Cluster, Inc. (“we”, “our”, or “us”) processes the personal data collected in the course of and for the performance of “Cluster” service (the “Service”) from users of the Service. We recognize the importance of data protection for the users and establish this Privacy Policy for the Service (this “Policy”) to provide you with our data protection policy and your rights concerning your personal data. Please read this Policy carefully to understand our views and practices regarding your personal data and our processing of your personal data. Sections 1 to 15 of this Policy apply to all users of the Service. If you reside in the state of California, USA, the Notice for California Residents in Section 16 below shall additionally apply. If you reside in member states of the European Union and the Four EEA/EFTA states; Iceland, Liechtenstein, Switzerland and Norway (collectively, the “EU”) and the UK, the Notice for EU/UK Residents in Section 17 below shall additionally apply. If you reside in Taiwan, Section 18 below regarding Notice for Taiwan Residents shall additionally apply.

1. Definition of Personal Information

Personal information in this Policy means personal information as defined in Article 2, Paragraph 1 of the Act on the Protection of Personal Information of Japan.

2. Purpose of Use of Personal Information

We use personal information for the following purposes:

To provide the Service
To provide information on the Service and to respond to inquiries, etc.
To provide information on our products, services, etc.
To respond to violations of our terms, policies, etc. ("Terms") regarding the Service
To survey and analyze the usage of the Service
To notify you of changes to the Terms regarding the Service
To improve our services and develop new services
To resolve problems in the operation of the services we provide, including the Service
To monitor posts or other activities that infringe on the rights of others, violate the Terms, or are otherwise inappropriate, and removing or taking other action in response to such posts and other activities
To prevent and monitor unauthorized use of the services we provide, including the Service and to ensure their safety
To request your cooperation in surveys or participation in various events, and to report the results
To send you rewards for your cooperation in surveys, etc.
To send you prizes for your participation in prize competitions, etc.
To create statistical data related to our services, processed into a format that does not allow individuals to be identified
to serve advertisements to consumers on our applications based on the use of the Service and/or on third-party sites and applications
For other purposes incidental to the above purposes of use

3. Changes to the Purposes of Use of Personal Information

We may change the purposes of use of personal information to the extent that it is reasonably deemed to be relevant, and in the event of a change, we will notify the individual who is the subject of the personal information (the “Individual”) or publicly announce the change.

4. Restrictions on Uses of Personal Information

We will not handle personal information beyond the scope necessary for achieving the purpose of use without obtaining the Individual’s consent, except as permitted by the Act on the Protection of Personal Information or other laws and regulations. However, this does not apply in any of the following cases:

cases based on laws and regulations;
cases in which there is a need to protect the life, wellbeing, or property of an individual, and it is difficult to obtain the consent of the Individual;
cases in which there is a special need to improve public wellbeing or promote healthy child development, and it is difficult to obtain the consent of the Individual; or
cases in which there is a need to cooperate with a national government organ, local government, or person entrusted thereby with performing the functions prescribed by laws and regulations, and the consent of the Individual is likely to interfere with the performance of those functions.

5. Proper Acquisition of Personal Information

We will acquire personal information properly, and will not acquire personal information by deception or other wrongful means.

We will not acquire sensitive personal information (as defined in Article 2, Paragraph 3 of the Act on the Protection of Personal Information of Japan) without obtaining the Individual’s consent in advance, except cases set forth in the following:

when any of the cases set forth in the proviso of Section 4 above applies;
cases in which the sensitive personal information is open to the public by the Individual, a national government organ, a local government, an academic research institution or the equivalent, a person set forth in each item of Article 57, Paragraph 1, or other person prescribed by Order of the Personal Information Protection Commission;
we acquire message contents sent by users using the message function of the Service (please be noted that the messages sent through the Service’s functions are not closed communications between users, but rather three-way communications in which one user sends the message contents to the other user and us);
cases in which seemingly-clear sensitive personal information is acquired by visual observation, filming or photographing of an Individual; or
when receiving provision of sensitive personal information in a manner that is deemed not to constitute provision to a third party under the proviso of Section 7.1 below.

When receiving provision of personal information from a third party, we will confirm matters set forth in the following pursuant to Order of the Personal Information Protection Commission; provided, however, that this does not apply to cases in which the provision of personal information falls under any of the cases set forth in the proviso of Section 4 above or is made in a manner that is deemed not to constitute provision to a third party under the proviso of Section 7.1 below:

the name and address of the third party and, if the third party is a corporation, the name of its representative (in the case of an unincorporated association with a designated representative or manager, the name of the representative or manager); and
background of the acquisition of the personal information by the third party.

6. Managing Security of Personal Information

We will exercise necessary and adequate supervision over our employees to ensure the secure management of personal information against risks such as loss, destruction, falsification, and leakage of personal information. In addition, when we entrust all or part of the handling of personal information, we will exercise necessary and adequate supervision over the entrusted person, so as to ensure the secure management of the personal information.

7. Provision to Third Parties

We will not, except in the cases set forth in the proviso of Section 4 above, provide personal information to a third party without obtaining the prior consent of the Individual. However, the following cases do not fall under the provision to a third party as stipulated above:

Cases in which we provide personal information in connection with our entrustment of all or part of the handling of the personal information within the scope necessary for achieving the purpose of use;
Cases in which personal information is provided as a result of the succession of business in a merger or otherwise; or
Cases in which we use personal information jointly with a specific individual or entity in accordance with the Act on the Protection of Personal Information of Japan.

Notwithstanding the provisions of Section 7.1 above, except cases set forth in the proviso of Section 4 above, before we provide personal information to a third party (excluding those that have established a system that conforms to standards prescribed by Order of the Personal Information Protection Commission in accordance with Article 28, Paragraph 1 of the Act on the Protection of Personal Information of Japan) in a foreign country (excluding those prescribed by Order of the Personal Information Protection Commission in accordance with Article 28, Paragraph 1 of the Act on the Protection of Personal Information of Japan), we will obtain the Individual’s consent to the effect the Individual approves the provision to a third party in a foreign country.

When providing personal information to a third party, we will prepare and keep records in accordance with Article 29 of the Act on the Protection of Personal Information of Japan.

When receiving provision of personal information from a third party, we will perform the necessary confirmation in accordance with Article 30 of the Act on the Protection of Personal Information of Japan, and will prepare and keep records related to such confirmation.

We outsource credit card payment processing in Cluster to a third-party service provider. Please note that your credit card information is stored and managed by this service provider, and we do not store such information.

8. Disclosure of Personal Information

If we receive a request for disclosure of personal information from an Individual in accordance with the provisions of the Act on the Protection of Personal Information of Japan, we will, after confirming that the request is made by the Individual themselves, disclose the personal information to the Individual without delay (if the relevant personal information does not exist, we will notify the Individual to that effect). However, this does not apply to cases in which we are not obligated to disclose the personal information under the Act on the Protection of Personal Information of Japan or other laws and regulations. Please note that a fee (1,000 JPY per request) will be charged for the disclosure of personal information, except as otherwise provided by applicable laws and regulations or where there are reasonable grounds.

9. Corrections of Personal Information

If we receive from an Individual a request for correction, addition, or deletion of personal information (collectively "Correction") on the grounds that the content of personal information is not factual, we will, after confirming that the request is made by the Individual themselves, conduct the necessary investigation without delay to the extent necessary to achieve the purpose of use, make Correction of content of the personal information based on the results, and notify the Individual to that effect (if we decide not to make such Correction, we will notify the Individual to that effect). However, this does not apply to cases in which we are not obligated to make such Correction under the Act on the Protection of Personal Information of Japan or other laws and regulations.

10. Ceasing to Use or Deleting Personal Information

If we receive, from an Individual, a request to cease using or delete their personal information ("Cessation of Use or Deletion") in accordance with the provisions of the Act on the Protection of Personal Information of Japan on the grounds that the personal information is handled beyond the scope of the purpose of use publicly announced in advance or that the personal information was obtained through deception or other wrongful means, or a request to cease providing their personal information to a third party (“Cessation of Provision”) in accordance with the provisions of the Act on the Protection of Personal Information of Japan on the grounds that the personal information is provided to a third party without the Individual’s consent, and there are found to be grounds for the request, we will, after confirming that the request is made by the Individual themselves, implement Cessation of Use or Deletion or Cessation of Provision of the personal information without delay and notify the Individual to that effect. However, this does not apply to cases in which we are not obligated to make such Cessation of Use or Deletion or Cessation of Provision under the Act on the Protection of Personal Information of Japan or other laws and regulations.

11. Handling of Anonymized Personal Information

When preparing anonymized personal information (as defined in Article 2, Paragraph 6 of the Act on the Protection of Personal Information of Japan, and limited to those compiled in an anonymized personal information database or the equivalent defined in Article 16, Paragraph 6; the same applies hereinafter), we will process personal information in accordance with standards prescribed by Order of the Personal Information Protection Commission.

When having prepared anonymized personal information, we will take measures for the management of the security thereof in accordance with standards prescribed by Order of the Personal Information Protection Commission.

When having prepared anonymized personal information, we will disclose the categories of information on an individual that is contained in the anonymized personal information, pursuant to Order of the Personal Information Protection Commission.

We will, before providing anonymized personal information (including those we prepare or provided by a third party; the same applies hereinafter unless otherwise provided) to a third party, disclose the categories of information on an individual that is contained in the anonymized personal information we provide to the third party, and the means of the provision, and state to the third party explicitly that the information we provide is anonymized personal information, pursuant to Order of the Personal Information Protection Commission.

When handling anonymized personal information, we will not, in order to identify the Individual identifiable by the personal information used to prepare the anonymized personal information, (1) collate the anonymized personal information with other information, nor, only for anonymized personal information provided by a third party, (2) acquire information relating to identifiers or their equivalent or individual identification codes deleted from the personal information and information relating to methods of processing carried out pursuant to the provisions of Article 43, Paragraph 1 or Article 116, Paragraph 1 (including cases in which it is applied mutatis mutandis pursuant to Article 116, Paragraph 2).

We will endeavor to take the necessary and appropriate measures for managing the security of anonymized personal information and the necessary measures to ensure the proper handling of anonymized personal information such as processing complaints about the preparation and other handling of anonymized personal information, and will endeavor to disclose the content of those measures.

12. Use of Cookie and Other Technologies

Our services use cookies and similar technologies. Those technologies help us understand how our services are being used and help us improve our services. Users who wish to disable cookies may do so by changing the settings on their web browsers. However, if you disable cookies, you may not be able to use some of the features of our services.

For details on the use of cookies, etc., please refer to our External Transmission Policy or the Details described in the Cookiebot which appears as a cookie banner.

Use of YouTube API services

Our service uses YouTube API services for comment integration with YouTube Live.

YouTube API services are provided in accordance with Google's Privacy Policy and YouTube's Terms of Service. In addition, by using Our services, users are deemed to have agreed to each of the following terms of use.

Please see below for YouTube's Terms of Service, YouTube API services Terms of Use, and Google Privacy Policy.

Google Privacy Policy

https://www.google.com/intl/ja/policies/privacy/

YouTube Terms of Service

https://www.youtube.com/t/terms

YouTube API Services Terms of Service

https://developers.google.com/youtube/terms/api-services-terms-of-service

13. Information of Children

As used in this Section, the term “child” or “children” means those under the age of 13, and the term “parent” includes legal guardians.

Our Services are intended for a general audience and are not targeted at children. We do not knowingly collect, use or share any personal data about children without verifiable parental consent or as permitted by law. If you are a parent and you believe your child has provided us with personal data, please contact us and request that your child’s information be deleted from our system. If we learn that we have inadvertently collected personal data from children, we will deactivate the relevant account(s) and take reasonable measures to promptly delete such personal data from our records.

If you are a child, your parents must agree to the terms of this Privacy Policy and Terms of Use and comprehensively agree to your use of the Service in accordance with the Privacy Policy and Terms of Use.

14. Contact Us

Data Controller

We are responsible for your personal data as a data controller. If you have any question or would like to exercise your rights, please contact us at:

Mail: Cluster, Inc.

FORECAST Gotanda WEST 10F

8-9-5, Nishigotanda

Shinagawa, Tokyo, 141-0031

Customer Support Form

15. Continuous Improvement

We will review the operational status of the handling of personal information from time to time and strive for continuous improvement. Accordingly, we may change this Policy as necessary, in which case we will inform you.

16. Notice for California Residents

Information We Collect

We collect information that identifies, relates to, describes, references, and is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”). In particular, we can collect, and have collected some categories in the last twelve (12) months, the following categories of Personal Information from our consumers:

Category	Examples
A. Identifiers.	Real name, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name or other similar identifiers.
B. Financial Information	Credit card number, or other financial information.
C. Commercial information	Records of services purchased.
D. Internet or other electronic network activity information.	Information on your interaction with an application or advertisement.
E. Audio, electronic, visual, or similar information	Voice records and profile pictures.
F. Inferences	Inferences drawn from the above information to create a profile reflecting the consumer’s preferences or behavior.

We obtain your Personal Information listed above directly or indirectly from you in our relationship with you, including, without limitation, when you: (i) make your personal account for the Service; (ii) link your social media account with your personal account for the Service; (iii) access or use the Service; and (iv) communicate with us for inquiries about the Service.

Use of Personal Information

We may use the Personal Information for one or more of the business purposes indicated in Section 2 above.

We will not collect additional categories of Personal Information or use the Personal Information we collect for materially different, unrelated or incompatible purposes without providing you notice thereof.

Disclosure of Personal Information

We are committed to maintaining your trust, and we want you to understand when and with whom we may share the information we collect. We may disclose your Personal Information to:

Authorized third-party vendors and service providers. We share your Identifiers; Financial Information; Commercial Information; Internet or Other Electronic Network Activity Information; Audio, Electronic, Visual, or Similar Information; and Inferences with third-party vendors and service providers that provide services to us for a variety of business purposes, such as billing, payment processing, customer service, email deployment, advertising and marketing (including counting ad impressions, verifying positioning and quality of ad impressions, ensuring compliance with industry standards and specifications, ad delivery, reporting, personalization, audience segmentation, and analytics), security and performance monitoring, maintaining or servicing accounts, processing or fulfilling orders and transactions, verifying customer information, research, data hosting, auditing, and data processing.
Corporate affiliates. We may share Identifiers; Financial Information; Commercial Information; Internet or Other Electronic Network Activity Information; Audio, Electronic, Visual, or Similar Information; and Inferences with our corporate affiliates.
Business transfers. We may share any of the information we collect in connection with a substantial corporate transaction, such as the sale of a service, a merger, consolidation, asset sale, initial public offering, or in the unlikely event of bankruptcy.
Legal purposes. We may disclose any of the information we collect to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims or government inquiries, and to protect and defend our rights, interests, safety, and security, users, or the public.
With your consent. We may share information for any other purposes disclosed to you at the time we collect the information or pursuant to your consent.

If you access third-party services -- such as social media services, mobile platforms for in-app purchases -- through the Services, these third-party services may be able to collect information about you, including information about your activity on the Service, and they may notify your connections on the third-party services about your use of the Service, in accordance with their own privacy policies.

If you choose to engage in public activities on the Services, you should be aware that any information you share there can be read, collected, or used by other users of these areas. You should use caution in disclosing information while participating in these areas. We are not responsible for the information you choose to submit in these public areas.

Sale or Sharing of Personal Information

We do not sell your Personal Information to third parties for money or other valuable consideration. When you use our Services, we may share your Personal Information with our third party advertising partners (including advertising networks and exchanges, data analytics providers, operating systems and platforms, and social networks)) using cookies, pixels, and other similar technologies (collectively, “cookies”) to collect information from your browser or device and use it for cross-contextual behavioral advertising to you on our Service and across other services and devices. By using the Services, you consent to our use of cookies and similar technologies. We do not knowingly sell or share Personal Information about consumers under the age of 16.

Your Rights and Choices under Applicable Law

Depending on where you live, you may have several rights in relation to our processing of your Personal Information in accordance with applicable law, which may include, the right to request access to, correct or delete your Personal Information. They may also include the ability to opt-out of receiving notifications, promotions, offers or other advertising from us.

If you are a California resident, the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively the “California Privacy Law”) provide specific rights regarding Personal Information to consumers who are residents of California. The following parts of this Section describe our data practices as well as your rights under the California Privacy Law and explain how to exercise those rights. Please note that each of these rights is subject to statutory exceptions and limitations.

(1) Right to Know What Personal Information is Being Collected / Right to Access Personal Information

You have the right to request that we disclose certain information to you about our collection, sharing, disclosure or use of your Personal Information over the past twelve (12) months from the time of your request. Once we receive and confirm your verifiable consumer request, we will disclose to you any or all of the following information:

The categories of personal information we have collected about you.
The categories of sources from which the personal information is collected.
The business or commercial purpose for collecting, selling, or sharing personal information.
The categories of third parties to whom we disclose personal information.
The specific pieces of personal information we have collected about you.

(2) Right to Request Deletion

You have the right to request that we delete Personal Information that we have collected from you and retained, subject to certain exceptions. Upon receiving and confirming your verifiable consumer request, we will delete (and direct our service providers or contractors to delete) your Personal Information from our records, unless an exception applies.

(3) Right to Request Correction of Inaccurate Personal Information

You have the right to request that we correct inaccurate Personal Information that we have collected from you and retained, subject to certain exceptions. Upon receiving and confirming your verifiable request, we will correct (and direct our service providers or contractors to correct) your inaccurate Personal Information from our records, unless an exception applies.

(4) Opt-Out Rights

You have the right to opt-out of the sale and sharing of your Personal Information that we have collected from you and retained.

To exercise your opt-out right under the California Privacy Law, please contact us at :

Customer Support Form

(5) Non-Discrimination

We will not discriminate against California residents for exercising any of their rights under the California Privacy Law. Moreover, unless permitted by the California Privacy Law, we will not:

Deny you goods or services;
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
Provide you with a different level or quality of goods or services; or
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

(6) Exercising Rights under the California Privacy Law

To exercise your rights under the California Privacy Law to access, delete or correct your Personal Information as described above, please submit a verifiable consumer request to us by contacting us in the manner set forth in Section 14 (Contact Us).

Only you, or an agent authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify that you are the person whose Personal Information we have collected or an authorized representative thereof (e.g., the account name, email address, etc.); and
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond thereto.

Retention Period

We retain your Personal Information for as long as needed for the purposes described in this Policy. The criteria used to determine our retention period include, without limitation: (i) the duration of our ongoing relationship with you; (ii) whether there is any legal obligation to which we are subject; and (iii) whether there is a need to perform a contract to which you are a party.

17. Notice for EU/UK Residents

Lawful Processing

We will only process your personal data:

where you have given your consent;
where the processing is necessary to provide our products or services to you;
where the processing is necessary to respond to a request from you;
where the processing is necessary to maintain our relationship with you;
where the processing is necessary for compliance with our legal and regulatory obligations; or
where the processing is necessary in order to protect the vital interest of the data subject.

What Personal Data We Collect About You

We collect and process the following personal data in the context of the Service:

Personal Data You Provide

Account Information: When you register an account in the Service, you may need to provide us with your name, date of birth, postal address, e-mail address, profile pictures, and bank account number.

Personal Data We Collect Automatically

Usage Information: When you interact with the Service, we automatically collect technical data regarding your usage of the Service, including:
- records of services purchased;
- online identifier, including cookie and IP address;
- information on your interaction with an application or advertisement;
- audio, electronic, visual, or similar information, including voice records and profile pictures;
- data such as PDFs and videos in files in Cluster;
- behavioral and voice data in Cluster;
- comments in public and private worlds;
- messages with friends in Cluster; and
- information on the location as a country or at the regional level (from which countries/regions accessed)

Personal Data Provided from Third Parties

Login features: When you use your third-party service account, we can collect your data:
- ID, username, registered email address and profile photo for these accounts.
Financial information: Credit card payment when you make a purchase within Cluster, we can collect your data:
- Credit card expiry date; and
- last 4 digits of the card number.

You are required to provide us with certain personal data when you create an account for or log-in to the Service. Personal data that is mandatory is indicated in the relevant forms. We are not able to provide the Service to you if such data is not provided.

We obtain your personal data listed above directly or indirectly from you in our relationship with you, including, without limitation, when you: (i) make your personal account for the Service; (ii) link your social media account with your personal account for the Service; (iii) access or use the Service; and (iv) communicate with us for inquiries about the Service.

How We Use Personal Data

We use your personal data for the purposes set out in Section 2.

We will not collect additional categories of personal data or use the personal data we collect for materially different, unrelated or incompatible purposes without providing you notice thereof.

Disclosure of Personal Data to Third Parties

We may disclose your personal data to the third parties as indicated in Section 16.3 above.

International Data Transfers

The Service is controlled and operated from Japan and the files containing your personal data will be maintained on our servers or those of our IT service providers located in Japan. As the European Commission and the UK Secretary of State has confirmed that the laws in Japan offer an adequate level of protection of personal data as are enjoyed within the European Economic Area (“EEA”) and/or the UK, we will process your personal data with the same level of protection as in the EEA and/or the UK and recognise your rights on your personal data you would hold under the GDPR.

Where we share your personal data with our group companies in Japan, we will rely on the decision by the European Commission and the UK Secretary of State in accordance with Article 45 of GDPR that the laws in Japan offer an adequate level of data protection as are enjoyed within the EEA and/or the UK. The relevant adequacy decisions is available here.

We may also share your personal data with other group companies and other third parties (set out in Section 4 above) located in countries in which laws do not offer the same level of protection of personal data as are enjoyed in countries inside the EEA and/or the UK. In such cases, we will ensure that any such international transfers are made subject to appropriate or suitable safeguards as required by the GDPR, such as the “standard contractual clauses”. You can obtain copies of the relevant safeguard documents by contacting us at the Contact Information specified in Section 14 above.

How We Protect Your Personal Data

We are committed to safeguarding and protecting your personal data and will implement and maintain appropriate technical and organisational measures to ensure a level of security appropriate to protect your personal data from accidental or unauthorised destruction, loss, alteration, disclosure or access.

We have security measures that are intended to protect any personal data or other sensitive information under our control from loss, misuse, or alteration. Though we cannot guarantee that loss, misuse or alteration of information will never occur, we use reasonable efforts to prevent it.

Sending or storing information on the Internet is not 100% secure, so we can’t guarantee the security of any information you share with us. To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure.

Your Rights

You have the following rights regarding personal data we collected and processed about you:

Access to personal data: the right to obtain access to the personal data which we hold about you;
Rectification of personal data: the right to request us to rectify your personal data if it is inaccurate or incomplete;
Erasure of personal data: the right to request us to erase your personal data in certain circumstances;
Restriction on processing of personal data: the right to request us to restrict our processing of your personal data in certain circumstances;
Data portability of personal data: the right to receive any personal data which we process about you on the basis of the performance of a contract with you or your consent (as opposed to any other legal ground) in a structured, commonly used and machine-readable format and/or request that we transmit that data to a recipient where this is technically feasible;
Object to processing of personal data: the right to object to us about our processing of your personal data;
Withdraw consent to our processing of your personal data: the right to withdraw your consent to our processing of your personal data at any time (please note, however, that we may still be entitled to process your personal data if we rely on another legal ground for doing so); and
Lodge a complaint with the data protection authority: the right to lodge a complaint with the data protection authority if you think that any of your rights have been infringed by us.

Retention Period

We store personal data for the time required to carry out the purpose indicated above in Section 3 above, or for the time specified by laws and regulations. When your personal data is no longer needed, we will promptly take measures to delete or anonymize it in a safe way.

Our representative

Our data protection officer and representative in EU and UK are The Classmethod (Europe) GmbH. You can contact them at:

Mail: Krausenstr. 9 -10, 10117 Berlin, Germany
E-mail: cluster@gdpr-contact.email

18. Notice for Taiwan Residents

Sensitive Personal Information

We do not collect, process, or use personal information concerning medical records, medical treatment, genetic information, sexual life, health examination, and criminal records, except in the following cases:

Where there are express provisions of law;
Where it is necessary for a government agency to perform its duties or for a non-government agency to fulfill its legal obligation, and proper security measures are adopted prior or subsequent to such collection, processing, or use;
Where the personal information has been disclosed by the data subject or has been legally disclosed;
Where the collection, processing, or use of personal information is necessary for statistical or academic research purposes by government agencies or academic research institutions, and the information has been processed by the provider or disclosed by the collector in such a manner that the specific data subject cannot be identified;

Where it is necessary to assist government agencies in performing their legal duties or non-government agencies in fulfilling their legal obligations, and proper security measures are adopted prior or subsequent to such collection, processing, or use;

Where written consent has been given by the data subject. However, this shall not apply where the collection, processing, or use of personal information exceeds the necessary scope of the specific purpose, where other laws prohibit such collection, processing, or use with mere written consent from the data subject, or where the consent is against the data subject's will.

Personal Information Obtained from Third Parties

When receiving personal information from a third party other than the data subject, we shall inform the data subject of the following matters before processing or using such personal information or at the time of first use:

The name of our company;
The purpose of collection;
The type of personal information;
The period, area, recipients, and methods of using the personal information;
That the data subject has the right to make the following requests and the methods to exercise such rights:
- To query or review their personal information;
- To request a copy of their personal information;
- To supplement or correct their personal information;
- To request to cease the collection, processing, or use of their personal information;
- To request deletion of their personal information.

However, this notification requirement shall not apply in any of the following circumstances:

Use of Personal Information Beyond Original Purpose

Personal information may be used beyond the original purpose of collection in any of the following circumstances:

- Where there are express provisions of law;

- Where it is necessary for promoting public interests;

- To prevent harm to the life, body, freedom, or property of the data subject;

- To prevent serious damage to the rights and interests of others;

- Where it is necessary for academic research institutions to conduct statistical or research analysis in the public interest, provided that such information has been processed by the provider or disclosed by the collector in such a manner that the specific data subject cannot be identified;

- Where written consent has been given by the data subject;

- Where such use benefits the rights and interests of the data subject.

Security of Personal Information

In the event of a theft, leak, alteration, or other infringement of personal information due to a violation of the Personal Data Protection Act by a government agency or non-government agency, we shall notify you through appropriate methods after clarification.

Deletion of Personal Information

a. When you terminate your Cluster account, we shall consider the specific purpose of collecting, processing, and using personal information to have been achieved and shall delete, cease processing, or cease using such personal information, except in any of the following circumstances:

- Where there are special provisions in the law;

- Where there is consent from the parties in a contract or similar written document;

- Where it is necessary for the performance of our business operations.

b. When deleting personal information pursuant to the preceding paragraph, we shall take measures to ensure that the personal information cannot be restored or reused through any of the following methods:

- For electronic data, deletion through methods that prevent restoration;

- For paper documents, destruction through shredding, dissolution, or other methods that prevent restoration of the personal information;

- Other appropriate methods that achieve the purpose of personal information protection.

Articles in this section