Privacy Policy

1. Scope

DESAIL (the Company) takes your personal information seriously and complies with Korea's Personal Information Protection Act and related laws. This policy applies to every mobile application and the website the Company provides.

Our apps do different jobs, so they handle different data. Some send nothing to a server at all; others create an account. This document sets out those differences in a per-app table.

The Company's website uses no cookies and no analytics tools. Simply browsing it collects no personal information whatsoever. The one exception is the contact form on the support page: what you enter there is sent to the Company (see section 3), and Cloudflare Turnstile runs at that moment to screen out automated programs. Our hosting provider may also keep short-lived access records for security and fault handling.

2. Why we process personal information

The Company processes personal information for the purposes below. We do not use it for anything else, and if a purpose changes we will tell you first and ask for separate consent.

1. Providing the service — running the features you ask for and showing you back what you saved
2. Account management — verifying you through social sign-in, preventing abuse, answering enquiries
3. In-app purchases — confirming what you bought and restoring it when you change devices
4. Advertising — showing ads in apps that carry them, and measuring how they perform
5. Improving the service — usage analysis and diagnosing errors

The Company does not sell your personal information, and does not pass it outside the Company except for the processing entrusted below.

3. What we collect, and how

Here is what each app handles.

There are two collection methods: (i) you enter something in the app or agree to social sign-in, and (ii) data generated automatically as you use the app (advertising identifier, device information, error logs).

Here is the same information app by app, in more detail — including why each permission is asked for and how to delete what is left.

Separately, if you send the contact form on the support page or write to support@desail-company.com directly, we collect your email address and the content of your enquiry as needed to reply. We keep it for three years afterwards and then destroy it, as required by Korea's Act on Consumer Protection in Electronic Commerce for records of consumer complaints and disputes. What you send through the form is delivered to the Company's mailbox and is not stored in any separate database.

4. How long we keep it

The Company destroys personal information without delay once the purpose for collecting it has been fulfilled. Retention by category:

Device-only data

We never store it. Deleting the app removes it from your device.

Account and activity records

Erased in full without delay when you delete your account. There is no grace period.

Payment, ad, and error data

Until the purpose entrusted to each processor is fulfilled

Enquiry records

Three years after the reply (retention required by law)

Where the law requires us to keep something for a set period, we keep it for that period only and use it for nothing but that retention.

How we destroy it is set out in section 5.

5. How we destroy personal information

The Company destroys personal information without delay once its retention period has passed or the purpose for processing it has been fulfilled.

Procedure — we identify the information that has fallen due for destruction and destroy it with the approval of the privacy officer.

Method — electronic files are deleted by a method that makes recovery impossible; anything printed is shredded or incinerated.

How you delete data yourself differs from app to app.

6. Providing data to third parties

The Company does not provide your personal information to third parties. What we collect is used inside the Company only, for the purposes in section 2.

The exceptions are:

• where you have given prior consent, and
• where a law specifically requires it, or an investigative authority requests it following the procedure and method laid down by law.

Entrusted processing — work we hand to outside providers because the service cannot run without it — is a different thing, and is set out in section 7.

7. Processing we entrust to others

To run the service, the Company entrusts personal data processing as follows.

When we sign a processing agreement we require in writing that the data not be used beyond the entrusted purpose and that it be handled securely. If the entrusted work or the processor changes, we will update this policy to say so.

8. Transfers outside South Korea

Under Article 28-8 of Korea's Personal Information Protection Act, the Company discloses transfers of personal information abroad as follows.

How to refuse a transfer — you may refuse transfers abroad. Transfers for advertising can be blocked yourself in your device settings, as described in section 9. To refuse transfers for payment, error analysis, or notification delivery, write to support@desail-company.com. Note that refusing the transfer needed for payment verification may limit purchases and restores of paid features, and refusing the transfer for notification delivery means the notification-mirroring feature cannot work at all — it does not exist without that transfer. In that case, unpairing in the app also deletes the connection record left on the server.

9. Automatic collection, and how to switch it off

Apps that carry advertising use the advertising identifier supplied by the operating system (IDFA on iOS, Advertising ID on Android) to show you more relevant ads. It is not linked to your name or contact details, and you can switch it off or reset it at any time.

On iOS an app may use the advertising identifier only if it asks you for tracking permission. An app that does not ask never obtains it on iOS, and its ads there are shown without reference to you. Which apps ask is set out in the per-app detail in section 3.

iOS

Settings → Privacy & Security → Tracking — switch it off per app, or turn off “Allow Apps to Request to Track” to block them all.

Android

Settings → Privacy → Ads → “Delete advertising ID” or “Reset advertising ID”

Refusing the advertising identifier does not stop you using the app. You may simply see ads that are less relevant to you.

Apps marked yes for usage analytics carry an analytics tool that counts which screens are used and how often. It collects an installation identifier generated at random when the app is installed, along with device and app information; it is not linked to your name or contact details. There is currently no switch inside the apps to turn this off, so if you would rather we did not count it, write to support@desail-company.com.

Beyond what is described above, our apps carry nothing that follows you around and watches you. The website sets no cookies and runs no automatic collection.

10. Your rights and how to exercise them

You may exercise the following rights against the Company at any time.

1. the right to request access to your personal information
2. the right to request correction of anything inaccurate
3. the right to request deletion
4. the right to request that processing be suspended

Write to support@desail-company.com in writing or by email and the Company will act without delay. If you are acting through a representative, please include a letter of authority.

Article 35-2 of the Personal Information Protection Act gives you a right to data portability — the right to have your personal information transmitted elsewhere — against operators that meet certain thresholds. The Company is not one of those operators, so we do not run a facility for handling such requests. You can still see what we hold through the right of access above, and if we ever come within scope we will amend this clause and tell you.

Data that lives only on your device is not in our hands, so you can remove it yourself in the app or by deleting the app.

11. Automated decisions

Article 37-2 of the Personal Information Protection Act provides that where a fully automated system — one with no human involvement — makes a decision affecting your rights or obligations, the criteria and procedure must be disclosed, and you must be able to refuse that decision or ask for an explanation of it.

The automated decisions made in our apps are as follows.

Refusing, and asking for an explanation — write to support@desail-company.com to refuse any of the decisions above or to ask us to explain its criteria and procedure. We will look into it without delay and tell you the outcome.

12. Children

Our apps can be used at any age. The investment simulator involves no real money, so we place no age restriction on it either.

Apps that need no account collect no personal information at all, so anyone can simply use them.

Apps that do need an account support social sign-in (Google, Apple) only — the Company creates no accounts of its own. The minimum age therefore follows each provider's own policy: in South Korea, Google and Apple both require you to be 14 or over to manage your own account, and younger children can sign in only through a guardian-managed family account (Google Family Link, Apple Family Sharing).

The Company does not separately verify your age and does not knowingly collect personal information from children under 14. If we learn we hold such information without a legal guardian's consent, we destroy it without delay.

Legal guardians may at any time request access to, correction of, or deletion of their child's personal information. Write to support@desail-company.com and we will act without delay.

13. How we keep it safe

The Company takes the following measures to protect personal information.

• Collect the minimum — we ask only for what the service genuinely needs. Data never collected cannot leak.
• Restrict access — as few people as possible can reach systems holding personal data, and permissions are separated.
• Encryption — data is encrypted in transit (HTTPS/TLS) and at rest.
• On-device processing — anything that does not need to reach a server is never sent to one, and is handled on your device instead.

14. Privacy officer

The Company has designated a privacy officer with overall responsibility for personal data processing and for handling complaints and remedies relating to it.

Name

천세훈

Position

Representative

Contact

support@desail-company.com

If you feel your personal information has not been protected, or you simply have a question, please get in touch. The Company will answer you properly.

15. Where to go for help

If you wish to seek a remedy for a privacy infringement, you may apply to any of the bodies below for mediation or advice.

Personal Information Dispute Mediation Committee

1833-6972 · https://www.kopico.go.kr

Privacy Infringement Report Centre (KISA)

118 · https://privacy.kisa.or.kr

Supreme Prosecutors' Office, Cyber Investigation Division

1301 · https://www.spo.go.kr

Korean National Police Agency, Cybercrime Reporting System

182 · https://ecrm.police.go.kr

You may also file an administrative appeal under Korea's Administrative Appeals Act if an act or omission by the Company has infringed your rights or interests.

16. Changes to this policy

The effective date of this policy appears at the top of the document.

When we change it because the law or the service has changed, we will post notice here at least 7 days before it takes effect. For changes that materially affect your rights, we will give at least 30 days' notice, and where necessary tell you inside the app as well.

Here is the revision history so far.

This document was written in Korean. Where a translation differs in meaning, the Korean version prevails.

17. Business information

Company

DESAIL (디세일)

Representative

천세훈

Business registration no.

345-35-01559

Address

Buldang 21-ro, Seobuk-gu, Cheonan-si, Chungcheongnam-do, South Korea

Email

support@desail-company.com