Privacy Policy for Mentee Members

PRIVACY POLICY (English)

Effective Date: [2025-10-10]

Company: C.Luv Co., Ltd. (㈜씨럽)

Contact: info@shoulders-c.com

| +82-10-9392-0531

We value your privacy and process personal information in compliance with applicable laws, including the Personal Information Protection Act of Korea and other relevant regulations.

1. What We Collect

We collect the following categories of personal information:

A) Student/Parent Members (required)

ID (username), nickname, name, gender, date of birth/age, mobile phone number, region/city.

Optional: account details for benefits or refunds; profile information you choose to add (e.g., school, grades, photos).

B) Tutor Members (required)

ID, nickname, name, gender, date of birth/age, mobile phone number, education information (school, student ID, enrollment/graduation status), and identity/credential documents reasonably requested for verification (e.g., student card image, enrollment or graduation certificate).

Optional: documents for business/lesson verification (e.g., private tutor filing certificate, business registration), bank account info for settlements or refunds, additional profile information (e.g., prior schools, records).

C) Service & Payment Data

Service usage logs (visit time, actions), device and app identifiers, IP address, cookies (see Section 8), payment/settlement data as needed by the payment method (card issuer, masked card number, approval code; bank name and account for transfers; mobile carrier for mobile billing), and records related to customer support.

We do not collect national ID (resident registration number) by default. If any law requires identity verification, we use telecom PASS identity verification providers (see Section 4).

2. How We Use Personal Information (Purposes)

Service delivery & contract performance: account creation, authentication, providing tailored features, notices, purchases and billing, settlements, and benefits.

Member management: identity verification, prevention of fraud and abuse, dispute resolution, records retention, and customer support.

Service improvement & marketing: service analytics, developing new features, offering events/benefits, and providing marketing communications where you consent (you may opt out at any time).

Legal compliance: responding to lawful requests and complying with applicable laws.

3. Retention

We retain personal information only as long as necessary for the purposes above or as required by law. Statutory retention includes, for example:

Contracts and service use records: 3 years

Payment and supply records: 5 years

Electronic financial transaction records: 5 years

Consumer complaints/dispute records: 3 years

Advertising records: 6 months

Website access logs: 3 months

When retention periods expire or purposes are achieved, we securely delete or anonymize data.

4. Identity Verification (PASS)

To prevent duplicate or fraudulent sign-ups and to verify identity, we may use PASS verification via the following providers: ATON Inc., SK Telecom Co., KT Corp., LG Uplus Corp.

Data used: name, date of birth, gender, mobile number, device identifier (DI).

Retention: until the purpose is fulfilled or as required by law.

5. Sharing & Third-Party Disclosures

We do not disclose personal information to third parties without your consent, except:

Where you consent (e.g., sharing limited Tutor identity information to a Student upon request for safety/verification);

To comply with legal obligations or lawful requests;

To service providers (processors) under contract to process data on our behalf (e.g., hosting, analytics, payment, customer support). We supervise processors and limit use to our instructions.

6. Processing by Service Providers (Outsourcing)

We may engage processors for: hosting, storage, analytics, notifications (email/SMS/push), identity verification, and payments. We require processors to protect personal information and restrict use to contracted purposes. We will notify you of material changes to processors via this Policy.

7. Destruction of Personal Information

When data is no longer needed, we securely delete it:

Electronic files: irreversible deletion methods;

Paper: cross-cut shredding or incineration.

Deletion is approved by the Data Protection Officer (DPO) and recorded.

8. Cookies & Similar Technologies

We use cookies and similar technologies to operate and improve the Service, remember preferences, analyze usage, and measure performance. You can manage cookies via your browser settings; disabling cookies may limit certain features.

9. Security Measures

We employ administrative, technical, and physical safeguards, including encryption in transit and at rest where appropriate, access controls, least-privilege principles, regular security training, monitoring, and secure facilities.

10. Your Rights

You may access, correct, or delete your personal information, request suspension of processing, or withdraw consent, subject to legal limitations. Use in-app settings or contact us at info@shoulders-c.com. We will respond without undue delay. If data was shared with third parties as permitted, we will notify them of corrections or deletions where feasible.

11. Children

We do not knowingly collect personal information directly from children under 14. If we become aware of such collection without appropriate guardian consent, we will delete it promptly. For parent-initiated features involving a child (e.g., verification), we rely on the parent/guardian’s lawful authority and consent.

12. International Transfers

Your information may be processed outside your country (including outside Korea) by us or our processors. Where required, we implement appropriate safeguards (e.g., contractual clauses) to protect your information.

13. Inquiries & DPO

Data Protection Officer (DPO): Jihoo Moon

Email: info@shoulders-c.com

Phone: +82-10-9392-0531

You may also contact relevant authorities for advice or complaints (e.g., Korea Personal Information Protection Commission).

14. Updates to this Policy

We may update this Policy to reflect changes in law or our practices. We will notify you at least 7 days before material changes take effect via in-app notice or website posting. Prior versions will be archived for your review.