Privacy Policy

Fingerlabs Inc. (hereinafter the “Company”) collects personal information (hereinafter “Personal Information”) in the course of providing all products, applications, websites, and services (hereinafter “Services”) related to Xclusive. We collect only the minimum required personal information at the time it is needed, and use it only within the scope notified to and agreed upon by the user. The Company will not use or disclose any personal information beyond the agreed scope without prior consent.

To protect users' personal information, the Company complies with the applicable laws and regulations of the countries and regions where it operates and establishes this Privacy Policy to ensure safe handling of personal information.

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

The Company collects only the minimum necessary personal information for service provision. The items collected and the methods of collection are as follows:

Collection TimeCollected ItemsCollection MethodUpon sign-upEmail, name, date of birth, nationality, mobile phone numberInput via registration formUpon purchasing pointsPayment history, payment method (e.g., card issuer, PG provider)Indirect collection via payment APIDuring content usageViewing history, access time, IP address, browser info, device info (OS, model), cookie infoAutomatic collectionWhen participating in eventsName, email, mobile phone numberSeparate entry upon event participation

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

The Company uses collected personal information for the following purposes:

1. Member identification and account management

2. Point recharge and payment history verification

3. Usage of paid content and unlocking episodes

4. Responding to customer inquiries and improving services

5. Managing events and notifying winners

6. Record keeping for legal compliance

Article 3 (Retention and Use Period of Personal Information)

ItemRetention PeriodMember registration info1 year after account deletion, then deletedPayment and purchase historyRetained for 5 years per e-commerce lawEvent participation infoDeleted 6 months after event endsService usage recordsAutomatically deleted after 1 year

※ However, if preservation is required by applicable law, such data will be stored separately in accordance with such laws.

Article 4 (Provision to Third Parties and Outsourcing of Personal Information Processing)

The Company does not disclose personal information to external parties except in the following cases:

1. Provision to third parties

   • None (If needed, provision will be made only after obtaining prior consent)

2. Outsourcing of personal information processing

SubcontractorPurpose of OutsourcingPayletter (PG)Point payment processing and verificationAmazon Web ServicesCloud infrastructure operation and data storage

※ The Company includes compliance with personal information protection laws in its outsourcing agreements and supervises the subcontractors accordingly.

Article 5 (Overseas Transfer of Personal Information)

The Company uses Amazon Web Services (AWS) Korea region, and therefore no cross-border transfer of personal information occurs. If overseas transfer becomes necessary in the future, the Company will comply with legal requirements for prior notice and consent.

Article 6 (User Rights and Exercise Methods)

Users may exercise the following rights regarding their personal information at any time:

• Request to access, modify, or delete personal information

• Request to suspend processing

• Withdraw consent and request account deletion

• Request data portability (if technically feasible)

Article 7 (Destruction of Personal Information)

The Company destroys personal information without delay once the retention period has expired or the purpose of processing has been fulfilled.

• Electronic files: Irreversibly deleted using secure technology

• Printed documents: Shredded or incinerated

Article 8 (Cookies and Automated Data Collection Tools)

The Company may use cookies and Google Analytics to collect service usage statistics.

• Cookies can be disabled via browser settings

• Google Analytics Privacy Policy: https://policies.google.com/privacy

Article 9 (Personal Information Protection Officer and Contact Information)

Personal Information Protection Officer: Sungyoung Byun

Email : xclusive_official@fingerlabs.io

Contact Number : +82-2-552-9510

Users may contact the officer at any time for privacy-related inquiries or complaints.

Addendum

This Privacy Policy shall take effect on April 14, 2025.