Supplemental Korean Privacy Statement
We are Catchy Yazılım Limited Şirketi. This Supplemental Korean Privacy Statement (“Statement”) applies only to residents of the Republic of Korea and supplements our Catchy Yazılım Privacy Policy.
1. Personal Data Destruction Procedures & Methods
When personal data becomes unnecessary—either upon expiration of the retention period or fulfillment of the processing purpose—we promptly and securely destroy it following these steps:
- Destruction Procedures:
- Identify data due for disposal.
- Obtain approval from our Data Protection Officer.
- Securely destroy the identified data.
- Destruction Methods:
We store data electronically. To ensure irreversible destruction, we use methods that permanently delete electronic records (e.g., secure overwriting or degaussing).
If legal obligations require continued retention beyond the normal period, we retain only what is strictly necessary, after assessing the relevance of each data element.
2. Mandatory Retention Periods under Korean Law
| Law | Data Type | Retention Period |
|---|---|---|
| Protection of Communications Secrets Act | Login records & IP addresses | 3 months |
| Act on Consumer Protection in Electronic Commerce | Records of labeling & advertisement | 6 months |
| Records of contract/subscription cancellations | 5 years | |
| Records of payment & supply of goods | 5 years | |
| Records of consumer complaints or dispute settlement | 3 years | |
| Framework Act on National Taxes, Value‑Added Tax Act, Corporate Tax Act | Accounting books, transaction documents, tax invoices, receipts | 5 years |
3. Overseas Collection & Processing
We collect and process your personal data in Türkiye, the United Kingdom, the United States, Belgium, Ireland, and Israel.
4. Overseas Outsourcing & Storage
Legal Basis: Personal Information Protection Act Art. 28‑8(1)(iii) (outsourcing for contract performance)
| Recipient | Data Transferred | Country | Transfer Method | Purpose | Retention by Recipient |
|---|---|---|---|---|---|
| Google Cloud EMEA Limited<br/>([email protected]) | All user data | United States | Continuous over Internet | Cloud storage of user data | As per our Privacy Policy, until our contract ends |
| Amazon Web Services, Inc.<br/>([email protected]) | All user data | United States | Continuous over Internet | Cloud storage of user data | As per our Privacy Policy, until our contract ends |
| AppsFlyer Ltd.<br/>([email protected]) | Device ID, IDFV/IDFA | Belgium & Ireland | Continuous over Internet | User‑matching (with your consent) | Until you change your OS settings |
5. Overseas Disclosure to Third Parties
Legal Basis: Personal Information Protection Act Arts. 17(1)(i) & 28‑8(1)(i) (with consent)
| Recipient | Data Transferred | Country | Transfer Method | Purpose | Retention by Recipient |
|---|---|---|---|---|---|
| Meta Platforms, Inc.<br/>([email protected]) | IDFA, IP address, Services used, timestamps, inferred interests | USA | Continuous over Internet | Interest‑based targeted advertising | Until you toggle cookie settings in‑game |
| Google Ireland Limited<br/>([email protected]) | Same as above | Ireland | Continuous over Internet | Interest‑based targeted advertising | Until you toggle cookie settings in‑game |
| AppsFlyer UK Ltd.<br/>([email protected]) | Same as above | UK | Continuous over Internet | Interest‑based targeted advertising | Until you toggle cookie settings in‑game |
| Pecan AI Ltd.<br/>([email protected]) | Same as above | Israel | Continuous over Internet | Interest‑based targeted advertising | Until you toggle cookie settings in‑game |
| Unity Technologies<br/>([email protected]) | Same as above | USA | Continuous over Internet | Interest‑based targeted advertising | Until you toggle cookie settings in‑game |
If you do not want your data transferred overseas, you may refuse consent or ask us to stop transfers. However, refusal may prevent use of our Services.
6. Withdrawing Consent
You may withdraw consent to collection/use of personal data at any time by contacting us as described in the “Contact Us” section of our Privacy Policy.
7. Domestic Agent
We have not designated a separate domestic agent in Korea. For all inquiries or requests under Korean law, please contact our Data Protection Officer directly (contact below).
8. Contact Us
Data Protection Officer
Catchy Yazılım Limited Şirketi
Üniversiteler Mahallesi, İhsan Doğramacı Blv.
ARGE ve Eğitim Merkezi No: 13
06800 Çankaya / Ankara / Türkiye
Email: [email protected]