Paddle

LEGAL · PADDLE

Privacy Policy

Paddle Co., Ltd. (the “Company”) establishes and discloses the following Privacy Policy pursuant to Article 30 of the Personal Information Protection Act of Korea (“PIPA”), in order to protect the personal information of data subjects and to handle related grievances promptly and smoothly.

This policy applies to personal information processed on the Company’s website (paddle.kr). The website does not offer membership registration or payment; the Company collects only the minimum information required to respond to business and partnership inquiries. This English text is a reference translation — the Korean version prevails in the event of any discrepancy.

Article 1 (Purposes of Processing Personal Information)

The Company processes personal information for the purposes below. Personal information processed is not used for any purpose other than the following, and where the purpose changes the Company takes necessary measures such as obtaining separate consent pursuant to Article 18 of PIPA.

  1. Responding to business and partnership inquiries: reviewing the inquiry, identifying the enquirer, consulting and replying, providing quotations and proposals, and conducting follow-up consultations.
  2. Website usage statistics and service improvement: analysing visit and usage records to improve content and services.

Article 2 (Items of Personal Information Processed and Methods of Collection)

① The Company collects the following personal information through the website inquiry form:

  • Required: name, company or organisation name, email address, inquiry type, inquiry content.
  • Optional: phone number, expected venue and operating period, any files you attach to the inquiry.

② The following information may be generated and collected automatically while the website is used:

  • Access IP address, cookies, access date and time, browser and device information, operating system information, visit and usage records, and referral path.

③ Personal information is collected either by the data subject entering it directly into the website inquiry form, or automatically through web log analytics tools.

④ The Company does not collect sensitive information — such as ideology, belief, membership in trade unions or political parties, political opinions, health, or sex life — or unique identifiers such as resident registration numbers.

⑤ The website is not directed at children under the age of 14, and the Company does not collect personal information from children under 14.

Article 3 (Processing and Retention Periods)

① The Company processes and retains personal information within the retention and use period prescribed by law, or within the period consented to by the data subject at the time of collection.

② Retention periods for each processing activity are as follows:

Processing activityRetention periodBasis
Receipt of and response to inquiries3 years from the date the inquiry is receivedConsent of the data subject
Website usage analyticsThe period set in Google Analytics data retention settings (up to 14 months) from collectionConsent of the data subject

③ If a data subject requests destruction before the retention period ends, the Company destroys the personal information without delay, except where retention is required by applicable law.

④ Information the Company is required to retain under applicable law is kept for the period prescribed by that law. For example, website visit records are retained for three months under the Protection of Communications Secrets Act.

Article 4 (Provision of Personal Information to Third Parties)

The Company processes personal information only within the scope specified in Article 1, and provides personal information to third parties only where Articles 17 and 18 of PIPA apply — such as with the consent of the data subject or under special provisions of law. It is not otherwise provided to third parties.

Article 5 (Entrustment of Personal Information Processing)

① The Company entrusts personal information processing tasks as follows:

ProcessorEntrusted workRetention and use period
Alibaba Cloud (Alibaba Cloud Computing Ltd.)Website server hosting and infrastructure operationUntil termination of the entrustment agreement or destruction of the personal information
Green Planet Pack Co., Ltd.Operation of the work management system (GreenWork) used to receive and process inquiries, including storage of attachmentsUntil termination of the entrustment agreement or destruction of the personal information
Microsoft CorporationDelivery of inquiry notifications and operation of the internal collaboration tool (Microsoft Teams)Until termination of the entrustment agreement or destruction of the personal information
Google LLCWebsite usage analytics (Google Analytics · Google Tag Manager)Until termination of the entrustment agreement or destruction of the personal information

② When concluding entrustment agreements, the Company specifies in the contract, pursuant to Article 26 of PIPA, matters such as the prohibition of processing beyond the purpose of the entrusted work, technical and administrative safeguards, restrictions on sub-entrustment, supervision of the processor, and liability including damages — and supervises whether the processor handles personal information safely.

③ Any change to the entrusted work or to the processor will be disclosed through this Privacy Policy without delay.

Article 6 (Transfer of Personal Information Overseas)

① Pursuant to Article 28-8(1)3 of PIPA, the Company entrusts the processing and storage of personal information overseas as follows and discloses it through this Privacy Policy.

Alibaba Cloud Computing Ltd.

Country
Hong Kong
Date and method of transfer
Transmitted over the network when the website is accessed or an inquiry is submitted
Items transferred
All personal information collected under Article 2
Purpose
Website server hosting and infrastructure operation
Retention and use period
Until termination of the entrustment agreement or destruction of the personal information
Contact
https://www.alibabacloud.com/help/legal

Microsoft Corporation

Country
The United States and other countries where Microsoft operates data centres
Date and method of transfer
Transmitted over the network when an inquiry is submitted
Items transferred
Name, company or organisation name, email address, phone number, inquiry type, expected venue and operating period, inquiry content
Purpose
Delivering inquiry notifications to the responsible staff
Retention and use period
3 years from the date the inquiry is received
Contact
https://privacy.microsoft.com

Google LLC

Country
The United States
Date and method of transfer
Transmitted over the network when the website is accessed
Items transferred
Cookies, access IP address, browser and device information, visit and usage records
Purpose
Website usage analytics
Retention and use period
The period set in Google Analytics data retention settings (up to 14 months)
Contact
https://policies.google.com/privacy

② Data subjects may refuse the overseas transfer of their personal information by contacting the address in Article 11. However, website hosting and inquiry handling depend on the transfers above, so refusing may prevent use of the inquiry form; in that case you may contact the Company directly by email.

Article 7 (Procedure and Method of Destroying Personal Information)

① The Company destroys personal information without delay once it becomes unnecessary — for example when the retention period has elapsed or the processing purpose has been achieved.

② Where personal information must continue to be retained under other laws even after the consented retention period has elapsed, it is moved to a separate database or stored in a different location.

③ The procedure and method of destruction are as follows:

  • Procedure: the Company selects the personal information for which grounds for destruction have arisen and destroys it with the approval of the Chief Privacy Officer.
  • Method: personal information recorded and stored in electronic files is permanently deleted so that it cannot be recovered or reproduced; personal information recorded on paper is shredded or incinerated.

Article 8 (Rights of Data Subjects and Legal Representatives, and How to Exercise Them)

① Data subjects may at any time request access to, correction of, deletion of, or suspension of the processing of their personal information, and may withdraw consent.

② Such rights may be exercised in writing or by email using the contact in Article 11, and the Company will act on the request without delay.

③ Rights may also be exercised through a legal representative or a duly authorised agent. In that case a power of attorney in the form of Annex 11 of the Public Notice on Methods of Processing Personal Information must be submitted.

④ Requests for access and suspension of processing may be restricted under Article 35(4) and Article 37(2) of PIPA.

⑤ Deletion may not be requested where the personal information concerned is expressly specified as subject to collection under other laws.

⑥ When a request for access, correction, deletion, or suspension of processing is made, the Company verifies whether the requester is the data subject or a duly authorised agent.

Article 9 (Installation, Operation and Refusal of Automatic Collection Devices)

① The Company uses “cookies” — small pieces of information sent by the server to the user’s browser and stored on the user’s device — to understand how the website is used.

② The Company uses Google Tag Manager and Google Analytics to analyse website usage. In this process, cookies collect information such as access IP address, browser and device information, and visit and usage records, which is used solely for statistical analysis.

③ Users may refuse the installation and operation of cookies as follows:

  • Choose whether to allow cookies in your browser settings (Chrome: Settings > Privacy and security > Third-party cookies / Edge: Settings > Cookies and site permissions / Safari: Settings > Privacy).
  • Install the Google Analytics opt-out browser add-on (https://tools.google.com/dlpage/gaoptout) to refuse collection.

④ Refusing to store cookies may make some functions difficult to use.

Article 10 (Measures to Ensure the Safety of Personal Information)

The Company takes the following measures to ensure the safety of personal information:

  • Administrative measures: minimising and training staff who handle personal information, and establishing and implementing an internal management plan.
  • Technical measures: managing access rights to personal information processing systems, access control, encryption in transit (HTTPS/TLS), and installing and regularly updating security programs.
  • Physical measures: access control for facilities such as servers where personal information is stored.

Article 11 (Chief Privacy Officer and Department Handling Access Requests)

① The Company designates a Chief Privacy Officer as follows, who takes overall responsibility for personal information processing and handles complaints and remedies for data subjects.

Chief Privacy Officer

Name
Hyunho Kim
Title
Chief Executive Officer
Email
sales@paddle.kr

Receipt and handling of access requests

Department
Paddle Co., Ltd.
Email
sales@paddle.kr

② Data subjects may direct any privacy-related inquiry, complaint, or request for remedy arising from use of the website to the Chief Privacy Officer. The Company will respond without delay.

③ Requests for access to personal information under Article 35 of PIPA are also received and handled at the contact above.

Article 12 (Remedies for Infringement of Rights)

Data subjects may apply to the Personal Information Dispute Mediation Committee or the Korea Internet & Security Agency’s Privacy Infringement Report Centre for dispute resolution or consultation regarding personal information infringement. Other reports and consultations may be directed to the organisations below.

OrganisationPhoneWebsite
Personal Information Dispute Mediation Committee1833-6972www.kopico.go.kr
Privacy Infringement Report Centre118privacy.kisa.or.kr
Supreme Prosecutors’ Office, Cyber Investigation Division1301www.spo.go.kr
National Police Agency, Cyber Investigation Bureau182ecrm.police.go.kr

A person whose rights or interests are infringed by a disposition or omission of the head of a public institution in response to a request under Article 35 (access), Article 36 (correction or deletion), or Article 37 (suspension of processing) of PIPA may file an administrative appeal under the Administrative Appeals Act.

Article 13 (Changes to This Privacy Policy)

① Any addition, deletion, or modification to this Privacy Policy will be announced on the website at least 7 days before it takes effect. Where the change materially affects the rights of data subjects, it will be announced at least 30 days in advance.

② When this Privacy Policy is amended, the Company continuously discloses the date of the amendment, its effective date, and the details of the change.

This Privacy Policy was amended on 18 August 2026 and takes effect on 25 August 2026. The previous version (effective 14 August 2026) applies until 24 August 2026.