Chelly Privacy Policy

Last update date: February 15, 2024

Introduction

Welcome to Chelly . This Privacy Policy applies to the Chelly mobile software application (“ Chelly APP”). This Privacy Policy also describes how we collect, use, share and process personal information of you and other individuals in connection with our Services.

The service is provided and managed by Lenged Co., Ltd. (registered address: #201, 57, Gangnam-daero 34-gil, Seocho-gu, Seoul (Yangjae-dong, Joongang Classic) (“Company”). This applies to all regions unless otherwise specified in the section ‘Supplementary Terms and Conditions – By Jurisdiction’.

Information We Collect

We may collect the following information about you:

Information You Provide

Email contact information. Where possible, if you are a registered user of our website and you choose to sign up or log in to the Services using Google and you explicitly consent to synchronizing your Google contacts, we collect your contacts' Gmail addresses . do.
Information when contacting us . When you contact us, provide feedback or inquiries about your use of our Services, or our Services Terms and Conditions , Community We collect information that you transmit to us, including information about possible violations of our guidelines or other policies.
Other Information . We may also collect your feedback about our Services if you choose to provide us with feedback.

Information automatically collected

Technical information we collect about you. When you use the Services, we automatically collect certain information from you. This information includes This includes unique device identifier (device ID ), network type and connection, mobile or device model, application version number, operating system, system language , location, usage data, etc.
Location information. We collect information about your approximate location based on your SIM card and/or IP address. We may use this information, for example, to provide you with personalized content.
Usage Information. We collect information about how you engage with our Services. This information may include problems encountered when using our services, editing type, frequency of use of each function, etc.

Information from other sources

We may receive information described in this Privacy Policy from other sources, including:

Connected services. If available, and if you use third party services, such as ZEPETO, such third party services will provide information to us. Depending on the services provided, these third-party services may share information about your use of those services.

etc. For example, if you are included or mentioned in User Content or in any complaints, objections, requests or feedback submitted by users or third parties, or if any user has provided us with your contact information, we may We may receive information about you from third parties.

How we use your information

We use your information for the following purposes:

Age and Identity Verification
Communicate with you, including notifying you about changes to our Services;
Administering and providing the Services, including enabling you to create, edit, modify and share User Content and interact with other users, and, if you choose, to participate in interactive features of the Services;
Promote your content to other users
Provide you with tailored or personalized information or content that may be of interest to you, such as marketing communications based on your preferences;
Our Services Terms and Conditions , Community Implementation of guidelines and other terms and conditions and policies
Responding to, handling and processing your inquiries, requests, applications, complaints and feedback.
Ensuring that the Services' tools are presented in the most effective way for you and your devices, and by improving our technologies, such as machine learning models and algorithms.
Service administration and internal operations (including troubleshooting, data analysis, testing, research, statistical and survey purposes)
Detect abuse, fraud and illegal activity on our Services, and where permitted by applicable law; Terms and Conditions , Community Ensuring your safety and security, including scanning, analyzing and reviewing User Content and associated metadata for violations of our Guidelines and other terms and policies ;
Providing advertising services, including, where permitted, to deliver personalized advertising to you and to measure and understand the effectiveness of our advertising;
Where necessary to comply with our legal obligations, carry out tasks in the public interest or protect the vital interests of our users and others.

also use your information for other purposes that we disclose to you at the time your information is collected, subject to your consent or as otherwise permitted by applicable law.

How we share your information

This section explains how we share your information with third parties.

Service Providers and Business Partners

We use the categories listed above, including <Information You Provide>, <Information We Collect Automatically>, and <Information We Obtain from Other Sources> . We may share personal information with our service providers and business partners. They provide services such as cloud hosting, content delivery, customer and technical support, content management, marketing, analytics, and online payments.

Our corporate group

The service is supported by a specific corporation belonging to our corporate group, a global company. These entities work for us when necessary to provide important functions such as storage, content delivery and optimization, security, research and development, analytics, online payments, customer and technical support, and content management for the Services. We may also share your information with members of our Enterprise to improve our Services, allow you access to other services offered by members of our Enterprise, or for internal business purposes.

Third Party Social Network Services

If you choose to sign up or log in to use the Services with your other social network account details or other third party service account details, or if you choose to link your service account with another social network account, such Third-party services may collect information about you, including information about your activities on the Service, and in accordance with their privacy policies, you may collect information about you from such third-party services in the course of your use of the Service. We may notify you when a connection is established.
If you allow a third-party service to access your account, we will share certain information about you with that third-party service, such as your app ID, access token, and referring URL. Depending on the permissions you grant, third party services may obtain your account information and other information you choose to provide. If you choose to share User Content you create or upload on the Service with other social media services, your User Content, username, and attached text (if applicable) will be shared with those services.

Legal Obligations and Rights

We may share <Types of Information We Collect> with law enforcement agencies, public authorities or other entities if required to do so by law, or if we believe in good faith that such action is reasonably necessary to:

Comply with applicable laws, regulations, codes of practice, government directives or other legal and regulatory obligations in accordance with internationally recognized standards.
Our Services Enforce our Terms and other agreements, policies and standards, including investigating potential violations thereof;
Exercise or defend any legal claim, including in response to subpoenas, court orders, legal proceedings, law enforcement requests, legal claims, or governmental inquiries.
Detect, prevent, or otherwise address security, fraud, or technical issues; or
Protect the rights, property or safety of us, our users, third parties or the public, as required or permitted by law (including exchanging information with other companies and organizations to prevent fraud) ;

Sale or merger

We may also disclose your information to third parties in the following cases:

If we sell our business or assets, we may disclose your information to the prospective purchaser of such business or assets.
If we sell, buy or merge with another company or business, if another company or business acquires us, if we enter into an affiliation with another company or business, or if we sell some or all of our assets. In such case, your user information may be among the assets transferred pursuant to that transaction.

With your consent

We may share information with third parties based on your consent or direction.

your rights

Depending on your country of residence, you may have rights to access, rectification, deletion and restriction of processing. You may exercise these rights by written request or email, and we will act promptly upon receipt of such request. However, country-specific laws may limit the exercise of these rights. This right can also be exercised through a legal representative or an agent formally authorized by the user. We will verify the identity of the person requesting rights as required by applicable law.

View personal information . You have the right to access personal information relating to personal information we process.

Deletion of personal information. You may have the right to request erasure of personal information relating to you. However, information that needs to be kept cannot be deleted.

Restriction of processing of personal data. You have the right to request that we restrict processing of your personal information.

Right to object . Where we use your personal information, you have the right to object to the processing of your personal information.

Right to portability of personal information . You have the right to request that we provide you with information about yourself.

To exercise any of the above rights or to submit a request, please contact us at support@chelly.app . However, we may refuse your request in cases such as special provisions in law.

Data security

We take steps to ensure that your information is treated securely and in accordance with this Policy. Unfortunately, the transmission of information over the Internet cannot be guaranteed to be completely secure. We cannot guarantee the security of your information transmitted through the Service.

We maintain appropriate technical, administrative and physical security measures designed to protect your information against unauthorized access, theft, disclosure, modification or loss. We maintain these technical and administrative measures and modify them from time to time to improve the overall security of our systems.

We sometimes include links to third party websites. If you follow a link to such websites, please note that these websites have their own privacy policies and that we have no responsibility or liability for those policies. Please check the website's handling policy before providing information to that website.

Data retention

We will retain your information for as long as necessary to provide you with services and for other purposes specified in this Privacy Policy or as required by law.
Retention periods vary depending on the type of information and the purposes for which we use that information.

Information regarding minors

Chelly is not intended for children under 13 years of age. The minimum age to use the Service may vary depending on your country or region. If you believe that we have collected personal information from a child under the minimum age, please contact us at support@chelly.app .

Privacy Policy Updates

We may revise or update this Privacy Policy from time to time. If we update our Privacy Policy, we will notify you by updating the “Last Updated” date at the top of the new Privacy Policy and by posting the new Privacy Policy or providing such other notice as required by applicable law. We will notify you of any material changes to this Policy. We encourage you to periodically review this Policy to stay informed of our privacy practices.

Contact us

Questions, comments and requests regarding this Policy are always welcome. In such cases, please contact us at:
Lenged Co., Ltd.
Email: support@chelly.app
Address: #201, 57, Gangnam-daero 34-gil, Seocho-gu, Seoul (Yangjae-dong, Joongang Classic)

Supplementary Terms – Jurisdiction Specific

If there is a conflict between the provisions of the Supplementary Terms - Jurisdiction-Specific, which apply to the jurisdiction in which you access or use the Services, and the remaining provisions of this Policy, the Supplementary Terms - Jurisdiction-Specific, for that jurisdiction , will supersede, and this Supplement. It is governed by terms and conditions.

European Economic Area (“EEA”), Switzerland and the United Kingdom

If you use the Service from the EEA, Switzerland or the United Kingdom (“European Region”), the following additional terms and conditions apply.

Legal basis for processing

We only use your personal data where we are legally permitted to do so. Our legal bases for the processing of your personal data described in this policy are set out in the table below.

Categories of personal data and purposes of processing	Legal Basis
use <information you provide>, <information collected automatically>, and <information from other sources> . The following points are related to this: - When registering an account - When you log in, sign up, or connect to our services through a third-party account. - User content and other information collected when you use our services - Your location - When contacting us - From other sources - From your device or app The purpose is to enable us to administer the Services and provide the Services to you, including enabling you to create, edit, modify and share User Content and interact with other users and, if you choose, to participate in interactive features of the Services; We also use this information to promote content or provide you with customized or personalized information or content that may be of interest to you.	Processing is necessary for the performance of any agreements under which we provide the Services or to take steps requested by you before you can use the Services.
use <information you provide>, <information collected automatically>, and <information from other sources> . The following points are related to this: - When registering an account - When you log in, sign up, or connect to our services through a third-party account. - User content and other information collected when you use our services - Your location - When contacting us - From other sources - From your device or app To understand how you use the Services and to improve and develop the Services, including training and improving our technology, such as our machine learning models and algorithms.	Processing is necessary to pursue our legitimate interests, including improving and developing our services .
use <Information You Provide>, <Information Collected Automatically>, and <Information from Other Sources> , and share such information with our third-party advertising partners. The following points are related to this: - Information collected when you use our services - Your location - From your device or app you with personalized advertising.	We or our third-party advertising partners seek your consent to deliver personalized advertising to you based on your aggregated activity on the Services and across apps and websites independent of us.
We use <Information You Provide> and <Information We Collect Automatically> to deliver non-personalized advertising to you , and share such information with our third-party advertising partners.	We or our third-party advertising partners serve you non-personalized advertisements. This processing is necessary for our legitimate interests, namely to display non-personalized advertising to keep our services free.
We use <Information You Provide>, <Information Collected Automatically>, and <Information from Other Sources> and share such information with our third-party advertising partners to measure and understand the effectiveness of our advertising.	This processing is based on our legitimate interests, which include growing our business and helping us, our advertisers and our advertising partners understand how their advertisements perform and who sees or interacts with their advertisements. Required. This is so they can make informed decisions (e.g. what kind of advertising campaign they want to run, what type of audience they are targeting, what types of ads their users like best). This helps us keep the advertising we show you relevant and entertaining, and helps us keep our service free for all users.
The categories of information we use will depend on the specific circumstances of each request or obligation. Depending on the circumstances, we use <information you provide>, <information collected automatically>, and <information from other sources> . The following points are related to this: - When registering an account - When you log in, sign up, or connect to our services through a third-party account. - User content and other information collected when you use our services - Your location - When contacting us - From other sources - From your device or app To comply with any legal obligations, including as necessary to support law enforcement proceedings and investigations conducted by government and/or regulatory authorities.	This processing is necessary for compliance with our legal obligations under European Union or member state law. This includes situations where we have a duty to take steps to ensure the safety of our users or to comply with a valid legal request, such as an order from law enforcement or a court. Similarly , processing may be necessary to respond to regulatory requests requiring processing of data pursuant to Chapters 4 and 6 of the GDPR . In other circumstances, processing is necessary for our legitimate interests, such as disclosing and sharing information with regulators or other government agencies.
We use <information you provide>, <information collected automatically>, and <information from other sources> . The following points are related to this: - When registering an account - When contacting us - From your device or app To communicate with you about matters relating to the Services, to respond to and address your inquiries, requests, applications, complaints and feedback, and to notify you of changes to the Services , including changes to our terms and policies. .	Processing is necessary for the performance of our contract with you .
use <information you provide>, <information collected automatically>, and <information from other sources> . The following points are related to this: - When registering an account - User content and other information collected when you use our services - Your location - From your device or app We may use this information to send you marketing communications based on your preferences.	Processing is necessary to pursue our legitimate interests, such as promoting newly developed improvements and features of our services. Where required by law, we will obtain your consent to send you messages.
use <information you provide>, <information collected automatically>, and <information from other sources> . The following points are related to this: - When registering an account - When you log in, sign up, or connect to our services through a third-party account. - User content and other information collected when you use our services - Your location - When contacting us - From other sources - From your device or app To enforce our Terms of Service, Community Guidelines and other terms and policies, including verifying that you are of appropriate age to use the Services.	Processing is necessary for the performance of our contract with you .
use <information you provide>, <information collected automatically>, and <information from other sources> . The following points are related to this: - When registering an account - When you log in, sign up, or connect to our services through a third-party account. - User content and other information collected when you use our services - Your location - When contacting us - From other sources - From your device or app permitted by applicable law, to scan, analyze, and review your User Content and related metadata for violations of our Terms of Service, Community Guidelines, and other terms and policies . The purpose is to ensure safety and security. We may also use this information for troubleshooting, data analysis, testing, and research.	Processing is necessary to pursue our legitimate interests, such as : - Ensure the safety and security of the Services, ensure compliance with our Terms of Service and Community Guidelines, and identify misuse of the Services - Ensure the continued stability and security of the Service and ensure that the Service continues to be provided and function.
aggregate or anonymize <Information You Provide>, <Information Collected Automatically>, and <Information from Other Sources> for research , statistical or other purposes, to the extent permitted by applicable law. We may use it in a way that is designed to prevent you from being identified.	This processing is necessary for our legitimate interests, namely to carry out research and protect personal data through aggregation or anonymization in accordance with data minimization and privacy protection by design.
may use <Information You Provide>, <Information Collected Automatically>, and <Information from Other Sources> when necessary to protect the life, physical integrity or safety of you or others . This may include providing information to law enforcement or emergency responders in urgent circumstances to protect health or life. The specific types of information we use will depend on the specific circumstances.	Processing is necessary to protect your vital interests or those of another person.
We may use <Information You Provide>, <Information Collected Automatically>, and <Information from Other Sources> for other purposes authorized by you . The actual information we use will depend on the actual circumstances.	We process your information if you provide consent.

International transfer of data

If you are normally located in Europe, the personal data we collect about you may be transferred back to and stored at destinations outside of Europe. For example, we may store

the information we collect on secure servers located in the Republic of Korea . When we transfer your information outside the European region, we rely on the following to ensure that an appropriate level of data protection applies to that information:

Determination of adequacy. This is a decision of the European Commission pursuant to Article 45 of the GDPR (or an equivalent decision under other laws) recognizing that a country provides an adequate level of data protection. We transfer your information to some countries where adequacy decisions exist. or
Standard Contract Clauses. The European Commission has approved contractual provisions enabling companies within the EEA to transfer data outside the EEA under Article 46 of the GDPR. These clauses (and, in the case of the UK and Switzerland, their own approved equivalents) are incorporated into standard contractual clauses ( standard contractual clauses). contractual clauses ). We transfer your information under standard contractual clauses to certain entities within our corporate group and to third parties in countries for which we have not made an adequacy decision.

For more information about these safeguards, please contact support@chelly.app .

Your rights

You have the following rights:

Free of charge, ( i ) confirmation as to whether we are processing your personal data and ( ii ) access to a copy of the personal data we hold about you.
The right to request appropriate rectification or erasure of your personal data, or restriction of processing of your personal data.
Where the processing of your personal data is based on your consent or is necessary for the performance of a contract with you and the processing takes place by automated means, we will receive personal data relating to you in a structured, widely used and machine-readable format or may be technologically advanced. The right to have your personal data transferred directly to another entity (data portability), where feasible.
If the processing of your personal data is based on your consent, the right to withdraw your consent at any time (withdrawal will not affect the lawfulness of data processing activities that occurred before such withdrawal).
Automated communications, including profiling, that have legal consequences or similarly materially affect you, unless we obtain your consent, or are authorized by the law of the European Union or its Member States or are necessary for the performance of a contract. Right not to be subject to the decision ;
The right to object to processing of your personal data where we rely on our legitimate interests, unless we can demonstrate compelling legitimate grounds which override your rights. If you object to such processing, we will review the processing of your personal data and ask you to state the grounds for that objection in order to balance our legitimate interests in the processing and your objection to such processing. request.
In case where a ) you contest the accuracy of the information; ( b ) you believe the information has been processed unlawfully and you object to its erasure; (c) we require retention of the information for the pursuit or defense of legal claims; , or ( d ) if you object to the processing and is waiting for the said request’s result, you have the right to request restriction of that processing.
The right to object to processing of your personal data for direct marketing purposes.
The right to lodge a complaint with your local data protection authority

Before we can respond to your request to exercise one or more of the rights listed above, we may need to verify your identity or account details.
To exercise your rights, please email support@chelly.app .

GDPR representative

LENGED Co., Ltd

57, Gangnam-daero 34-gil, Seocho-gu , Seoul , Republic of Korea

support@chelly.app