Distancing Privacy Policy

Orwell Health Co., Ltd. (hereinafter referred to as the "Company") establishes and publicly discloses the following privacy policy to protect the personal information of users who use the "Distancing" service (hereinafter referred to as the "Service") in accordance with relevant laws and regulations, and to promptly and smoothly handle any related grievances.

Article 1 (Purpose of Processing Personal Information)

The Company processes personal information for the following purposes:

1. Membership registration and management: Confirmation of intent to register, identity verification, age verification, maintenance and management of membership qualifications, prevention of fraudulent use of services, confirmation of consent from the legal representative when processing personal information of children under 14 years old, various notifications
2. Provision of goods or services: Delivery of goods, provision of basic/customized services, sending of contracts/invoices, identity verification, age verification, payment and settlement of fees, debt collection
3. Grievance handling: Verification of user identity, confirmation of grievance details, contact/notification for fact-finding, notification of processing results
4. Marketing and advertising: Provision of customized advertising, provision of event and promotional information, and opportunities for participation
5. Service improvement and development: Improvement of existing services and development of new, customized services
6. Utilization of pseudonymized information: Use of pseudonymized information for the creation of statistics, scientific research, preservation of records for public interest, etc.

Article 2 (Personal Information Items Processed)

① The Company collects and processes the following personal information items for service users:

1. Basic collection items at the time of membership registration (mandatory): Email
2. Basic collection items for corporate member registration (mandatory): Workplace and department name
3. Collection items when using paid services

• When paying by credit card: Name, mobile phone number, credit card company name, credit card number, and other credit card information

1. Personal information items automatically collected during service use: IP address, cookies, service usage records (visit and usage history, bad usage records, etc.), device information (mobile phone model name, OS name, and version information), advertising identifiers
2. Information entered by members during service use: Due to the nature of the mental health management service, information related to personal health is collected through counseling and test sheets before applying for the service or during the provision of the service, and additional personal information such as occupation, educational background, counseling experience, psychiatric treatment experience, physical/mental complaints, and growth process may be included depending on the content and progress of the service.
3. During grievance handling: Collection and processing of necessary items among the above information and separate items required for the grievance handling

Article 3 (Processing and Retention Period of Personal Information)