Privacy Policy

Last updated February 28, 2025

Puzzle AI Voice AI Service Privacy Policy

Puzzle AI Co., Ltd. (hereinafter referred to as the "Company") places great importance on the protection of users' personal information and complies with the Personal Information Protection Act, the Information and Communication Network Utilization Promotion Act, and the Personal Information Protection Guidelines established by the Ministry of Information and Communication.

The Company's Privacy Policy applies to services provided by voice AI (hereinafter referred to as "Services").

Article 1 (Purpose of using personal information, items and methods of collection)

1. The company processes personal information essential for the use of the service for the following purposes. The personal information to be processed will not be processed for any purpose other than the following purposes, and if the purpose of processing and the items change, we will take necessary measures, such as obtaining separate consent. In particular, voice data is sensitive information, so it is collected and used by receiving separate consent from users.

1) purpose of collection

Membership management and identification [Required] Name, gender, date of birth, email address, mobile number
Voice AI-based medical support service [Required] Name, gender, date of birth, email address, mobile phone number, voice data
Biometric (voice) authentication service [Required] Name, gender, date of birth, email address, mobile phone number, voice data
Biometric (voice) recording service [Required] Name, gender, date of birth, email address, mobile phone number, voice data
When applying for affiliate inquiries (corporate alliances, membership, collaboration, etc.), identification, service provision and counseling, confirmation and prevention of illegal use of services, handling service complaints, and various notices and notices [Required when applying for an alliance] Hospital name/company name, applicant
Service Customer consultation service, such as handling complaints name, mobile phone number, email address, region/address, and inquiries [Required when applying for a civil petition] Name, gender, date of birth, mobile phone number, email address, chat details, information entered in consultation

2. When using the service, the company can request users to enter essential information and collect it in the following ways. However, if the company already has information, it can omit the input or provide input convenience for users.

A. Information entered directly by the user within the service

B. Information inquired by the user through the medical information inquiry service in the service

C. Information provided by affiliates to the company with prior consent from users for the use of specific services

D. Information generated in the course of consultation and civil complaint handling

E. Information automatically collected during service use

F. User information for handling leakage accident report

3. The company collects only the minimum amount of personal information needed to use the service.

Article 2 (Notification of disadvantages in the case of consent and refusal to collect and use personal information)

1. The service has a separate process of obtaining consent for collection and use at the time of membership registration and the start of detailed service use, and a decision-making process that users "agree" or "disagree" is in place. When expressing 'agree', it is considered to have agreed to collect and use personal information.

2. However, if you refuse to consent to collect and use the minimum amount of personal information necessary for signing a contract, you may not be able to use all or part of the company's services (why you are not aware of your identity and intention to sign a contract), and if you refuse to consent to collect and use personal information for marketing activities and public relations or to selectively collect and use, you may not be provided with information on events and benefits, or there may be disadvantages such as providing free gifts and promotional materials, using affiliate services, and applying discounts.

Article 3 (Period of Processing and Retention of Personal Information)

1. The personal information collected by the company will be used until the purpose of provision is achieved, the withdrawal of members, or the retention period under relevant laws and regulations.

2. Personal information shall be retained and used for the purpose of processing prescribed in Article 1 only during the period of collection and use of services agreed by the user, and shall be destroyed without delay upon withdrawal of membership. In particular, if a medical staff user leaves, the company will destroy personal information such as patient information stored by the medical staff user without delay. However, if personal information must be preserved in accordance with the provisions of the relevant laws and regulations, including the following cases, the relevant information shall be kept in accordance with the relevant regulations.

Records on withdrawal of contracts or subscriptions: 5 years (Act on Consumer Protection in Electronic Commerce, etc.)
Record of payment and supply of goods, etc.: 5 years (Act on Consumer Protection in Electronic Commerce, etc.)
Hold records on handling consumer complaints or disputes: 3 years (Act on Consumer Protection in Electronic Commerce, etc.)
Record of Electronic Financial Transactions: 5 years (the Electronic Financial Transactions Act)
Records of visits: 3 months (the Communications Secret Protection Act)
Books and supporting documents for all transactions prescribed by the Framework Act on National Taxes: 5 years
Advertising/marketing reception: Until withdrawal of consent or withdrawal of membership
User information for reporting leakage accidents: Jun Young-gu (Article 34 and Article 39-4 of the Personal Information Protection Act, Article 39-4 of the Act on the Use and Protection of Credit Information)

3. In order to block illegal and expedient activities, such as repeated withdrawal and re-registration of economic benefits, the user's personal information (service ID, withdrawal date, etc.) can be held for one year after withdrawal from membership.

Article 3-1 (Processing of Pseudonymized Information)

In accordance with Article 28-2 of the Personal Information Protection Act, the company treats the collected personal information under a pseudonym so that a specific individual cannot be identified for statistics preparation, scientific research, and public interest record preservation, and uses it as follows.

1. Details on the Processing of Pseudonymized Information

① Matters concerning the processing of pseudonym information

Classification	Purpose of Processing	Processing Item	Processing Period
Artificial intelligence advanced	Using research	Voice data	Until the purpose of processing is achieved
Courtesy of service	Service operation management	Voice data, Hospital/business name, name, gender, date of birth, email address	Until he leaves

② Matters concerning measures to secure the safety of pseudonym information under Article 28-4 of the Act (Obligation to take safety measures for pseudonym information, etc.)

Management measures: Establishment and implementation of internal management plans, regular employee training
Technical measures: Management of access rights to personal information processing systems, installation of access control systems, encryption of unique identification information, installation of security programs
Physical measures: Control access to computer rooms, data storage rooms

4. Once the legal retention period has elapsed, personal information is immediately deleted. Electronic personal information is deleted using an irreversible method, while paper documents containing personal information are shredded or incinerated.

Article 4 (Rights and obligations of users and legal representatives and methods of exercising them)

1. The company respects the user's rights to personal information and may exercise the following rights.

① The data subject may exercise the right to view, correct, delete, and suspend personal information to the company at any time. (If the consent to collect and use personal credit information of a specific service is withdrawn, there may be restrictions on the use of the service.)

② The exercise of rights under Paragraph 1 can be done to the company in writing, e-mail, etc. pursuant to Article 41 (1) of the Enforcement Decree of the Personal Information Protection Act, and the company will take action without delay.

③ The exercise of rights under paragraph (1) may be done through an agent, such as a legal representative of the data subject or a person who has been delegated. In this case, you must submit a power of attorney in accordance with attached Form 11 of the Enforcement Rules of the Personal Information Protection Act.

④ Requests for suspension of reading and processing personal information may restrict the rights of data subjects pursuant to Articles 35 (5) and 37 (2) of the Personal Information Protection Act.

⑤ The company verifies whether the person who requested access, correction or deletion, or suspension of processing according to the data subject's rights is himself/herself or a legitimate agent.

⑥ Requests for correction and deletion of personal information cannot be requested if the personal information is specified as a collection target in other laws.

⑦ If the information subject agrees that automated decisions are made, or if they are notified in advance through contracts, etc., or if the law clearly stipulates that automated decisions are not accepted, only explanations and review requests are allowed. In addition, requests for rejection or explanation of automated decisions may be rejected if there is a justifiable reason, such as the possibility of unreasonably infringing on the life, body, property, and other interests of others.

2. Requests for access to personal information about children under the age of 14 must be made by a legal representative, and the information subject who is a minor over the age of 14 may exercise his or her rights through a legal representative.

Article 5 (Procedures and Methods for Personal Information Destruction)

1. In principle, the company shall destroy the personal information without delay if the purpose of collecting and using personal information is achieved or the retention period of personal information, such as the expiration of the contract, has elapsed. However, in the case of personal information that needs to be preserved in accordance with related laws and regulations, the relevant personal information or personal information files are stored and managed separately from other personal information. At this time, the personal information stored separately will not be used for any purpose other than the purpose corresponding to the respective grounds for preservation.

2. When destroying personal information, the personal information printed on the paper is shredded or destroyed through incineration, and the personal information stored in the form of an electronic file is destroyed by permanently deleting it in a way that cannot be restored.

Article 5-1 (Matters concerning the installation and operation of automatic personal information collection devices and their refusal)

1. The company uses 'cookies' that store usage information and call it up from time to time to provide individual services and convenience to users using Google Analytics.

2. Cookies are a small amount of information sent by the server (http) used for website operation to the information subject's browser and are stored on the information subject's PC or mobile. It includes access IP addresses, service usage records, home page visits, device information (hardware models, operating systems, unique device identification numbers, etc.) and identifies users personally.

① Purpose of use of cookies: It is used to improve service performance and provide optimized marketing information by identifying the type of visit and use of each service and website visited by users, popular search terms, security access, and user preferences.

② The company collects behavioral information from its website as follows.

Collected items: Website Visit History

a method of collection: Automatic collection by data subject when they visit the website

purpose of collection: Store user preferences, improve service analysis and performance, marketing and targeted advertising

Retention and period of use: Until the purpose of processing is achieved, withdrawal of membership, or refusal to collect

③ How to install and reject cookies:

For Internet Explorer: Tools > Internet Options > Privacy menu options settings at the top of the Web browser
For Google Chrome: Chrome browser top right [ Settings > Privacy and Security] tab > [Cookie and other site data] > General settings
For Safari: Select Safari > Preferences, click Privacy, and set cookie and website data options

3. If the data subject refuses to save cookies as above, it may be difficult to use the customized services provided by the company.

Article 6 (Provided by a third party of personal information)

1. The company shall use the user's personal information within the scope notified in Article 1 of the Purpose of Use of Personal Information, Items and Methods, and shall not use the information collected without the user's consent beyond the scope of the purpose or disclose it to the outside. However, users' personal information may be shared with suppliers to provide services based on Articles 17 and 18 of the Personal Information Protection Act, such as when notifying users and obtaining consent.

2. However, exceptions are made in the following cases.

A. When there is a request from the relevant agency for investigative purposes under the relevant laws and regulations
B. When providing to advertiser partners or research organizations in the form of non-identification for market research, such as academic research and statistics preparation
C. When there is a request in accordance with the procedures prescribed by other relevant laws and regulations

3. The company does its best to prevent information from being provided indiscriminately or against the original purpose of collecting personal information.

Article 7 (Consignment processing of personal information)

1. The company can entrust personal information processing work to perform smoothly, such as providing better services and providing customer convenience.

2. In accordance with Article 26 of the Personal Information Protection Act, the company stipulates matters concerning responsibilities such as prohibition of processing personal information other than the purpose of performing consignment, technical and administrative protection measures, re-entrustment restrictions, management and supervision of trustees, and compensation for damages in documents such as contracts and supervises whether the trustee handles personal information safely.

3. If the contents of the consignment work or the trustee changes, we will disclose it without delay through this personal information processing policy.

Article 8 (Personal Information Protection Officer and Department in Charge)

1. Users can contact the person in charge of personal information protection or the department in charge for inquiries or complaints related to personal information that occur while using the company's service.

2. In the event of an accident contrary to the matters notified to the user in protecting personal information, the person in charge of personal information protection shall take full responsibility. However, despite technical supplementary measures, we are not responsible for information damage caused by unexpected accidents caused by basic network risks such as hacking and various disputes caused by visitors' posts.

3. The person in charge and person in charge of handling the user's personal information are as follows, and we respond quickly and sincerely to inquiries related to personal information.

A. Company representative information

Address: 5079 Gangnam-daero, Seocho-gu, Seoul (Shin Tae-yang Building)
Number: 02-6941-0214
Email: hello@puzzle-ai.com

B. Chief Information Protection Officer and Personal Information Protection Officer

Chief Information Protection Officer (CISO): Eunjung Lee
Director of Personal Information Protection (CPO): Hwang Ji-wook
Number: 02-6941-0214
Email: hello@puzzle-ai.com

C. If you need other personal information consultation, you can contact the company's e-mail above, and if you need to report a dispute or privacy infringement to a state agency, you can contact the contact information below for help.

Personal Information Infringement Reporting Center (http://privacy.kisa.or.kr / 118 without country number)
Personal Information Dispute Mediation Committee (https://www.kopico.go.kr/main/main.do/ 1833-6972)
Cyber Investigation Division of Supreme Prosecutors' Office (http://spo.go.kr / 1301 without national number)
Cyber Safety Bureau of the National Police Agency (http://cyberbureau.police.go.kr / 182)

Article 9 (Measures for Safe Personal Information Protection)

1. The company is making various protective measures and efforts to protect users' personal information safely.

Management measures: Establishment and implementation of internal management plans, conducting personal information education, etc
Technical measures: Limiting the operation and access rights of access control devices to personal information, storing access records and using security functions to prevent forgery/modification of personal information processing systems, encrypting personal information, installing antivirus program and security programs, etc.
Physical measures: Control of access to computer rooms, data storage rooms, etc

2. The Company will notify users of the following within 72 hours from the time of personal information leakage (or recognition of the leakage).

Items of leaked personal information, the timing and circumstances of the leakage, information on how the data subject can do it to minimize the damage that may occur due to the leakage, the company's countermeasures and damage relief measures, department in charge of receiving a report in case of damage to the data subject, and contact information

Article 10 (Updated Personal Information Processing Policy)

The personal information processing policy can be updated at any time by reflecting any changes, such as the contents of personal information to be processed.

Personal Information Processing Policy Version Number: V025-1.1
Date of Enforcement of Personal Information Processing Policy: February 28, 2025

[Revised details of personal information processing policy]

[February 1, 2025 ~ February 27, 2025]

Last updated July 22, 2024

This privacy notice for PuzzleAI ("we," "us," or "our"), describes how and why we might collect, store, use, and/or share ( "process") your information when you use our services ("Services"), such as when you:

Visit our website at https://puzzle-ai.com , or any website of ours that links to this privacy notice

Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at hello@puzzle-ai.com .

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.

Do we process any sensitive personal information? We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law. Learn more about sensitive information we process.

Do we collect any information from third parties? We do not collect any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our SECURITY and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the privacy notice in full.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE PROCESS YOUR INFORMATION?

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

7. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?

8. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

9. HOW LONG DO WE KEEP YOUR INFORMATION?

10. HOW DO WE KEEP YOUR INFORMATION SAFE?

11. DO WE COLLECT INFORMATION FROM MINORS?

12. WHAT ARE YOUR PRIVACY RIGHTS?

13. CONTROLS FOR DO-NOT-TRACK FEATURES

14. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

15. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

16. DO WE MAKE UPDATES TO THIS NOTICE?

17. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

18. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

names

phone numbers

email addresses

mailing addresses

job titles

usernames

passwords

contact preferences

contact or authentication data

billing addresses

debit/credit card numbers

Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

health data

financial data

Payment Data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is handled and stored by Stripe and PayPal . You may find their privacy notice link(s) here: https://stripe.com/privacy and https://www.paypal.com/us/legalhub/privacy-full#personalData .

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Notice: puzzle-ai.com/cookies .

The information we collect includes:

Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps" ), and hardware settings).

Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.

To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.

To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.

To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.

To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.

To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.

To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. , legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

Consent. We may process your information if you have given us permission (i.e. , consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.

Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.

Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e. , express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e. , implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way

For investigations and fraud detection and prevention

For business transactions provided certain conditions are met

If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim

For identifying injured, ill, or deceased persons and communicating with next of kin

If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse

If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province

If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records

If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced

If the collection is solely for journalistic, artistic, or literary purposes

If the information is publicly available and is specified by the regulations

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.

5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

In Short: We are not responsible for the safety of any information that you share with third parties that we may link to or who advertise on our Services, but are not affiliated with, our Services.

The Services may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. The inclusion of a link towards a third-party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy notice. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.

6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account , prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests, or to send abandoned shopping cart reminders (depending on your communication preferences). The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.

To the extent these online tracking technologies are deemed to be a "sale"/"sharing" (which includes targeted advertising, as defined under the applicable laws) under applicable US state laws, you can opt out of these online tracking technologies by submitting a request as described below under section " DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS? "

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice : puzzle-ai.com/cookies .

Google Analytics

We may share your information with Google Analytics to track and analyze the use of the Services. The Google Analytics Advertising Features that we may use include: Remarketing with Google Analytics and Google Analytics Demographics and Interests Reporting . To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. You can opt out of Google Analytics Advertising Features through Ads Settings and Ad Settings for mobile apps. Other opt out means include http://optout.networkadvertising.org/ and http://www.networkadvertising.org/mobile-choice. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.

7. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?

In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.

As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, " AI Products " ). These tools are designed to enhance your experience and provide you with innovative solutions. The terms in this privacy notice govern your use of the AI Products within our Services.

Our AI Products

Our AI Products are designed for the following functions:

AI automation

AI applications

Text analysis

Natural language processing

AI document generation

How We Process Your Data Using AI

All personal information processed using our AI Products is handled in line with our privacy notice and our agreement with third parties. This ensures high security and safeguards your personal information throughout the process, giving you peace of mind about your data's safety.

8. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in South Korea . If you are accessing our Services from outside South Korea , please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see " WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION? " above), in South Korea, and other countries.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.

European Commission's Standard Contractual Clauses:

We have implemented measures to protect your personal information, including by using the European Commission's Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Data Processing Agreements that include Standard Contractual Clauses are available here: puzzle-ai.com/dpa . We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

9. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us .

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

10. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

11. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age .

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at hello@puzzle-ai.com .

12. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada , you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

In some regions (like the EEA, UK, Switzerland, and Canada ), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section " HOW CAN YOU CONTACT US ABOUT THIS NOTICE? " below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section " HOW CAN YOU CONTACT US ABOUT THIS NOTICE? " below or updating your preferences .

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section " HOW CAN YOU CONTACT US ABOUT THIS NOTICE? " below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. You may also opt out of interest-based advertising by advertisers on our Services. For further information, please see our Cookie Notice: puzzle-ai.com/cookies .

If you have questions or comments about your privacy rights, you may email us at hello@puzzle-ai.com .

13. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ( "DNT" ) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized . As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

14. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia , you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Categories of Personal Information We Collect

We have collected the following categories of personal information in the past twelve (12) months:

Category	Examples	Collected
A. Identifiers	Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name	NO

B. Personal information as defined in the California Customer Records statute

Name, contact information, education, employment, employment history, and financial information

C . Protected classification characteristics under state or federal law	Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data	NO
D . Commercial information	Transaction information, purchase history, financial details, and payment information	NO
E . Biometric information	Fingerprints and voiceprints	NO
F . Internet or other similar network activity	Browsing history, search history, online behavior , interest data, and interactions with our and other websites, applications, systems, and advertisements	NO
G . Geolocation data	Device location	NO
H . Audio, electronic, sensory, or similar information	Images and audio, video or call recordings created in connection with our business activities	NO
I . Professional or employment-related information	Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us	NO
J . Education Information	Student records and directory information	NO
K . Inferences drawn from collected personal information	Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics	YES
L . Sensitive personal Information	Account login information , citizenship or immigration status , contents of email or text messages , debit or credit card numbers , financial information including account access details , health data , genetic data , national origin , racial or ethnic origin , religious or philosophical beliefs , precise geolocation , sex life or sexual orientation , social security numbers , state id card numbers , status as transgender or nonbinary and personal data from a known child	YES

We only collect sensitive personal information, as defined by applicable privacy laws or the purposes allowed by law or with your consent. Sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. You may have the right to limit the use or disclosure of your sensitive personal information. We do not collect or process sensitive personal information for the purpose of inferring characteristics about you.

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

Receiving help through our customer support channels;

Participation in customer surveys or contests; and

Facilitation in the delivery of our Services and to respond to your inquiries.

We will use and retain the collected personal information as needed to provide the Services or for:

Category H - As long as the user has an account with us

Category K - As long as the user has an account with us

Category L - As long as the user has an account with us

Sources of Personal Information

Learn more about the sources of personal information we collect in " WHAT INFORMATION DO WE COLLECT? "

How We Use and Share Personal Information

Learn about how we use your personal information in the section, " HOW DO WE PROCESS YOUR INFORMATION? "

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information to in the section, " WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION? "

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

Right to know whether or not we are processing your personal data

Right to access your personal data

Right to correct inaccuracies in your personal data

Right to request the deletion of your personal data

Right to obtain a copy of the personal data you previously shared with us

Right to non-discrimination for exercising your rights

Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law) , the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ( "profiling" )

Depending upon the state where you live, you may also have the following rights:

Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including California's and Delaware's privacy law)

Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including Oregon’s privacy law)

Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including California’s privacy law)

Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including Florida’s privacy law)

How to Exercise Your Rights

To exercise these rights, you can contact us by emailing us at hello@puzzle-ai.com , by visiting puzzle-ai.com/contact , or by referring to the contact details at the bottom of this document.

We will honor your opt-out preferences if you enact the Global Privacy Control (GPC) opt-out signal on your browser.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at hello@puzzle-ai.com . We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

California "Shine The Light" Law

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section " HOW CAN YOU CONTACT US ABOUT THIS NOTICE? "

15. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: You may have additional rights based on the country you reside in.

Australia and New Zealand

We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (Privacy Act).

This privacy notice satisfies the notice requirements defined in both Privacy Acts , in particular: what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information.

If you do not wish to provide the personal information necessary to fulfill their applicable purpose, it may affect our ability to provide our services, in particular:

offer you the products or services that you want

respond to or help with your requests

manage your account with us

confirm your identity and protect your account

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section " HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU? "

If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner and a breach of New Zealand's Privacy Principles to the Office of New Zealand Privacy Commissioner .

Republic of South Africa

If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the office of the regulator, the details of which are:

The Information Regulator (South Africa)

General enquiries: enquiries@inforegulator.org.za

Complaints (complete POPIA/PAIA form 5): PAIAComplaints@inforegulator.org.za & POPIAComplaints@inforegulator.org.za

16. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this privacy notice. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

17. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at hello@puzzle-ai.com, or contact us by post at:

PuzzleAI

강남대로 507 5층 (신태양빌딩)

서초구 , 서울시 06536

South Korea

CISO: 이은정
CPO: 황지욱

18. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country or state of residence in the US , you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please visit: puzzle-ai.com/data-request .

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