Buzzencer Privacy Policy

"Personal information" in this Policy means personal information as defined in Article 2, Paragraph 1 of the APPI, namely information about a living individual that can be used to identify a specific individual by means of name, date of birth, telephone number, email address, or other description (including information that can be easily collated with other information and thereby used to identify a specific individual).

The Company may collect the following information in providing the Platform.

The Company uses collected personal information for the following purposes:

• Screening applications and verifying identity for participation in the Platform
• Creating, managing, and operating accounts
• Calculating, confirming, and paying rewards (including bank transfers)
• Forming, operating, and managing Guilds
• Providing functionality and measuring performance of the Buzzencer System
• Improving Platform functions, responding to defects, and enhancing quality (including analysis of posted content and support for account growth)
• Statistical analysis for developing new features and improving services (including use in non-personally-identifiable form)
• Notifying Affiliators of announcements and important matters relating to the Platform
• Responding to inquiries and providing support
• Investigating and responding to violations of the terms of use and fraudulent activity (including multi-level marketing schemes)
• Compliance with applicable laws and regulations, and reporting to administrative authorities
• Prevention of disputes in sales activities
• Content generation support, behavioural analysis, performance prediction, and service quality improvement using artificial intelligence (AI)

The Company will not disclose Affiliators' personal information to third parties except in the following circumstances:

• Where prior consent has been obtained from the Affiliator concerned
• Where disclosure or provision is required by applicable laws or regulations (including lawful requests from courts, investigative authorities, and similar bodies)
• Where disclosure is necessary to protect the life, person, or property of an individual and it is difficult to obtain the consent of the individual concerned
• Where disclosure is particularly necessary for improving public health or for the sound development of children
• Where cooperation is necessary in the execution of duties prescribed by law by a national authority or similar body
• Where disclosure is made to subcontractors necessary for the operation of the Platform (such as system companies, payment processors, and accounting firms) to the extent necessary. The following are examples and are not exhaustive:
  • HubSpot
  • Zendesk
  • Payoneer
• Where disclosure is made to a business successor in connection with a merger, company demerger, business transfer, or other reason involving the succession of a business

The Company may outsource all or part of the handling of personal information to third parties to the extent necessary to achieve the purposes of use. In such cases, the Company will appropriately select outsourcing parties, conclude agreements with them regarding appropriate handling of personal information, and exercise necessary and appropriate supervision.

The Company implements appropriate technical and organisational security measures to prevent unauthorised access, loss, damage, falsification, and leakage of personal information.

The Company provides education and guidance to employees who handle personal information regarding appropriate handling practices.

When personal information is no longer required to be retained, the Company disposes of or deletes it in an appropriate manner in accordance with procedures established by the Company.

While the Company implements appropriate security measures, the Company shall not be liable for information leakage caused by unauthorised access by third parties, cyber-attacks, hacking, or other circumstances beyond the Company's reasonable control, except in cases involving the Company's wilful misconduct or gross negligence.

The Platform uses cookies and similar technologies for the purposes of improving service convenience, enhancing functions, and tracking performance. These technologies are used to improve the convenience of Affiliators and to enable accurate reward calculations; they are not used to monitor Affiliators' behaviour.

Affiliators may disable cookies through their browser settings; however, certain functions of the Platform may become unavailable as a result.

The Company uses tracking codes unique to each Affiliator for the purpose of accurately measuring performance under the Guild Affiliator Program. Data collected is used solely for performance measurement and service improvement.

Performance data relating to the Buzzencer System, such as execution counts and posting history, is recorded and managed on the Company's systems and is used solely for the purpose of calculating rewards on the Platform and improving functions. Personal information and tracking data collected will not be used for advertising delivery or provided to third parties.

For content posted or shared by Affiliators on SNS, Affiliators are obligated to include disclosure statements such as "#PR", "#Ad", or "* This link contains an affiliate link" in compliance with stealth marketing regulations under the Act against Unjustifiable Premiums and Misleading Representations where such content contains affiliate links. The Company promotes compliance with this obligation but accepts no responsibility for the content of individual Affiliators' posts.

Affiliators may make the following requests with respect to their personal information held by the Company, in accordance with the provisions of the APPI:

• Notification of the purpose of use of retained personal data
• Disclosure of retained personal data
• Correction, addition, or deletion of the content of retained personal data
• Suspension of use or erasure of retained personal data
• Cessation of provision of retained personal data to third parties

Requests should be submitted to the inquiry contact below by written letter or email. After verifying the identity of the requester, the Company will endeavour to respond within 30 days of receipt to the extent reasonable. Please note that disclosure and similar requests may be declined in cases provided for by applicable laws and regulations.

The Platform is intended for individuals aged 18 years and over. The Company does not intentionally collect personal information from individuals under the age of 18. If the Company becomes aware that a person under the age of 18 has provided personal information, the Company will promptly delete such information.

The Company retains collected personal information for the period necessary to achieve the purposes of use. Information subject to a statutory retention obligation will be retained for the period prescribed by the relevant laws and regulations (for example, tax-related documents are subject to a statutory retention obligation of 7 years). Even after account deregistration, the Company may retain information for the prescribed period to the extent necessary to fulfil these statutory obligations.

Following the achievement of the purposes of use, collected personal information will be promptly deleted.

The Platform is used in conjunction with external SNS platforms such as Instagram, X (formerly Twitter), LINE, and TikTok. In relation to activities conducted through the Buzzencer System, such as posting and sharing, the handling of personal information on those external services is governed by the privacy policies of the respective service providers. The Company accepts no responsibility for Affiliators' activities on external services.

The Company may amend this Policy in connection with changes to applicable laws and regulations or the content of the service.

In the event of amendments, the Company will notify Affiliators by a method deemed appropriate by the Company, such as posting on the Platform's website or notifying the registered email address.

If an Affiliator continues to use the Platform after an amendment, the Affiliator will be deemed to have consented to the amended Policy.

For opinions, questions, or requests relating to the handling of personal information, please contact the following: