Invincible Ventures has prepared and applies the technical and administrative measures to protect the user’s personal information.
1. Technical Measure
  Invincible Ventures devises the following technical measures to safeguard personal information from being lost, stolen, leaked, forged or damaged in the process of handling the users’ personal information:
  1. User’s personal information is password-protected and the important information is protected through independent security functions that encode files and transmission data or use lock functions.
  1. Invincible Ventures takes measures to prevent damage which may arise from computer viruses by using a vaccine program. The vaccine program is regularly updated. Upon sudden emergence of a virus, a new vaccine developed against the virus shall be immediately provided upon availability to prevent infringement of personal information.
  1. Invincible Ventures adopts a security system (SSL or SET) for safely transmitting personal information over network through a code algorithm.
  1. Invincible Ventures makes best efforts to battle infiltrations from outside such as hacking, etc. by using infiltration blocking systems and vulnerability analysis systems, etc. on each server.
1. Administrative Measure
  Invincible Ventures takes administrative measures to safeguard personal information from being lost, stolen, leaked, forged, or damaged in the process of handling user’s personal information by limiting the number of persons with access to the users’ personal information to a minimum, requiring employees to sign the written oath for privacy protection or upon their employment, etc.
1. Invincible Ventures shall not be responsible for any events resulting from user’s negligence or the fundamental risks of the Internet. Members should properly manage their IDs and passwords to protect their personal information and be liable therefor.
1. Invincible Ventures recommends that any password others can guess easily should be avoided and that the passwords be changed on a regular basis.
1. In the event of any loss, leakage, falsification, or damage to personal information due to an internal manager’s mistake or any technical accident, Invincible Ventures shall immediately inform users thereof and prepare proper measures and compensation.

Matters Concerning Installation, Operation and Refusal of Automatic Personal Information Collection Device
1. Invincible Ventures may install and use cookies or other tracking devices ( together the ”Information Collection Device”), that contain user’s information and can be searched through its Internet service. Information Collection Device means a string of information which the web server sends to web browser for storing and is sent back to the server at the time of additional request from the server. If a user accesses BYSNAP Store’s web site, Invincible Ventures may read the contents of the Information Collection Device existing in the user’s browser, search additional information and use such information to provide services without additional input of the name, etc.
1. The user’s information collected by Invincible Ventures through a Information Collection Device may be used for the following purposes:
  1. Providing customized information according to the areas of personal interests;
  1. Targeted marketing by analyzing the frequency or duration of a visit by the members and non-members and determining users’ preference and interests;
  1. Providing customized service to the user by tracking the traces of the contents which the user viewed with interest;
  1. Notifying the expiration of any subscription used; or
  1. Analyze users’ habits as a measure of service reorganization, etc.
1. A user has an option to decide whether to install the Information Collection Device or not. A user may choose to accept all Information Collection Device, see a notice when the Information Collection Device is installed, or refuse all use of Information Collection Device under "Tools > Internet Options > Privacy > Advanced" at the top of the web browser. However, when the user refuses to install the Information Collection Device, there may be some inconvenience in use of or difficulty in provision of services.
1. Information Collection Device expires upon closing the browser or logging out.

Rights and Obligations of Users
1. Users should exercise caution to enter and maintain the most up-to-date personal information. Users shall be liable for any incident arising from any inaccurate information indicated by them. If users indicate any false information such as personal information of someone else, their membership may be revoked.
1. Users have the right to have their personal information be protected as well as the obligation to protect themselves, and not to infringe information of others. Users should be careful to avoid theft of their personal information including passwords, and also avoid potentially damaging others’ personal information through, including but not limited to, posts.

Collecting Opinions, Deleting Customer Information, and Handling Complaints
1. Invincible Ventures values the opinion of users and users have the right to receive sincere replies to their inquiries at any time.
1. Invincible Ventures operates consultation channels such as the Help Center for seamless communication with users. If users have any questions, they may contact the following and hear sincere replies at any time:
  1. Help Center relating to personal information (Inquiries including destruction of customer's information)
    - By email : contact@bysnap-app.com

Supervisors Responsible for Managing Personal Information
1. BYSNAP considers the user’s personal information to be very valuable and makes best efforts to prevent any damage, infringement, or leakage of user’s personal information.
1. The Help Center serves as Privacy Center and strives to answer users’ questions regarding privacy protection promptly and sincerely. When users seek to contact BYSNAP’s manager in charge of privacy protection, they are redirected from the Help Center to the following person:
  - Manager in charge of privacy protection (Privacy Officer): Minji Shin
  - Email: privacycenter@bysnap-app.com
  - Grievance Handling Department: BYSNAP Help Center
  The Privacy Officer can be contacted via the following postal address as well:
  - Address: 39, Seocho-daero 77-gil, Seocho-gu, Seoul, Republic of Korea

Duty to Notify
1. This Policy was established on [Mar 27, 2024].
1. If there are changes made to the contents of Invincible Ventures' policies due to changes in government policies or cybersecurity technologies, the company will publicly announce general changes before they take effect. Otherwise, we may change this Privacy Policy from time to time.
1. This announcement will be made in the NOTICE section of the BYSNAP help center on our homepage
1. In some cases, where appropriate, we may also provide notification in other ways that are reasonable, such as email or other channels.
1. Any modifications to this Privacy Policy will be effective when the modified version is posted, or as otherwise indicated.
1. We shall assume your continued use of the services of BYSNAP after the posting of any modified Privacy Policy to be an indication of acceptance to our modified Privacy Policy.
1. We encourage you to review the Privacy Policy whenever you access the Services or otherwise interact with us to stay informed about our information practices and the choices available to you.

Privacy Policy for California and Virginia Residents
This addendum applies to residents of California and Virginia (the "States") regarding their privacy rights and Personal Information. It complies with the respective privacy laws, including the California Consumer Privacy Act (CCPA), the Virginia Consumer Data Protection Act, and other relevant privacy laws applicable in the state (collectively referred to as the "State Privacy Laws").
This addendum is an addition to our existing Privacy Policy and takes precedence over conflicting sections. Please note that while we strive to fulfill your requests under the law, these rights may be subject to legal limitations.
1. Information We Collect : When you use our services, we collect various categories of personal information, which include:
  - Identifiers: information such as your name, address, email, phone number, your device's IP address, software, and identification numbers associated with your devices.
  - Commercial Information: Records of products or services you have purchased, obtained, or considered.
  - Internet or Other Electronic Information: We gather information related to IP address, device and browser information, Information Collection Device such as Cookies, date of visit to BYSNAP Store, service usage record, and abnormal service usage record.
  - Geolocation: If you have enabled location services on your device, we may collect your geolocation information.
  - Results of Research activities: Information that you give us when you agree to participate in any of our research activities, such as surveys or interviews.
  - Inferences: We may derive inferences about your provided gender, preferences, characteristics, behavior, and attitudes based on the information we collect. We generally do not collect biometric information or education-related information. For more detailed information about the personal information we collect and how we collect it, please refer to the section titled "Personal Information Collected" above.
1. How We Collect, Use, and Share Your Information
  - Collection of Personal Information: We collect personal information directly from you, as well as indirectly from sources such as website activity and interactions with our company. This includes information submitted through our website portal and details collected automatically.
  - Use of Personal Information: We use your personal information for various business purposes, including providing, maintaining, and improving our services. The Privacy Policy provides clarification on the parties responsible for processing your personal data in the ‘6. Use of the Collected Personal Information and Provision of such Information to a Third Party’ section.
  - Sharing of Personal Information: We may share your personal information with certain categories of third parties. This includes service providers who assist us in delivering our services. The Privacy Policy provides clarification on the parties responsible for processing your personal data in the '11. Entrustment to Handle Personal Information' section. We enter into contracts with these organizations to ensure the confidentiality and limited use of the information.
  - Selling of Personal Information: We do not sell personal information in exchange for monetary compensation. However, we may allow certain third parties, such as advertising partners, to collect personal information through automated technologies on our platforms to provide personalized content and advertisements. You have the right to opt out of this disclosure of your information, as described in the '8. Withdrawal of Consent to Collect, Use and Provide Personal Information.'
1. Your Rights
  - Right Against Discrimination: We will not discriminate against you for exercising your privacy rights under the law.
  - Right to Know: You have the right to request information about the personal information we have collected about you. This includes details about the categories of personal information, sources of information, purposes of collection, and categories of third parties with whom we share the information. Additionally, you have the right to request a copy of the specific personal information we have collected about you during a specific time frame.
  - Right to Delete: You have the right to request the deletion of your personal information that we have collected, subject to certain exceptions. Upon verifying your request, we will delete your personal information from our records, ensuring it is no longer retained.
  - Right to Opt-Out of Information Sharing: You have the right to opt out from the sharing of your personal information with third parties. We provide mechanisms, such as Information Collection Device settings, for you to manage your preferences and exercise this right. We do not sell your personal information without your explicit consent.
1. How to Exercise Your Rights
  - Submitting Requests: To exercise your rights as described above, you can contact us via the ‘Submit a Request' form at our help center. When exercising your rights, we may ask you to provide specific information to verify your identity, such as your name, email address, phone number, and/or address. We will respond to your request under applicable State Privacy Laws and other relevant regulations. If your request is denied, you have the option to appeal the decision by contacting us.
  - Authorized Agents: You have the option to authorize an agent to submit a request on your behalf. If we receive a request from an authorized agent, we will follow the same authentication process as outlined above. To ensure proper authorization, we may request written proof or a copy of the power-of-attorney document granting the agent the right to act on your behalf.

Privacy Policy for Nevada Residents
This section applies only to Nevada residents. While we do not sell any "covered information" of Nevada "consumers" as defined in Chapter 603A of the Nevada Revised Statutes, if you are a Nevada consumer, please visit our Help Center and let us know if you would like to receive a notice in case we do so in the future through 'Submit a Request'.

Privacy Policy for Colorado, Connecticut, and Utah Residents

You have the right to opt out of (i) the “sale” of your personal information, (ii) targeted advertising, and (iii) profiling in furtherance of decisions that produce legal or similarly significant effects. If you are accessing this Privacy Policy using your web browser, you may request to opt out [here]. If you are accessing this Privacy Policy using the BYSNAP App, you may request to opt out [here].

You also have the right to request, with some exceptions, to obtain a copy of your personal information in a portable format, to confirm whether we are acting as a controller when processing your personal information, to correct inaccuracies, and to delete your information. If a request you made to exercise your rights access is denied, you may appeal the denial by writing to [email].

The categories of personal information we process, the purposes for processing that information, and the categories of information that we share with third parties and the categories of third parties we share that information are explained above in our Privacy Policy.