FaceTalk Service

Privacy Policy (Effective: October 1, 2025)

1. Items and Methods of Personal Information Collection

• The Company may collect personal information as follows for the purpose of providing services and fulfilling contracts such as member registration, consultation, and service applications.

• Required Information for Member Registration

– ID, Password, Gender, Age

• Profile Items Directly Entered by Users After Member Registration

– Name (Nickname), Photo, Activity Area, Profile Photo, Initial Greeting Voice (Female Members)

• Optional Items Entered by Users Upon Request During Member Registration

– Purpose of Use, Language Used, Hobbies, Religion, My Style, Preferred Opposite Sex Style, Personality, Occupation, Profile, Background Photo, Profile Message, Initial Greeting Message

• When Users Directly Enter Information for Personal Authentication to Protect Users

– Email, Phone Number and Mobile Phone Number, Identity Verification Service Identification Value (Phone numbers and mobile phone numbers are personal authentication means to protect users from fraudulent use and are not used for any other purposes), Copy of Identity Document, Account Number (Copy of identity document and account number are used for the purpose of exchanging accumulated points and are not used for any other purposes)

• The following information may be automatically generated and collected during service use

• Automatically Generated Information for Service Use and User Protection

– Membership Date, App (Client) Information Used, Recent Connection Time, Location Information, Device Type, Device ID, Platform Information Used, Device Language Used, Country Information, Service Usage Records, Fraudulent Use Records, Marketing Information Reception Consent Confirmation and Date (Location information, device type, and device ID are never exposed to other users, and location information is displayed only as distance for user protection)

• Automatically Generated Information for Customer Inquiry Response During Service Suspension and Withdrawal

– Withdrawal Date and Time

1. The Company may collect user ADID/IDFA

• ADID (Android OS)/IDFA (iOS) is an advertising identification value for mobile app users, which may be collected for measurement purposes to provide customized services to users and to provide advertisements in a better environment.

• Refusal Method

① Android: Settings → Google (Google Settings) → Ads → Deselect Ad Customization Settings

② iOS: Settings → Privacy → Advertising → Limit Ad Tracking

※ However, if you choose the option to refuse ADID/IDFA collection, inconvenience may occur in using customized services.

1. The Company collects personal information through the following methods

• Member registration, direct input by users, member information modification, service use, generated information collection tools, fax, telephone, email, customer center inquiries, etc.

2. Purpose of Personal Information Collection and Use

• Contract fulfillment related to service provision and service function implementation

• Member management and user protection, identity verification, personal identification, complaint processing and grievance handling, notification delivery, prevention and blocking of fraudulent use by malicious members

• Additional service provision and advertisement placement based on statistical characteristics, service effectiveness verification, event and promotional information provision and participation opportunity provision, connection frequency monitoring, statistics on member service usage

Matters Regarding Sensitive Information Processing

• Sensitive Information Collection Items: Gender, Age, Religion, Sexual Orientation Related Information

• Processing Purpose: Providing Customized Matching Services

• Consent Method: Separate consent for sensitive information processing in addition to basic personal information processing consent (Required)

• Possibility of Sensitive Information Disclosure: Some information (gender, age) may be disclosed to other users when providing matching services

• Right to Refuse Consent: Service use is impossible if you do not consent to sensitive information processing

3. Sharing and Provision of Personal Information
4. The Company uses users’ personal information within the scope announced in “2. Purpose of Personal Information Collection and Use” and does not use it beyond that scope or disclose users’ personal information to external parties without prior consent from users. Additionally, user information is not sold or exposed for commercial purposes other than app operation within the scope announced in the above item 2.

However, the following unavoidable cases are exceptions

• Information that users have consented to disclose in advance

• Personal information necessary for fulfilling contracts related to service provision where obtaining normal consent is significantly difficult due to economic and technical reasons

• When there is a request from investigative agencies according to procedures and methods stipulated by law for investigation purposes or by legal provisions

Matters Regarding Third-Party Provision of Personal Information

Limited to providing customized matching cross services, the Company may provide personal information to third parties within the scope of the Company’s same service app and partner companies’ same cross services.

• Recipient: QJ Soft co.ltd

• Purpose of Provision: Providing Customized Matching Cross Services

• Items Provided: Profile Information (Nickname, Age, Gender, Activity Area, Hobbies, Preferred Style)

• Retention Period: Until Service Use Ends

• Consent Method: Individual Consent Through Separate Consent Window (During Member Registration)

• When Consent is Refused: Member registration and cross matching service use with relevant partner companies unavailable

4. Personal Information Retention and Use Period

Users’ personal information is disposed of without delay once the purpose of personal information collection and use is achieved. The personal information processing and retention periods are as follows.

• Service User Member Registration and Management: Until Service Withdrawal

However, in cases falling under the following reasons, until the relevant reason ends

• When investigation or inquiry for violation of relevant laws is in progress, until the relevant investigation or inquiry ends

• When debt-credit relationships remain from service use, until the relevant debt-credit relationships are settled

Notwithstanding the above item 1, the following information is stored for the specified period for the reasons stated below.

• Fraudulent Use Records (Specific examples of fraudulent use must be included)

– Storage Reason: Prevention of Fraudulent Use

– Storage Period: 1 Year

• User Reports and Suggestions

– Storage Reason: Service Improvement and Prevention of Fraudulent Use

5. Consignment of Personal Information Processing

For smooth business processing and providing rewards for customer activities, business is consigned to the following consignee companies. Partner companies for providing customer point benefits may change from time to time. In this case, customer personal information will be retained until member withdrawal or consignment contract termination (including cancellation, termination, etc.), whichever comes first.

Ulab co.ltd

6. Personal Information Disposal Procedures and Methods

• Users’ personal information is disposed of without delay when personal information becomes unnecessary due to expiration of personal information retention period, achievement of processing purpose, etc.

• If personal information must continue to be stored according to other laws despite the expiration of the personal information retention period consented to by the data subject or achievement of processing purpose, the relevant personal information is moved to a separate database (DB) or stored in a different storage location.

• Personal information disposal procedures and methods are as follows.

Disposal Procedures
The Company selects personal information for which disposal reasons have occurred and disposes of personal information with approval from the Company’s personal information protection officer.

Disposal Methods
The Company disposes of personal information recorded and stored in electronic file format so that records cannot be reproduced, and personal information recorded and stored in paper documents is disposed of by shredding with a shredder or incineration.

7. Rights of Users and Legal Representatives and Methods of Exercise

• Data subjects (referring to legal representatives in the case of those under 14 years old) may exercise the following personal information protection-related rights at any time.

– Request for access to personal information

– Request for correction in case of errors, etc.

– Request for deletion

– Request for processing suspension

• Exercise of rights under item a can be conducted in writing or through email after creating according to Personal Information Protection Act Enforcement Rules Annex Form No. 8, and measures will be taken without delay. However, users can directly view, correct, or withdraw after clicking “Change Personal Information” (or “Modify Profile Information”, etc.) or “Withdraw” and going through identity verification procedures.

• When a data subject requests correction or deletion of errors in personal information, the relevant personal information is not used or provided until correction or deletion is completed. Also, if incorrect personal information has already been provided to third parties, correction processing results are notified to third parties without delay to ensure correction is made.

• Exercise of rights under the above item “a” can be conducted through agents such as legal representatives or authorized persons of data subjects. In this case, a power of attorney according to Personal Information Protection Act Enforcement Rules Annex Form No. 11 must be submitted.

• Requests for personal information access and processing suspension may be restricted according to Article 35, Paragraph 4 and Article 37, Paragraph 2 of the Personal Information Protection Act.

• Requests for correction and deletion of personal information cannot request deletion when that personal information is specified as a collection target in other laws.

• When requesting access, correction/deletion, or processing suspension based on data subject rights, identity verification is conducted to confirm whether the requester is the person in question or a legitimate agent.

• Data subjects may request that their processed personal information be transmitted to other personal information processors.

• Personal information canceled or deleted at the request of users or legal representatives is processed as specified in “4. Personal Information Retention and Use Period” by the Company and is processed so that it cannot be viewed or used for other purposes.

8. Installation and Operation of Automatic Personal Information Collection Devices and Matters Regarding Refusal

• The Company receives users’ location information from GPS built into devices to display user distances. However, for user protection, it is reflected only during service connection and is not updated when not in use.

• Users can refuse to provide information by turning off location services (GPS) in “Device Settings”.

• The Company does not use devices to store and retrieve user information other than the above GPS.

9. Technical and Administrative Protection Measures for Personal Information

The Company takes the following technical and administrative measures to ensure safety so that personal information is not lost, stolen, leaked, altered, or damaged when handling users’ personal information.

• Personal Information Encryption
  Users’ personal information is protected by passwords, and IDs and passwords are encrypted and stored and managed, known only to the person themselves. Due to the characteristics of personal information on mobile devices, identity verification is difficult, so no ID and password verification and change functions are provided.

• Measures Against Hacking, etc.
  The Company does its best to prevent members’ personal information from being leaked or damaged by hacking or computer viruses. In preparation for personal information damage, data is backed up daily as needed, and firewalls and SSL are used to prevent users’ personal information and data from being leaked or damaged. The Company strives to equip all possible technical devices to ensure system security.

• Minimization and Training of Handling Staff
  The Company’s personal information-related handling staff is limited to personnel in charge, separate passwords are assigned for access, and compliance with the privacy policy is constantly emphasized through ongoing training for personnel in charge.

10. Contact Information for Personal Information Management Responsibility Department

Contact (Service): Online request to operator

Contact (Email): cs@luminova.tokyo

Person in Charge: Lee CH

11. Implementation of Privacy Policy

This Privacy Policy is effective from October 1, 2025.

12. The Company receives separate consent for each purpose and classifies them as follows

For other member and company contract and obligation contents, please refer to the “Member Terms and Conditions”.

• Required Consent: Personal information processing absolutely necessary for service provision

• Optional Consent: Marketing information provision, etc.

• Third-Party Provision Consent (Required Consent): Cross matching service provision with partner companies

• Sensitive Information Processing Consent: Processing of sensitive information such as gender, age, religion

Basic service use is possible even if you do not consent to optional consent items.