Website and App Privacy Policy

Valid from March 1st, 2023

1. Overview

This is the Website and App Privacy Policy (“Privacy Policy”) of Dreamfora, Inc., a corporation registered at Engineering Research Park, Yonsei University, 50 Yonsei-ro, Seodaemun-gu, Seoul, South Korea (“Dreamfora”) and we are the data controller in respect of the Personal Information (as defined below) that we collect from you. It covers information Dreamfora collects from users and visitors of our official website (“Site”) and official mobile app (“App”).

 

When we use the terms “we”, “us” or “our” we refer to Dreamfora and “Our Group” means entities controlling, controlled by or under common control with Dreamfora.

 

By accessing our Site or App, you confirm that you have read and understood the entirety of this Privacy Policy.

 

You have various rights in respect to our use of your Personal Information as set out in the ‘Your Rights’ section below. Two of the fundamental rights to be aware of are that you may:

 

• 1.ask us to stop using your Personal Information for direct-marketing by email or push notification. If you exercise this right, we will stop using your Personal Information in this regard; and
• 2.ask us to consider any valid objections you have to our use of your Personal Information where we process your Personal Information on the basis of our, or a third party's, legitimate interests.

2. What does this Privacy Policy cover?

We process certain information about you when you visit or use our service provided by our Site or App (“Dreamfora Service”). Some of that information may enable you to be identifiable (“Personal Information”).

 

This Privacy Policy explains how we collect, store and use your Personal Information when you visit or use our Site and App. It also describes the types of Personal Information we collect, how we use this Personal Information to ensure we provide a relevant and timely Dreamfora Service to you, and to improve your experience of the Dreamfora Service.

 

3. What Personal Information do we collect from you?

Information you submit to us

 

Visiting our Site or using our App without registration

• •Technical Information (see “Technical and Statistical Information section”)

If you register with us via our Site or App

• •Username, Email address and password
• •Types of goal interests that you indicate through your use of the Site or App.

If you sign in via Social Media such as Facebook or Google

• •If you sign into our Site or App via Facebook, we will collect your Facebook ID, email address, profile photo and you have the option to allow us to collect the names of your Facebook friends. This is restricted to Facebook friends who use the Dreamfora Service and have allowed Dreamfora to see their list of Facebook friends.
• •If you sign into our Site or App via Google, we will collect your Google ID, name, profile photo and e-mail address.

If you complete your profile

• •Personal Information you provide including your photo, username, location and biography.

If you use the Premium Service

• •If you subscribe to the Premium Service from our App you will need to submit your payment information to Google Inc. and/or Apple Inc. and such information will be used and managed by them in accordance with their own privacy policies as linked below.

   

  - Google: https://privacy.google.com/
  - Apple: https://www.apple.com/legal/privacy/en-ww/

If you post content or comments

• •Any Personal Information included in any of your posts, comments or other submissions will be collected and processed by Dreamfora.

If you use the messaging function

• •Contact information of others may be collected, either through your phone contacts if you select "Choose friends from your phone" or from Facebook if you select "Invite your friends via Facebook".
• •If you choose to "Invite friends via email", we will request an email address, so we can determine if the other person is a registered user and connect you on the Dreamfora Service.
• •Any Personal Information contained within a message will be processed by Dreamfora.
• •Any messages reported as abusive or harmful will be directed to our staff to evaluate the report.

If you participate in user interviews, surveys or beta testing groups

• •Your screen may be recorded as you are using the test version of the App. This will only record your screen whilst you are using the Dreamfora Beta App.
• •We will collect feedback from you about your use of the App and this may include Personal Information.
• •If you help us by completing a user interview then we may collect Personal Information as part of this process which you volunteer as part of the interview.

If you enter a contest

• •If you go on to win a competition we may need your postal address in order to send you potential prizes.

If you attend a Dreamfora event

• •If you attend a Dreamfora event in person then, as part of registration for the event, we will collect one or more of your:
  - Name
  - Email Address
  - Dreamfora User ID
  - Phone Number
• •Photographs may be taken of you if you attend a Dreamfora event

If you contact us

• •Name, phone number or email address and any other Personal Information you provide to us in the course of our communication.

Automatically Collected Information

 

Technical and Statistical Information

• •The internet protocol (IP) address used to connect your computer or device to the internet and geographical location determined from such;
• •Your login information, browser type and version, time zone setting, browser plug-in types and versions, device information such as operating system and platform (as applicable to the device you are using);
• •Information about your visit to our Site, the path that you take through and from our Site (including date and time); pages that you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page; and
• •In the case of our App, information about your use of our App and the country you are connected from.

4. Cookies

We and our third-party partners, such as advertising networks, social media widgets, and analytics providers, use cookies and similar technologies to provide, support and improve Dreamfora Service and each of the uses outlined and described in this Privacy Policy. Our partners also may collect information about your online activities over time, on other devices, and on other websites or apps. Those third parties may have their own privacy policies governing their use of your Personal Information. To switch off cookies, you need to change your browser settings. For further information about how to do this please visit http://www.aboutcookies.org/. Please note that if you choose to switch off cookies on your device that will mean certain functions of our Site and App cannot operate properly and the usability of the Dreamfora Service will be affected.

Read our Cookie Policy to learn more.

5. How do we use Personal Information collected from you?

We, or third-party data processors acting on our behalf, use the Personal Information we collect from you in the following ways: To provide, develop, maintain, tailor and improve the Dreamfora Service and any other services that we operate

 

For example, we might use your Personal Information to:

• •verify your identity;
• •allow access to the Site and App;
• •facilitate the access and amendment of registration information;
• •store information about preferences;
• •customize the content on the Site and App in order to provide a more suitable, enriching and improved user experience for you, including the online advertising displayed on the Dreamfora Service;
• •enable users to participate in competitions and promotions;
• •transmit notices relating to the Dreamfora Service and deliver prizes and products to you; and
• •ensure security of the Site and App.

To conduct analysis and marketing activity

 

For example, we might use your Personal Information to:

• •monitor the number of users using the Site and App in certain geographical locations;
• •monitor use of the Dreamfora Service in order to understand how it is used and to understand how we can improve the Dreamfora Service;
• •select participants for user interviews or testing conducted by us or other trusted partners; or
• •provide advertisers, information providers and service providers with information on the types of advertisements and information which can or should be displayed or provided to you through the Dreamfora Service.

To protect you, us and others

 

For example, we might use your Personal Information to:

• •promote safety and security on Dreamfora Service to protect you and your Personal Information;
• •deny use of the Dreamfora Service to previous registered users who have: (a) not made prompt payment; (b) caused damage to Dreamfora, other users or third parties; or (c) breached our terms of use ("Terms of Use") or used Dreamfora Service in a fraudulent or improper way; or
• •protect users of the Dreamfora Service and Our Group against threats such as fraud or cyber-attacks.

To conduct direct marketing and promote the Dreamfora Service.

 

For example, we might use your Personal Information to:

• •contact you from time to time with material that we think may be of interest to you, unless you ask us not to; or
• •advertise or promote new functions, events or news by sending notifications or e-mail newsletters to you.

All email newsletters include the option to unsubscribe. Except for notices and communications about the operation of the Dreamfora Service, you may opt-out of push notifications from us at any time by using the notifications panel on the settings page in the app. We will not provide your email address to any third parties for marketing purposes.

 

To communicate with you
We may use your contact details to communicate with you in order to respond to queries you have raised with us.

 

For other purposes

• •for internal corporate reporting, business administration, ensuring adequate insurance coverage for our business, ensuring the security of company facilities, research and development, and to identify and implement business efficiencies;
• •to comply with any procedures, laws and regulations which apply to us – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others to comply, as well as where we are legally required to do so;
• •to establish, exercise or defend our legal rights – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others, as well as where we are legally required to do so;
• •if you contact us on social media, to monitor your interactions with us and our brand online, where it is in our legitimate interests to do so for market research and for planning future marketing campaigns; or
• •if we use your photograph or video footage from an event, to amplify the event to a broader audience and for internal presentation purposes, where it is in our legitimate interests for marketing and business development purposes or where we have your consent.

Anonymous data
We will anonymize the aggregate data collected through the Dreamfora Service and use and disclose it for any business purpose. However, no single individual will be identifiable from the anonymized details we disclose for these purposes.

 

6. Who do we share your Personal Information with?

Group companies: We share your Personal Information within Our Group to provide you with the Dreamfora Service, information, or undertake other processing activities as set out above and, where it is in our legitimate interests to do so for internal administrative purposes (for example, corporate strategy, compliance, auditing and monitoring or research and development).

 

Other Dreamfora users: We share information with other users of the Dreamfora Service. For example, if you send other registered users messages through the Dreamfora Service, we will share the information in the messages with them.

 

Beta testing users: If you join one of our beta testing groups then your information may be shared with other members of the testing group in order to enable communication and enhance the features being tested. People in our beta testing groups are able to leave these groups at any time.

 

Trusted Dreamfora Partners: We may share your Personal Information with the following trusted partners and agents only if they need such information to perform their specific obligations or services to us. You may request a copy of the list of these partners by sending an email to us at support@dreamfora.com

 

• •The trusted partners, suppliers, sub-contractors and agents who cooperate with us to provide the Site and App, or in collecting, storing or processing your information for us.
• •Advertisers and advertising networks that require information to select and serve relevant adverts to you and others. We do not disclose Personal Information to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 users from Denmark have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the Personal Information we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience. Read our Cookie Policy to learn more about opting out of personalized advertising.
• •Analytics and search engine providers, and research institutions and suppliers, that assist us in the improvement and optimization of, and understanding of the use of and behavior on, the Site, App and Dreamfora Service. For example, we may use Google Analytics or Amplitude to collect and process information about how Dreamfora Service is used.
• •Other trusted third parties, but only with your prior consent or where you voluntarily choose to do so; for example, the Dreamfora Service may allow you to share information, including Personal Information, with social networking websites, such as Facebook.

Other disclosures: We may also share your Personal Information with other organizations or individuals:

 

• •If it is in our legitimate interests to do so to run, grow and develop our business; in particular:
  - if we sell or buy any business or assets, we may disclose your Personal Information to the prospective buyer or seller of such business or assets; or
  - if all or substantially all of our assets are acquired by a third party, in which case Personal Information held by us will be one of the transferred assets.
• •To meet any applicable law, regulation, legal process or enforceable governmental request.
• •To enforce applicable legal terms and conditions or our other legal rights, including investigation of potential breaches of our Terms of Use.
• •To detect, prevent, or otherwise address fraud, security or technical issues.
• •To protect against or prevent harm to the rights, property or safety of Our Group, our users or the public as required or permitted by law.

   

  Any such third parties are limited (by law and by contract) in their ability to use your Personal Information for any purpose other than to perform those obligations / provide their services. We will always require them to use your Personal Information in accordance with our instructions, with the terms of this Privacy Policy and any other appropriate confidentiality and security measures we require from them.

   

  Except as detailed in this Privacy Policy, we do not rent, sell, or share personal information about you with other people or unaffiliated companies without notifying you and, where necessary, obtaining your permission. If you have given us your consent for us to use your Personal Information in this way, but later change your mind, you should contact us via email at support@dreamfora.com and we will stop doing so.

7. Our legal grounds for processing Personal Information

We may only process your Personal Information if we have a legal basis for doing so. This section sets out the legal grounds on which we rely in order to process your Personal Information.

 

We consider that the legal bases for using your Personal Information are as follows:

• •use of your Personal Information is necessary to perform our obligations under any contract with you (for example, to comply with our Terms of Use which you accept by browsing the Site or by downloading the App);
• •our use of your Personal Information is necessary for complying with our legal obligations;
• •where neither of the above two legal bases applies, use of your Personal Information is necessary for our legitimate interests or the legitimate interests of others (for example, to ensure the security of the Site or App). Our legitimate interests are:
  - to run, grow and develop our business;
  - to operate and secure the Site and App;
  - marketing, market research and business development;
  - to provide the Dreamfora Services to our users, to provide customer and technical services and to know the users that we are providing the Dreamfora Services to;
  - to protect our users and Our Group from fraud or harm; and
  - for internal group administrative purposes.

If we rely on our (or a third party’s) legitimate interests for using your Personal Information, we will undertake a balancing test to ensure that our (or the third party’s) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of your Personal Information. You can ask us for information on this balancing test by contacting us via email at support@dreamfora.com

 

Other uses of Personal Information (including participation in the beta program) may be subject to your consent (which you may withdraw at any time after giving it).

 

If we rely on your consent for us to use your Personal Information in a particular way, but you later change your mind, you may withdraw your consent by contacting us and we will stop doing so. However, if you withdraw your consent, this may impact the ability for us to provide services to you.

 

8. Where is your Personal Information stored and processed?

We will process and store your Personal Information in the locations in which Our Group operates, and in the location of our servers.

 

We comply with applicable laws in respect of the international transfer of Personal Information.

 

If you are located in the European Economic Area (“EEA”), please note that we may transfer your Personal Information for the provision of the Dreamfora Service to locations outside the European Economic Area, including USA and South Korea. Some of those locations may not offer a similar level of protection to European regulations. In these cases, we will ensure that there are adequate safeguards in place to protect your Personal Information in accordance with this Privacy Policy. These adequate safeguards include, in the case of entities based in countries outside the EEA (including South Korea), entering into data transfer agreements with the recipient based on standard contractual clauses approved by the European Commission for transfers of personal data to third countries.

 

Further details on the steps we take to protect your Personal Information, in these transfer cases is available from us on request by contacting us via email at support@dreamfora.com at any time.

 

9. How long do we keep your Personal Information?

We will not keep your Personal Information longer than reasonably necessary to fulfill the purposes described in this Privacy Policy or as prescribed by law. In particular, we will implement a retention policy which stipulates the length of time we keep Personal Information. We will securely delete the Personal Information that we no longer need, and update, archive or securely delete Personal Information if it goes out of date. Therefore, we will retain any personal data related to your account for as long as you keep it open.

 

We do not retain the contact information you provide about others for matching purposes after we have performed the matching.

 

We keep daily backups of the Site and the App which will automatically be deleted after no more than 60 days, and a monthly backup which will allow us to keep a record of how the Site appears each month (both of which will include Personal Information) and which we will keep for 6 years, in each case for the purposes of maintaining the Site and the App, and establishing, exercising or defending our legal rights. We put measures in place to ensure that any Personal Information which is stored on our backup systems is put “beyond all reasonable use”. That means that we cannot and will not use that Personal Information to inform any decision about you or in a manner that affects you in any way, or give any other organization access to that Personal Information. It also means that, when you exercise any of your rights in relation to your Personal Information, any Personal Information which is stored on our backup systems will not necessarily be within scope of those rights (i.e. we will not usually disclose it in response to a request for access to Personal Information, nor will we usually need to erase it should you ask us to). Should you exercise any of your rights in relation to your Personal Information, we will explain – in our response – how those rights apply in relation to Personal Information which is stored in our backup systems.

 

The length of time we retain Personal Information for depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.

 

10. How do we secure your Personal Information?

We take steps in an effort to treat your information securely and in accordance with this Privacy Policy. Unfortunately though, the internet cannot be guaranteed to be 100% secure and, as such, you acknowledge and accept that we cannot guarantee the security of your Personal Information transmitted to the Site or the App and that such transmission is at your own risk.

 

Where we have given you (or where you have chosen) a password which enables you to access your online account, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

 

11. What about the privacy of children?

We do not knowingly collect, maintain, or use Personal Information from children under the age of 13, and no part of the Dreamfora Service is directed to children under the age of 13. If you learn that your child has provided us with Personal Information without your consent, you may alert us by contacting us via email at support@dreamfora.com. If we learn that we have collected any Personal Information from children under 13, we will promptly take steps to delete such information and terminate the child’s account.

 

12. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. We will post any Privacy Policy changes on our Site or App. Depending on the significance of the changes, we may get in touch with you or display a more prominent notice. If we need to, we will e-mail you with details of those changes and/or ask you to confirm that you are happy with them. Please check back frequently to see any updates or changes to our Privacy Policy.

 

13. Your rights

You have various rights in relation to your Personal Information. In particular, you have a right to:

• •obtain confirmation that we are processing your Personal Information and request a copy of the Personal Information we hold about you;
• •ask that we update the Personal Information we hold about you, or correct such Personal Information that you think is incorrect or incomplete;
• •withdraw consent to our processing of your Personal Information, where we are relying upon your consent as our legal basis for processing such Personal Information;
• •object to our processing of your Personal Information;
• •prevent the processing of your Personal Information for direct-marketing purposes by email or push notification; or
• •ask us to consider any valid objections which you have to our use of your Personal Information.

To exercise any of your rights, please contact us via email at support@dreamfora.com.

We will consider all such requests and provide our response within a reasonable period (and in any event any time period required by applicable law). Please note, however, that certain Personal Information may be exempt from such requests in certain circumstances.

 

14. Contacting us, further questions and how to make a complaint

If you have any queries about our collection, use or storage of your Personal Information, please contact Dreamfora’s Data Protection Officer:

• •By email: support@dreamfora.com
• •By post: Engineering Research Park, Yonsei University, 50 Yonsei-ro, Seodaemun-gu, Seoul, South Korea

If you are unhappy with the way we handle your Personal Information, or any privacy query or request that you have raised with us, we would always prefer you to contact us first. However, you have a right to complain to the EU Data Protection Authority (“DPA”) in the country where you usually live or work, or where an alleged infringement of privacy law has taken place. In the UK (for example), the DPA is the Information Commissioner’s Office. If you would like to be directed to the appropriate DPA, please contact us at the contact details above. Alternatively, you may seek a remedy through the courts if you believe your rights have been breached.