Privacy Policy

1. Terms of Service

Chapter 1: General Provisions

Article 1 (Purpose)
These Terms of Service ("Terms") govern the rights, responsibilities, and other necessary matters between “Kookie” (“Company”) and users (“Customer”) of the “Surebet Cal Pro” application (“Service”).

Article 2 (Governing Law)
Matters not covered by these Terms shall be governed by relevant laws such as the Act on the Protection and Use of Location Information, the Telecommunications Business Act, the Act on Promotion of Information and Communications Network Utilization and Information Protection, and the Company’s detailed usage guidelines.

Chapter 2: Service Usage

Article 3 (Eligibility)
Anyone who can install the application is eligible to use the Service.

Article 4 (Service Registration)

  1. The Service is considered registered once the user agrees to these Terms as required by the App Administrator.

  2. The App Administrator may reject a registration request under the following conditions:

    • Missing or incorrect user information.

    • The request violates public order or moral standards.

    • Other criteria set by the Company are not met.

Article 5 (Service Withdrawal)
Users may unsubscribe from the Service via the designated procedure in the settings menu. If no menu is provided, uninstalling the application will also result in termination of the Service.

Article 6 (Service Availability)

  1. The Service is available 24/7, year-round. However, it may be suspended temporarily due to technical or operational reasons (e.g., server maintenance, third-party infrastructure issues), in which case users will be notified in advance or afterward.

  2. Location information may contain inaccuracies due to technical limitations.

Article 7 (Restrictions and Termination)
The Company may restrict or terminate service use without prior notice if the user:

  • Disrupts another person’s service or steals their personal information.

  • Uses the Service for illegal or inappropriate conduct.

  • Intentionally interferes with the Company’s operations.

Article 8 (Service Modifications or Suspension)

  1. The Company may modify or suspend the Service in part or whole due to:

    • System maintenance.

    • Power outages, equipment failure, or traffic overload.

    • Termination of contracts with service partners or legal reasons.

    • Force majeure events such as natural disasters or national emergencies.

  2. In such cases, notice will be provided via the internet or directly to users. No compensation will be provided for interruptions beyond the Company’s control.

Chapter 3: Miscellaneous

Article 9 (Company Information)
Company Name: Kookie

Article 10 (Non-Transferability)
Users may not assign or transfer any rights, obligations, or positions under this agreement to any third party.

Article 11 (Liability for Damages)

  1. If the user violates these Terms and causes damage to the Company, they shall compensate the Company in full.

  2. If a third party files a complaint or lawsuit due to the user's actions, the user must cover all related damages.

  3. The Company is liable for damages caused to users due to a violation of applicable laws unless it proves lack of intent or negligence.

Article 12 (Disclaimer)

  1. The Company is not liable for service interruptions due to force majeure.

  2. The Company is not responsible for service issues caused by the user.

  3. The Company is not liable for users’ loss of expected profits or damages from using the Service.

  4. Users are solely responsible for decisions made using information from the Service.

  5. If technical issues delay service, the Company will notify users via email or website. If prior notice is impossible, it will be made afterward.

Article 13 (Dispute Resolution and Jurisdiction)

  1. The Company and users shall attempt to resolve disputes through good-faith negotiation.

  2. If unresolved, disputes may be submitted to the Personal Information Dispute Mediation Committee in accordance with relevant laws.

2. App Permissions

To use the app, optional permissions for camera, location, and storage may be requested.

3. Collection and Use of Personal Information

Purpose of Collection
Personal information is collected for enabling community features such as posting, commenting, and liking content.

Collected Information

  • Email, password, nickname (name), phone number

  • Collected during sign-up via the app

4. Third-Party Sharing

The Company does not share your personal information with third parties beyond the scope stated above.

5. Retention and Destruction of Personal Data

  • Information is destroyed within 1 year of withdrawal or when the purpose of use is achieved.

  • Destruction method:

    • Paper documents: Shredded or incinerated.

    • Electronic files: Deleted using non-recoverable methods.

6. Data Processing Outsourcing

  • Outsourced to: HM Solution

  • Scope: App development and system maintenance

  • Only necessary information is shared and handled securely.

7. User Rights

Users or their legal representatives may request corrections or deletions of their personal data at any time via written request, email, or phone. The Company will promptly act on such requests.

8. Cookies and Automatic Data Collection

The app does not use cookies or automatic data collection mechanisms.

9. Privacy Officer Contact

  • Privacy Officer: Hyungmin Lee

  • Department: Support Team

  • Phone: +82-31-994-3454

  • Email: exitsub10@gmail.com

For inquiries or complaints related to personal information, users may also contact:

  • Personal Dispute Mediation Committee: www.1336.or.kr / 1336

  • ePrivacy Committee: www.eprivacy.or.kr / +82-2-580-0533~4

  • Prosecutor's Office Cyber Crime Center: icic.sppo.go.kr / +82-2-3480-3600

  • National Police Cyber Bureau: www.ctrc.go.kr