Rakori Privacy Policy

Effective Date: September 15, 2026

RAKUENKOREA Co.,Ltd. (Rakuen Korea Co., Ltd.; hereinafter referred to as the “Company”) establishes this Privacy Policy (hereinafter referred to as this “Policy”) regarding the handling of users’ personal information and other information concerning users (hereinafter referred to as “User Information”) in the video call and communication service “Rakori” provided by the Company (hereinafter referred to as the “Service”), in compliance with the Act on the Protection of Personal Information (hereinafter referred to as the “APPI”) and other applicable laws and regulations.

Article 1 (Matters Concerning the Personal Information Handling Business Operator)

Pursuant to Article 32, Paragraph 1 of the APPI, the Company hereby discloses the following information.

ItemDetails
Business OperatorRAKUENKOREA Co.,Ltd. (Rakuen Korea Co., Ltd.)
AddressRoom 1108, Hwanhwa Building, 320 Gangnam-daero (832-7 Yeoksam-dong), Gangnam-gu, Seoul 06252, Republic of Korea
Representative(Insert name of representative)
Personal Information Protection Manager(Insert department and title)
ContactEmail: rakuen@rakuenkorea.com

Article 2 (Definitions)

Terms used in this Policy shall have the meanings prescribed in the APPI, except as otherwise set forth below.

(1) “Personal Information” means information relating to a living individual that can identify a specific individual by name, date of birth, or other descriptions contained in such information, or that contains a personal identification code.

(2) “Personal Data” means Personal Information constituting a personal information database or the like.

(3) “Retained Personal Data” means Personal Data for which the Company has the authority to disclose, correct, add to or delete the content, suspend use, erase, or suspend provision to third parties.

(4) “Special Care-Required Personal Information” means Personal Information containing descriptions prescribed by laws and regulations as requiring special care in handling so as to avoid unjust discrimination, prejudice, or other disadvantages to the individual, including race, creed, social status, medical history, criminal history, and the fact of having suffered harm from a crime.

(5) “Personally Referable Information” means information relating to a living individual that does not fall under Personal Information, pseudonymously processed information, or anonymously processed information, including cookies and advertising identifiers.

Article 3 (Information Collected and Methods of Collection)

1. The Company collects User Information by the following methods:

(1) Information directly entered or transmitted by users through the Service;

(2) Information obtained from external services (such as LINE, Kakao, and Stripe) when users authorize linkage with such external services;

(3) Information automatically generated or collected through cookies, SDKs, access logs, and similar technologies in the course of using the Service; and

(4) Information obtained from payment processors, identity verification service providers, and other business partners.

2. The categories of information collected by the Company are as follows.

CategoryInformation
Account InformationEmail address, password, telephone number, user ID, name, and profile image from linked external services
Profile InformationNickname, gender, date of birth, area of residence, height, body type, education, occupation, employer, school, information concerning alcohol consumption and smoking, personality, blood type, photographs, and preferences concerning potential matches
Age / Identity Verification InformationImages of official identification documents and information stated thereon (such as name, date of birth, and part of the address), and facial image of the user
Payment InformationName, purchased product information, payment method information, and payment history (credit card numbers and similar information are collected by payment processors and are not retained by the Company)
Communication InformationChats, messages, reports, and materials submitted with reports (video and audio from video calls are not recorded or stored in the Company’s systems)
Usage / Device InformationIP address, country/region information, access date and time, service usage history, browsing history, OS and version, device identifiers, language settings, advertising identifiers (ADID/IDFA), and cookies
Location InformationCity-level location information (or more precise location information where the user has granted permission)
Special Care-Required Personal InformationInformation concerning religion or creed and information concerning race (only where voluntarily entered by the user with explicit consent)

Note: Payments to Hosts are settled through the payment processor Stripe. Financial institution account information and information required for tax procedures are collected directly by the relevant service provider. The Company does not collect or retain such information.

3. In order to provide the Service, the Company accesses the following functions of users’ devices. Required permissions are explained and requested when the app is first launched, and optional permissions are explained and requested when the relevant function is used.

TypePermission / FunctionPurpose
RequiredStorage / PhotosTo register and save profile photos
RequiredTelephone NumberTo check duplicate registrations and prevent fraudulent use
OptionalLocation InformationTo display recommendations based on current location
OptionalCameraTo use the video call function
OptionalMicrophoneTo use the video call function
OptionalContactsTo configure settings so that the user’s information is not displayed to acquaintances

Note: Users may use the basic functions of the Service even if they do not grant optional permissions. Permission settings may be changed at any time through the device settings screen.

Article 4 (Purposes of Use)

1. The Company uses collected Personal Information for the following purposes:

(1) To provide and maintain the Service;

(2) To register and authenticate accounts and maintain and manage membership status;

(3) To conduct age verification and identity verification pursuant to the Act on Regulation of Soliciting Children by Using Opposite Sex Introducing Service on the Internet (the “Dating Site Regulation Act”) and other applicable laws and regulations;

(4) To display recommendations, perform matching, and provide content based on users’ preferences;

(5) To provide paid services, process payments, and settle payments to Hosts through payment processors;

(6) To respond to inquiries, reports, and disputes involving users;

(7) To detect, investigate, prevent, and respond to conduct that violates laws, regulations, or the Terms of Use, including monitoring;

(8) To improve the Service, develop new services, and conduct related statistical analysis;

(9) To provide notices, important notifications, and communications concerning changes to the Terms of Use and this Policy;

(10) To send information regarding advertisements, campaigns, and events, where the user has consented;

(11) To provide advertisements tailored to users’ interests and measure advertising effectiveness; and

(12) For purposes incidental to the foregoing.

2. If the Company changes a purpose of use, the change will be made only within a scope reasonably related to the purpose before the change, and the Company will notify users by publishing the revised purpose on the Service or by another appropriate method.

Article 5 (Handling of Special Care-Required Personal Information)

1. The Company collects Special Care-Required Personal Information, such as information concerning religion, creed, or race, only where the user has given explicit prior consent.

2. Users may choose not to enter such information and may delete information already entered at any time by the method prescribed by the Company.

3. The Company will not provide Special Care-Required Personal Information to a third party without the individual’s prior consent, except where permitted by law. The Company does not provide such information to third parties on an opt-out basis.

Article 6 (Handling of Age Verification Documents, etc.)

1. Pursuant to the Dating Site Regulation Act, the Company conducts age verification using official identification documents or similar materials. The Company may also conduct identity verification, including eKYC, to prevent impersonation and fraudulent use.

2. Images of documents obtained for age verification and identity verification will be used only to the extent necessary for such verification and, except where retention is required by law, will be promptly deleted after the period prescribed by the Company following completion of the verification.

3. The Company may instruct users to mask portions of identification document images other than the information necessary for verification before submission.

Article 7 (Personal Information of Persons Under 18)

The Company does not provide the Service to persons under 18 years of age and does not collect their Personal Information. If the Company determines that a user is under 18, the Company will immediately suspend the account and delete that user’s Personal Information, except where retention is required by law.

Article 8 (Handling of Cookies, Advertising Identifiers, etc.)

1. The Company uses cookies, SDKs, advertising identifiers (Android Advertising ID / IDFA), and similar technologies to improve convenience, analyze usage, and measure advertising effectiveness.

2. Such information may constitute Personally Referable Information that, by itself, cannot identify a specific individual. If the Company provides Personally Referable Information to a third party and it is anticipated that the third party will acquire such information as Personal Data, the Company will confirm in advance, pursuant to Article 31 of the APPI, that the individual’s consent has been obtained.

3. Users may restrict the use of advertising identifiers by the following methods:

• Android: “Settings” > “Google” > “Ads” > “Delete advertising ID” or “Reset advertising ID”

• iOS: “Settings” > “Privacy & Security” > “Tracking” > turn off “Allow Apps to Request to Track”

4. Cache and data stored on a device may be deleted by selecting this app from the device settings screen.

Article 9 (Disclosure Concerning External Transmission under the Telecommunications Business Act)

Pursuant to Article 27-12 of the Telecommunications Business Act, the Company discloses below the information concerning users that is externally transmitted from users’ devices when the Service is used.

RecipientInformation TransmittedPurpose of Use by Recipient
Google LLC (Firebase / Google Analytics)Device information, usage information, advertising identifiersUsage analysis and failure detection
Google LLC (Google Ads)Advertising identifiers, usage informationAdvertising delivery and effectiveness measurement
Meta Platforms, Inc.Advertising identifiers, usage informationAdvertising delivery, effectiveness measurement, and analysis
Adjust GmbHDevice information, advertising identifiers, usage informationAdvertising effectiveness measurement
Braze, Inc.User ID, usage informationNotification delivery and usage analysis
New Relic, Inc.Device information, error informationFailure detection and analysis
Stripe, Inc.Device information, payment-related informationPayment processing and detection of fraudulent payments
LY Corporation (LINE Login)Device information, authentication-related informationLogin authentication
Kakao Corp. (Kakao Login)Device information, authentication-related informationLogin authentication

Note: If you wish to stop such transmission, please restrict the use of your advertising identifier by the method described in Paragraph 3 of the preceding Article or contact the Company’s inquiry desk.

Article 10 (Provision of Personal Data to Third Parties)

1. The Company will not provide Personal Data to a third party without the individual’s prior consent, except in the following cases:

(1) Where permitted or required by laws and regulations;

(2) Where necessary to protect a person’s life, body, or property and obtaining the individual’s consent is difficult;

(3) Where particularly necessary to improve public health or promote the sound upbringing of children and obtaining the individual’s consent is difficult;

(4) Where cooperation is necessary for a national government agency, local public entity, or person entrusted thereby to perform duties prescribed by laws and regulations, and obtaining the individual’s consent may impede the performance of such duties;

(5) Where Personal Data is provided in connection with a succession of business due to a merger or other reason; or

(6) Where handling of Personal Data is outsourced to the extent necessary to achieve the purposes of use.

2. The Company does not provide Personal Data to third parties on an opt-out basis.

3. If the Company receives a disclosure request from an investigative authority or other public authority pursuant to law, the Company may provide information only to the extent necessary after confirming the legality and necessity of the request.

Article 11 (Outsourcing of Personal Data Handling)

The Company may outsource all or part of the handling of Personal Data to the extent necessary to achieve the purposes of use. In such cases, the Company confirms the suitability of the service provider, enters into an appropriate outsourcing agreement, and exercises necessary and appropriate supervision. The principal outsourced operations are as follows.

Outsourced OperationCountry Where Service Provider Is Located
Cloud infrastructure provision and data storageUnited States, Republic of Korea, Japan
Payment processing such as credit card payments and settlement to HostsUnited States
Telephone number verification and SMS deliveryRepublic of Korea, United States
Identity verification (eKYC)Japan, Republic of Korea
Provision of video-call infrastructure (real-time communications)United States, Republic of Korea
Usage analysis, notification delivery, and failure detectionUnited States
Customer support operationsRepublic of Korea

Note: If the nature of the outsourced operations or the service provider is added or changed, the Company will revise and publish this Policy without delay.

Article 12 (Provision to Third Parties Located in Foreign Countries)

1. The Company is an operator located in the Republic of Korea and handles Personal Data in countries outside Japan, mainly the Republic of Korea and the United States, in order to provide the Service.

2. Pursuant to Article 28 of the APPI, the Company provides the following information regarding provision to third parties located in foreign countries.

Destination CountryPersonal Information Protection System in the CountryMeasures Taken by the Company
Republic of KoreaA comprehensive protection framework is established under the Personal Information Protection Act and is supervised by the Personal Information Protection Commission (PIPC). The Republic of Korea is not designated by Japan’s Personal Information Protection Commission as a foreign country having a personal information protection system equivalent to that of Japan.The Company enters into agreements requiring systems that conform to the standards prescribed in Article 16 of the Enforcement Rules of the APPI and periodically verifies the handling status.
United StatesThere is no comprehensive federal personal information protection law; regulation is provided by state laws (such as the California Consumer Privacy Act) and sector-specific laws. The United States is not designated as a foreign country having a personal information protection system equivalent to that of Japan.Same as above

3. When providing Personal Data to a third party located in a foreign country, the Company will obtain the individual’s prior consent or provide such data only to a third party that has established a system conforming to the standards prescribed by laws and regulations.

4. Information concerning the destination countries and their legal systems reflects the circumstances at the time of the Company’s investigation. Please also refer to the website of the Personal Information Protection Commission for the latest information.

Article 13 (Security Control Measures)

The Company implements the following measures to prevent leakage, loss, or damage of Personal Data and otherwise ensure its secure management:

(1) Establishment of a basic policy: The Company establishes a basic policy, including this Policy, to ensure the proper handling of Personal Data.

(2) Organizational security control measures: The Company appoints a personal information protection manager, maintains handling records, periodically reviews handling status, and maintains a system for responding to incidents such as data leaks.

(3) Personnel security control measures: The Company provides regular training to employees and obtains confidentiality pledges concerning Personal Information.

(4) Physical security control measures: The Company controls access to areas where Personal Data is handled, takes measures to prevent theft of devices and electronic media, and encrypts data when it is taken outside controlled areas.

(5) Technical security control measures: The Company restricts access privileges to the minimum necessary, retains authentication and operation logs for at least one year, encrypts communications and stored data, deploys firewalls and unauthorized-access detection systems, and regularly updates security software.

(6) Understanding of the external environment: The Company handles Personal Data in the Republic of Korea and the United States and implements necessary and appropriate security control measures after understanding the personal information protection systems of those countries.

Article 14 (Retention Period and Deletion)

1. The Company retains Personal Information for the period necessary to achieve the purposes of use and, once that period has expired, promptly deletes it by a method that makes restoration impossible. Principal retention periods are as follows.

Category of InformationRetention Period
Account / Profile InformationFor 6 months after withdrawal (for prevention of fraudulent use and dispute handling)
Communication Information (Chats, etc.)For 6 months after withdrawal
Images of Age / Identity Verification DocumentsPromptly deleted after verification is completed, except where retention is required by law
Payment / Transaction Records7 years (retained pursuant to the Corporation Tax Act, Consumption Tax Act, etc.)
Complaint / Dispute Handling Records3 years after completion of handling
Access Logs and Other Automatically Collected InformationUp to 12 months from the date of collection
Consent Information for Advertising CommunicationsUntil consent is withdrawn or the user withdraws from the Service

2. For six months after withdrawal, the Company may restrict re-registration using the same identifying information in order to prevent fraudulent re-registration.

Article 15 (Response in the Event of Leakage, etc.)

If an incident involving leakage, loss, damage, or other compromise of the security of Personal Data occurs, the Company will report to the Personal Information Protection Commission and notify affected individuals in accordance with the requirements and deadlines prescribed by Article 26 of the APPI and other applicable laws and regulations. The Company will also investigate the cause and take necessary measures to prevent further harm and recurrence.

Article 16 (Monitoring and Automated Processing)

1. To prevent conduct that violates laws, regulations, or the Terms of Use and to ensure user safety, the Company may review profile information, chats, messages, and reports through automated or human means.

2. The Company does not monitor the video or audio of video calls and does not record, store, or otherwise preserve such video or audio.

3. Based on the results of the reviews described in the preceding two paragraphs, the Company may delete information, suspend accounts, or take other measures. Users may object to such measures by the method prescribed by the Company.

4. If the Company makes a decision solely by automated processing that materially affects a user’s rights or interests, a human reviewer will conduct a review upon the user’s request.

Article 17 (Statistical Information and Anonymously Processed Information)

The Company may create statistical information or anonymously processed information from collected information so that specific individuals cannot be identified, and may use such information to improve the Service, develop new services, and conduct marketing. If the Company creates anonymously processed information, it will disclose the categories of information concerning individuals contained therein as required by law and implement security control measures for information relating to the processing method.

Article 18 (Requests for Disclosure, etc.)

1. Users may request that the Company notify them of the purposes of use of Retained Personal Data, disclose such data (including records of provision to third parties), correct, add to or delete content, suspend use or erase data, or suspend provision to third parties.

2. Users may directly review and change the following items in the app:

• Review or change registration information: “Settings” > “Account”

• Delete account: “Settings” > “Account” > “Delete Account”

• Advertising and other communication preferences: “Settings” > “Notifications”

3. Requests other than those in the preceding paragraph should be submitted to the inquiry desk specified in Article 20 by the method prescribed by the Company. After verifying the identity of the requester or representative, the Company will respond without delay in accordance with applicable laws and regulations.

4. As a general rule, disclosure will be provided electronically. If you wish to receive disclosure in writing, please state that request.

5. For requests for notification of purposes of use or disclosure, the Company may charge a fee equivalent to actual costs per request. The amount and payment method will be explained when the request is received.

6. The Company may be unable to comply with all or part of a request for disclosure or other action where permitted by law. In such cases, the Company will explain the reason.

7. If the Company receives a request to correct or delete Personal Information, it will not use such Personal Information beyond the scope necessary to achieve the purposes of use or provide it to third parties until the correction or deletion is completed.

Article 19 (Changes to this Policy)

1. The Company may amend this Policy in response to amendments to laws and regulations, changes to the Service, or other circumstances.

2. If the Company amends this Policy, it will post the revised content and the effective date on the Service at least seven days before the effective date. However, if the amendment materially affects users’ rights or interests or requires renewed consent under applicable law, the Company will provide notice at least 30 days before the effective date and obtain consent where necessary.

Article 20 (Contact Information)

For inquiries regarding this Policy, requests for disclosure or other action, and complaints, please contact:

Rakori Personal Information Inquiry Desk (RAKUENKOREA Co.,Ltd.)

Email: rakuen@rakuenkorea.com

Address: Room 1108, Hwanhwa Building, 320 Gangnam-daero (832-7 Yeoksam-dong), Gangnam-gu, Seoul 06252, Republic of Korea

You may also submit a complaint regarding the Company’s handling of Personal Information to the Personal Information Protection Commission of Japan.

Personal Information Protection Commission, APPI Consultation Line: 03-6457-9849

Supplementary Provisions

1. This Policy shall take effect on September 15, 2026.

2. The former “Rakori Privacy Policy (Personal Information Processing Policy),” effective November 1, 2022, shall be abolished and replaced by this Policy as of the effective date of this Policy.

3. If revisions become necessary in connection with the enforcement of the Act Partially Amending the Act on the Protection of Personal Information, etc. (Act No. 56 of 2026), the Company will amend this Policy in accordance with the procedures set forth in Article 19.