KVAN KOREA Co., Ltd. (hereinafter referred to as the “Company”) places great importance on the protection of personal information of its members (in relationships related to driver dispatch, the relevant driver, and in cases where the person making the reservation and the passenger are different, the passenger shall also be included as a “Member”). The Company complies with all applicable personal information protection regulations under relevant laws and regulations that information and communications service providers are required to observe, including the Act on Promotion of Information and Communications Network Utilization and Information Protection, the Personal Information Protection Act, the Protection of Communications Secrets Act, and the Telecommunications Business Act. In accordance with applicable laws, the Company establishes and implements a Personal Information Processing Policy and makes its best efforts to protect Members’ rights and interests.

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The Company informs Members, through this Personal Information Processing Policy, of the purposes and methods by which personal information provided by Members is used, as well as the measures taken to protect personal information. This Personal Information Processing Policy is disclosed on the first page of the Company’s website (“https://www.linkro24.com”) so that Members may easily access it at any time.

If the Company revises this Personal Information Processing Policy, it will announce the reasons for revision and the details of such changes through notices on the website (or individual notices). When changes are made, the Company assigns version numbers, etc., so that Members can easily identify the revised content.

This Personal Information Processing Policy shall take effect as of January 1, 2026.

 

Article 1 (Items of Personal Information Collected and Collection Methods)

1. Items of Personal Information Collected

For membership registration (or service subscription), smooth customer support, and provision of various services, the Company collects the following personal information when a Member first uses the KVAN KOREA service.

■ General Personal Information

• Name (or nickname), email address (ID), password, mobile phone number

• Device information: model name, mobile carrier, OS, device unique identifier, advertising ID, etc.

• Profile photo (only if voluntarily uploaded by the Member)

• In-vehicle black box video and audio
  (※ Audio is not directly collected by the Company. Although some black box models may automatically record audio, the Company does not access or use such audio.)

• Location information (only with consent to the Location-Based Service Terms)

• Date of birth for card issuer authentication

• Information related to complaints or accidents

• Address information (home, workplace, etc. voluntarily entered by the Member)

• Call records related to service use (e.g., start/end time of calls with drivers)

• Referrer invitation history

• Other information voluntarily entered by the Member

• Information generated during service use or business processing, including: IP address, access date and time, service usage records, access logs, cookies, app installation information, network-based location information, records of improper use, etc.

■ Sensitive Information (limited to Members certified as persons with disabilities)

• Information related to disability registration

• In-vehicle black box video and audio of passengers with disabilities during transportation

• Account information of external services linked at the Member’s choice when using the service (e.g., Instagram, Facebook, etc.)

■ Payment Information

When processing payments, the following information may be collected depending on the payment method:

• Credit card payment: card issuer name, card number, etc.

• Mobile phone payment: mobile phone number, carrier, payment approval number, etc.

• Bank transfer: bank name, account number, etc.

• Simple payment or prepaid payment: simple payment service information, account number, etc.

■ Corporate (Organization) Member Information

Name, affiliated company (organization name), member type (corporate administrator/member), related usage history, etc.

For service operation and security purposes, the Company may periodically conduct validity checks or verification of key information such as Members’ payment card or account numbers.

In addition, during service operations, the Company may collect the above personal information from partners and drivers (drivers belonging to passenger transportation operators or dispatch agencies).

1. Methods of Collecting Personal Information

The Company collects personal information through the following methods:

• Collection during execution of the KVAN KOREA program or use of the service

• Provision from partner companies

• Collection through generated information collection tools (including cookies)

• Voluntary provision by Members during service use

 

Article 2 (Purposes of Collection and Use of Personal Information)

Except where consent has been obtained from the Member or where permitted by law, the Company does not use personal information beyond the scope notified in this Article. The Company uses collected personal information for the following purposes:

1. Provision and Operation of KVAN KOREA Services

Identification of Members within the KVAN KOREA service, performance of contracts related to service provision, settlement of fees, vehicle rental by partners, driver dispatch by partners, usage and expense payments, content provision, delivery of goods or invoices, identity verification for financial transactions and financial services, collection of outstanding payments, accident handling in case of vehicle accidents, and record review to detect violations of the Company’s terms or usage policies.

1. Member Management

Provision of membership services, member identification and identity verification, prevention of fraudulent use and unauthorized access by restricted Members (restricted under the KVAN KOREA Terms of Service), confirmation of intent to join and limitation of registration attempts, record retention for dispute resolution, complaint handling and customer support, delivery of notices, future verification of legal guardians, provision of updated information, verification of service effectiveness, analysis of access frequency, and statistical analysis of service usage.

1. (Optional) Development of New Services and Use for Marketing and Advertising

Development of new services and customized services, provision of services and advertisements based on statistical characteristics, offering opportunities to participate in events, or delivery of promotional information.

1. Collection and Use for Identifying Causes and Handling Accidents

 

Article 3 (Limited Disclosure and Provision of Personal Information to Third Parties)

1. Basic Principle

The Company processes Members’ personal information only within the scope specified in Article 2 (Purposes of Collection and Use of Personal Information). Except with prior consent from the Member or where required by law, the Company does not use personal information beyond the consented scope or provide it to third parties.
However, in the following cases, personal information may be carefully disclosed to a limited extent as necessary.

1. Reasons and Methods for Limited Disclosure of Personal Information

■ Disclosure for Mutual Identification Between Members
During use of the KVAN KOREA service, a Member’s name and profile photo may be disclosed to connected Members within the platform for identification purposes. In some cases, date of birth, email address, or mobile phone number may also be displayed.

■ Sharing of Personal Information When Using the Invitation Function

• When a Member invites another person, the inviter’s name, profile photo, and membership/boarding status may be shared with the recipient.

• If the Member selects a contact transmission method (e.g., SMS, KakaoTalk, LINE, WhatsApp, Twitter, Facebook, email, etc.), an invitation message is sent through the selected platform, during which the mobile phone number or email address may be disclosed to the recipient.

■ Information Display When Linking SNS Accounts
If a Member links an external service account (e.g., Instagram, Facebook, etc.) with the KVAN KOREA service, the linkage status may be displayed within the platform. Publicly displayed information is limited to “service registration status.”

■ Information Sharing for Corporate/Group Use
When using the service as a corporate or group Member, the following information may be shared with the relevant company’s 담당자 (responsible staff):

• Member name

• Affiliated company name entered by the Member

• Payment method (including card number, etc.)

• Service usage history
  Purpose of sharing: contract performance, payment processing, verification of service usage, and other business operations

■ Provision to Third Parties for Partner Services
If it is necessary to provide personal information to partners for improved service provision, such information will be provided only after obtaining prior consent, unless otherwise required by law.
Items specified at the time of consent:

• Recipient

• Purpose of use

• Items provided

• Retention and use period

• Right to refuse consent and any disadvantages thereof

In such cases, provided information is limited to essential items such as the Member’s name and profile photo. If additional or modified information is required depending on the nature of the service, separate consent will be obtained.

1. Retention and Use of Personal Information After Provision

Third parties that receive personal information may retain and use such information for a certain period even after consent is withdrawn, only in the following cases:

• Legal purposes such as contract performance, internal reporting, audits or inspections, and cost settlement (billing)

• Where separate retention is required under relevant laws (e.g., the Commercial Act)

In such cases, personal information will be immediately destroyed upon achievement of the relevant purpose or safely disposed of after the statutory retention period expires.

 

Article 4 (Outsourcing of Personal Information Processing)

To improve services, the Company entrusts the collection, storage, and processing of Members’ personal information to third parties within the necessary scope of work, as described below. In accordance with relevant laws, the Company stipulates necessary matters in outsourcing contracts to ensure the safe management of personal information.

When entering into outsourcing contracts, the Company specifies in written agreements matters such as prohibition of personal information processing beyond the purpose of outsourced work, technical and administrative safeguards, restrictions on re-outsourcing, management and supervision of contractors, and liability for damages, in accordance with the Personal Information Protection Act. The Company supervises whether contractors process personal information safely.

If there are changes to the outsourced work or contractors, the Company will disclose such changes without delay through this Personal Information Processing Policy.

The Company’s personal information processing contractors and outsourced tasks are as follows:

■ Outsourcing of Personal Information Processing to Domestic and Overseas Companies for Service Use

• Company : Outsourced Task

• Gabia: Infrastructure management for service provision and analysis

• KakaoTalk (AlimTalk), ICODE (SMS, https://www.icodekorea.com/): Sending SMS and AlimTalk messages related to reservations, dispatch notifications, and service alerts

• Payment processors (KG Inicis (domestic payments), Toss (overseas), PayPal (overseas payments)): Transaction approval verification, cancellations and refunds, settlement of transaction amounts, response to transaction verification requests, identity verification for financial transactions and financial services, payment and collection of compensation amounts

• Rent-a-Car Mutual Aid Association, Samsung Fire & Marine Insurance Co., Ltd., DB Insurance Co., Ltd.: Accident handling and insurance-related services

 

Article 5 (Right to Refuse Consent and Disadvantages of Refusal)

Members have the right to refuse consent to the collection and use of personal information. However, refusal to consent to the collection and use of minimum personal information necessary for contract conclusion and performance may result in inability to use the service or delays in processing.

In addition, refusal to consent to the collection and use of personal information for marketing and promotional activities and/or optional collection and use may result in disadvantages such as not receiving information on events or benefits, ineligibility for gifts or promotional items, inability to use partner services, application of discounts, or accumulation of points.

※ In addition to this consent, the Company may collect, use, or provide personal information to third parties in accordance with separate consent given by the Member.

 

Article 6 (Retention and Use Period of Personal Information)

The Company retains and uses Members’ personal information collected while the Member maintains membership status.

If a Member withdraws or loses membership status, the Company deletes and destroys the collected personal information without a separate request from the Member. However, notwithstanding withdrawal or loss of membership status, the following information is retained for the specified periods for the reasons below and then deleted and destroyed.

1. Retention Based on Internal Company Policies

• Records of Member information for dispute resolution between Members: until the statute of limitations for disputes expires

• Records of Member information to restrict re-registration of withdrawn Members: 3 months

• Records of Member information to restrict re-registration of restricted or fraudulent Members: according to the restriction period (stored separately)

1. Retention Based on Relevant Laws

• Records related to display/advertising: 6 months (Act on Consumer Protection in Electronic Commerce, etc.)

• Records related to contracts or withdrawal of subscriptions: 5 years (Act on Consumer Protection in Electronic Commerce, etc.)

• Records related to payment and supply of goods, etc.: 5 years (Act on Consumer Protection in Electronic Commerce, etc.)

• Records related to consumer complaints or dispute resolution: 3 years (Act on Consumer Protection in Electronic Commerce, etc.)

• Login records: 3 months (Protection of Communications Secrets Act)

 

Article 7 (Procedures and Methods for Destruction of Personal Information and Personal Location Information)

In principle, Members’ personal information and personal location information are destroyed without delay once the purposes of collection and use are achieved. The procedures and methods for destruction are as follows:

1. Destruction Procedure

Information entered by users for membership registration, etc., is transferred to a separate database (or separate file cabinet in the case of paper documents) after the purpose is achieved, stored for a certain period in accordance with internal policies and relevant laws (see retention and use period), and then destroyed.

Such personal information and personal location information are not used for purposes other than those for which they were collected and used, except as required by law.

1. Destruction Methods

Personal information and personal location information printed on paper are destroyed by shredding or incineration. Personal information and personal location information stored in electronic file form are deleted using technical methods that make the records unrecoverable.

 

Article 8 (Rights and Obligations of Members and Legal Representatives and Methods of Exercise)

Members may at any time view or modify their registered personal information and may refuse consent to the Company’s processing of personal information or request termination of membership (withdrawal). However, if Members change information necessary for service operation and verification, such as name, profile photo, or records of outstanding payments, service use may be restricted until the Company’s approval is obtained.

To view or modify personal information, Members may click “Change Personal Information” (or “Edit Member Information,” etc.). To terminate membership (withdraw consent), Members may click “Withdraw Membership” and directly view, correct, or withdraw after identity verification. Alternatively, Members may contact the Personal Information Manager in writing or by email, and the Company will take action without delay.

If a Member requests correction of errors in personal information, the Company will not use or provide such personal information to third parties until the correction is completed. If incorrect personal information has already been provided to a third party, the Company will notify the third party of the correction results without delay to ensure correction.

Personal information terminated or deleted at the Member’s request is processed in accordance with Article 6 (Retention and Use Period of Personal Information) and is not accessed or used for other purposes.

Only individuals aged 19 or older may register for the service. In principle, the Company does not collect personal information of children under the age of 14, for whom consent of a legal representative is required for collection and use of personal information.

 

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

[Cookies]

1. What Are Cookies?

To provide personalized and customized services, the Company uses “cookies,” which store and retrieve Members’ information from time to time.

Cookies are small text files sent by the server operating the website to the Member’s browser and stored on the hard drive of the Member’s computer. When a Member visits the website, the website server reads the contents of cookies stored on the hard drive to maintain the Member’s settings and provide customized services.

Cookies do not automatically or actively collect personally identifiable information, and Members may refuse or delete cookies at any time.

1. Purpose of the Company’s Use of Cookies

Cookies are used to help Members conveniently access and use the KVAN KOREA PC or mobile website according to their settings. Cookies are also used to provide optimized advertisements and customized information based on Members’ website visit records and usage patterns. The Company analyzes access frequency and visit times of Members and non-members to understand preferences and interests, track usage patterns, identify participation levels in events, and provide targeted marketing and personalized services.

1. Installation, Operation, and Refusal of Cookies

Members have the option to choose whether to allow cookies. Members may configure their web browser options to allow all cookies, prompt for confirmation each time a cookie is saved, or refuse all cookies.

Example (Internet Explorer): Tools > Internet Options > Privacy

However, refusal to store cookies may cause difficulties in technical support and service provision, for which the Company bears no responsibility.

[Online Customized Advertising Services]

1. Collection of Advertising Identifiers When Using Mobile Apps

The Company may collect users’ ADID/IDFA. ADID/IDFA are advertising identifiers for mobile app users and may be collected to provide customized services or measure and deliver more suitable advertising environments.

How to Opt Out

Example:
Android: Settings → Google → Ads → Turn off Ads Personalization
iOS: Settings → Privacy → Advertising → Limit Ad Tracking

1. Online Customized Advertising Services

The Company allows the following online advertising service providers to collect advertising identifiers and behavioral information:

1. Advertising service providers collecting and processing behavioral information: Google, Facebook

2. Method of collection: Automatically collected and transmitted when users run the Company’s app

 

Article 10 (Technical and Administrative Measures for Protection of Personal Information and Personal Location Information)

The Company implements the following technical and administrative measures to ensure the safety of personal information and prevent loss, theft, leakage, alteration, or damage.

1. Encryption of Personal Information

Personal information is securely stored and managed in encrypted form in accordance with applicable laws and internal policies.

1. Measures Against Hacking, etc.

The Company makes its best efforts to prevent leakage or damage of Members’ personal information due to hacking or computer viruses. Data is backed up daily, and the latest security patches and firewalls are used to prevent leakage or damage. Encrypted communication is used to securely transmit personal information over networks. Intrusion prevention systems are used to control unauthorized external access, and the Company strives to implement all possible technical measures to ensure system security.

1. Minimization and Training of Authorized Personnel

Access to personal information is limited to designated personnel only. Separate passwords are assigned and regularly updated, and continuous training is provided to emphasize compliance with the KVAN KOREA Personal Information Processing Policy.

1. Operation of a Dedicated Personal Information Protection Organization

The Company operates an internal organization dedicated to personal information protection to monitor compliance with this Policy and promptly correct any identified issues.

In addition, the Company applies the following measures to protect personal location information.

① Administrative Measures

• Designation and operation of a Location Information Management Officer

• Designation and restriction of access authority at each stage of collection, use, provision, and destruction of location information

• Establishment of procedures and guidelines defining duties and responsibilities of personnel handling location information

• Operation and management of logs recording provision of location information

• Regular internal inspections of location information protection measures

② Technical Measures

• Identification and authentication to verify access authority to location information and location information systems

• Installation of firewalls and other measures to block unauthorized access to location information systems

• Operation of electronic automatic recording and preservation systems for access logs

• Application of encryption technologies or equivalent measures to securely store and transmit location information

• Other necessary technical measures to protect location information

③ Automatic Recording and Retention of Location Information Collection, Use, and Provision Records

• Automatic recording and storage in the location information system of collection date and time, collection method, purpose (request details), provision date and details, and purpose of use

• Technical measures to prevent leakage, alteration, or damage of automatically recorded and stored data

The Company bears no responsibility for issues arising from leakage of personal information such as ID or password due to the Member’s negligence or internet-related problems.

 

Article 11 (Protection of Personal Information of Non-Members)

1. Even when using the KVAN KOREA service as a non-member, the Company requests only the minimum personal information necessary for reservation, payment, boarding history inquiry, and boarding confirmation. Such information is used solely for payment, vehicle dispatch, and boarding-related purposes and is never used for other purposes.

2. Purposes and Items of Personal Information Collection and Use for Non-Members

• Name, mobile phone number, service usage information (records generated during service use, billing and payment records, access logs, cookies, IP address): verification of boarding address and contact information for KVAN KOREA service use (reservation/dispatch/cancellation, etc.), complaint handling, confirmation of intent, and notification of new information and notices

• Account/card information: provision of payment services

• IP address, access date and time: prevention of fraudulent use

• Name, address, mobile phone number, access IP, payment records: prevention of fraudulent transactions

1. When using the service as a non-member, this Personal Information Processing Policy applies in the same manner as for Members, except for provisions applicable only to Members (e.g., retention and use period).

 

Article 12 (Personal Information Manager, Location Information Manager, and Contact Information)

Members may report all personal information protection-related complaints arising from service use to the Personal Information Manager or the relevant department.

To establish and implement technical and administrative measures for the protection of personal location information and to smoothly handle complaints from personal location information subjects, the Company designates and operates a Location Information Management Officer with substantive responsibility. The name and contact information are as follows.

The Company provides prompt and sufficient responses to Members’ reports.

1. Personal Information Manager

Name: Myungshin Choi
Affiliation: KVAN KOREA Co., Ltd.
Tel: 02-6673-5500
Position: CTO
Email: mymyautos.ms@gmail.com

1. Location Information Management Officer

Name: Jong-suk Choi
Affiliation: KVAN KOREA Co., Ltd.
Tel: 02-6673-5588
Position: Deputy Manager
Email: jingshu2017@gmail.com

If you require reporting or consultation regarding other personal information infringement, please contact the following organizations:

• Personal Information Infringement Report Center (http://www.118.or.kr / Dial 118 without area code)

• Supreme Prosecutors’ Office Cyber Crime Investigation Division (http://www.spo.go.kr / 02-3480-200)

• National Police Agency Cyber Terror Response Center (http://cyberbureau.police.go.kr / Dial 182 without area code)

 

Article 13 (Processing of Personal Location Information)

The Company processes and retains personal location information as follows.

1. Status of Processing and Retention of Personal Location Information

1. Items processed: Mobile phone location information (GPS, Wi-Fi, carrier base station information), movement routes, and service usage logs of vehicle callers, users, and drivers

2. Purpose of processing: Provision of KVAN KOREA services such as call and dispatch, fare calculation and processing, provision of coupons and promotions, service usage analysis and improvement, notices and communications, and complaint handling

3. Retention period: For purposes including call and dispatch, fare calculation and processing, promotions, service analysis and improvement, notices and communications, and complaint handling

When the Company uses personal location information, it immediately destroys personal location information other than records required to be preserved under Article 16(2) of the Location Information Act, in accordance with Article 23 of the same Act, upon achievement of the purpose of collection, use, or provision.

1. Provision of Personal Location Information to Third Parties

With the consent of the data subject, the Company may provide personal location information to third parties as necessary:

1. Items provided to vehicle call users: pickup and drop-off locations

2. Items provided to drivers: vehicle location

When providing personal location information to a third party designated by the user, the Company immediately notifies the user of the recipient, date and time of provision, and purpose through the communication device that collected the personal location information.

However, in the following cases, notification is provided through a communication device or email address designated in advance by the user:

• When the communication device used to collect personal location information does not support text, voice, or video reception

• When the user has requested notification through online posting or other methods in advance

For the protection of life or physical safety of the following users (hereinafter referred to as “children under 8, etc.”), the legal guardian may consent to the Company’s use or provision of personal location information of such users:

• Adult wards

• Persons with mental disabilities as defined in Article 2(2)2 of the Welfare of Disabled Persons Act who qualify as persons with severe disabilities under Article 2(2) of the Act on Employment Promotion and Vocational Rehabilitation of Persons with Disabilities (limited to those registered as persons with disabilities under Article 32 of the Welfare of Disabled Persons Act)

Consent by the legal guardian is provided by submitting a written consent form including the following items, along with written or electronic documents proving that the person is the legal guardian (including name seal, signature, or electronic signature):

[Items to be Included in the Written Consent Form]

• Name, address, and date of birth of the child under 8, etc.

• Name, address, and contact information of the legal guardian

• Statement that the purpose of collection, use, or provision of personal location information is limited to protection of the life or physical safety of the child under 8, etc.

• Date of consent

In accordance with Article 16(2) of the Location Information Act, the Company automatically records and retains records confirming the collection, use, and provision of location information in the system for six (6) months from the recording date.

 

Article 14 (Miscellaneous)

This “KVAN KOREA Personal Information Processing Policy” does not apply to the collection of personal information by websites linked within the KVAN KOREA service.

 

Article 15 (Obligation to Notify)

If there are additions, deletions, or amendments to this Personal Information Processing Policy, the Company will provide notice at least seven (7) days prior to the effective date through the Company website, in-service notices, or other easily accessible methods. However, if there are significant changes affecting Members’ rights, such as collection and use of personal information or provision to third parties, notice will be provided at least thirty (30) days in advance.

 

Revision Date: January 1, 2024

 

Previous versions of the Personal Information Processing Policy can be found on the website (https://www.linkro24.com).