This Policy (the "Policy") explains the way we treat information which is provided or collected in the METEORA application (the "METEORA") service (the "Service") on which this Policy is posted. In addition the Policy also explains the information which is provided or collected in the course of using the applications of the Company which exist in the websites or platforms of other company.

The Company is the controller of the information provided or collected in the websites on which this Policy is posted and in the course of using the applications of the Company which exist in the websites or platforms of other company.

Through this Policy, the Company regards personal information of the users as important and inform them of the purpose and method of Company's using the personal information provided by the users and the measures taken by the Company for protection of those personal information.

This Policy will be effective on the 17th August, 2021 and, in case of modification thereof, the Company will make public notice of it through posting it on the pop-up in the METEORA).

1. Information to be collected and method of collection

1.1 Personal information items to be collected
Personal information items to be collected by the Company are as follows:

• Information provided by the users

The Company may collect the information directly provided by the users.

• Information collected while the users use services

Besides of information directly provided by the users, the Company may collect information in the course that the users use the service provided by the Company.

1.2 Method of collection
The Company collects the information of users in a way of the followings:

• webpage, written form, e-mailing, tools for collection of created information provided by partner companies.

2. Use of collected information

The Company uses the collected information of users for the following purposes:

• Member management and identification
• To detect and deter unauthorized or fraudulent use of or abuse of the Service
• Improvement of existing services and development of new services
• Making notice of function of company sites or applications or matters on policy change
• To provide information on promotional events as well as opportunity to participate
• To create users’ characters
• To comply with applicable laws or legal obligation
• Use of information with prior consent of the users (for example, utilization of marketing advertisement)

METEORA entrusts part of its operations to third-party businesses to provide more convenient and improved services.

Processing personal information by the Company shall be lawful only if and to the extent that at least one of the following applies:

• A user has given consent to the processing of his or her personal information.
• Processing is necessary for the performance of a contract to which a user is party or in order to take steps at the request of a user prior to entering into a contract:
• Member management, identification, etc.
• Performance of a contract in relation to providing the services required by users, payment and settlement of fees, etc.
• Processing is necessary for compliance with a legal obligation to which the Company is subject
• Compliance with relevant law, regulations, legal proceedings, requests by the government
• Processing is necessary in order to protect the vital interests of users, or other natural persons
• Detection of, prevention of, and response to fraud, abuse, security risks, and technical issues that may harm users or other natural persons
• Processing is necessary for the performance of a task carried out in the public interest or in the excise of official authority vested in the Company
• Processing is necessary for the purposes of the legitimate interests pursued by the Company or by a third party (except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child).

3. Disclosure of collected information

Except for the following cases, the Company will not disclose personal information with a 3rd party:

I. When the Company disclosing the information with online tailored advertisement providers

• When the Company automatically collects users’ ADID/IDFA to be provided for AppsFlyer in order to analyze marketing effectiveness
• When the Company automatically collects users’ ADID/IDFA to be provided for Firebase in order to analyze marketing effectiveness

II. When the Company disclosing the information with its affiliates, partners and service providers;

• When the Company's affiliates, partners and service providers carry out services such as bill payment, execution of orders, products delivery and dispute resolution (including disputes on payment and delivery) for and on behalf of the Company

III. When the users consent to disclose in advance;

• When the user selects to be provided by the information of products and services of certain companies by sharing his or her personal information with those companies
• When the user selects to allow his or her personal information to be shared with the sites or platform of other companies such as social networking sites
• Other cases where the user gives prior consent for sharing his or her personal information

IV. When disclosure is required by the laws:

• if required to be disclosed by the laws and regulations; or
• if required to be disclosed by the investigative agencies for detecting crimes in accordance with the procedure and method as prescribed in the laws and regulations

4. Cookies, Beacons and Similar Technologies

We do not use these technologies to collect the information of users.

5. User’s right

The users or their legal representatives, as main agents of the information, may exercise the following rights regarding the collection, use and sharing of personal information by the Company:

I. The right to access to personal information;

• The users or their legal representatives may access the information and check the records of the collection, use and sharing of the information under the applicable law.

II. The right to rectification;

• The users or their legal representatives may request to correct inaccurate or incomplete information.

III. The right to erasure;

• The users or their legal representatives may request the deletion of the information after the achievement of their purpose and the withdrawal of their consent.
• However, Company will not be able to erase some personal data due to following reasons in accordance with the article 17 of the EU GDPR (General Data Protection Regulation).
• The processing of your personal data is necessary for compliance with a legal obligation.
• The processing of your personal data is necessary for the establishment, exercise or defense of legal claims.

IV. The right to restriction of processing;

• The users or their legal representatives may make temporary suspension of treatment of personal information in case of the disputes over the accuracy of information and the legality of information treatment, or if necessary to retain the information.

V. The right to data portability

• The users or their legal representatives may request to provide or transfer the information.

VI. The right to object

• The users or their legal representatives may suspend the treatment of personal information if the information is used for the purpose of direct marketing, reasonable interests, the exercise of official duties and authority, and research and statistics.

VII. The right to automated individual decision-making, including profiling

• The users or their legal representatives may request to cease the automated treatment of personal information, including profiling, which has critical impact or cause legal effect on them.

If, in order to exercise the above rights, you, as an user, use the menu of 'amendment of member information of webpage or contact the Company by sending a document or e-mails, or using telephone to the Company ( person in charge of management of personal information or a deputy), the Company will take measures without delay: Provided that the Company may reject the request of you only to the extent that there exists either proper cause as prescribed in the laws or equivalent cause.

6. User’s Obligations

The users shall keep their personal information up to date and be liable for the problems arising out of or in connection with the information incorrectly input by themselves.

The users have responsibility to ensure and maintain the security of their information such as METEORA ID, email address, Facebook ID, etc. and shall neither assign nor lend such information to a 3rd party. The Company shall not be held responsible for any problems related to personal information that may arise out of or in relation to the mistakes made by individual members or the cause not attributable to the Company.

The users shall appropriately manage their personal information and take full responsibility for such management, and be liable for the cooperation with the request of the Company to change the password on a regular basis under this Policy.

The users shall comply with the applicable laws and statues of personal information protection in each country.

7. Security

The Company regard the security of personal information of uses as very important. The company constructs the following security measures to protect the users' personal information from any unauthorized access, release, use or modification

I. Encryption of personal information

• Transmit users' personal information by using encrypted communication zone
• Store important information such as passwords after encrypting it

II. Countermeasures against hacking

• Install a system in the zone the external access to which is controlled so as to prevent leakage or damage of users' personal information by hacking or computer virus

III. Establish and execute internal management plan

IV. Install and operate access control system

V. Take measures to prevent forging or alteration of access record

8. Children

The Company does not knowingly collect any information from the children under 13 or equivalent minimum age as prescribed in the laws in relevant jurisdiction. The METEORA app employs a compliant neutral age gate to prevent children from accessing the service. If METEORA obtains actual knowledge during the course of business, that the app has collected personal information from a child all information will be deleted from our records and the account will be closed.

If you'd like to report an account that you believe belongs to someone under 13, please contact us. We take appropriate action when we receive your report.

9. Modification of Privacy Protection Policy

The Company has the right to amend or modify this Policy from time to time and, in such case, the Company will make a public notice of it through pop-up of its service (or through individual notice such as e-mail) and obtain consent from the users if required by relevant laws.

If this Policy is amended, the Company will announce such amendment with the reason and effective date seven (7) days before the effective date.

In the event of a change to this Privacy Policy, the Company will announce the amendment reason and effective date seven days prior to the effective date of the change.

10. Others

Data transfer to other countries
Considering it engages in global businesses, the Company may provide the users' personal information to the companies located in other countries for the purpose as expressly stated in this Policy. For the places where the personal information is transmitted, retained or processed, the Company takes reasonable measures for protecting those personal information.

11. Contact information of Company

Please use one of the following methods to contact the Company should you have any queries in respect to this policy or wish to update your information:

• Company name: Ivan Fil
• Address: http://theicon.io
• Email