Privacy Policy

Last Updated: Nov 3rd, 2022

This Policy (hereinafter the “Policy”) explains the way of process of information provided or collected in the websites and/or services, including applications, on which this Policy is posted. In addition, the Policy also explains the information which is provided or collected in the course of using the applications of LUXON FOUNDATION (hereinafter, the “Company”) which exist in the websites or platforms of other companies. The Company is the controller of the information provided or collected in: (a) the services on which this Policy is posted, and (b) the course of using the applications of the Company.

Through this Policy, the Company regards personal information of the users (hereinafter, the “user” or “you”) as important and informs users of the purpose and method of the use of personal information provided by the users and the measurements taken by the Company for protection of the personal information.

In case this Policy is modified, the Company will make public notice by posting on the bulletin board of the Company's service (or individual notice by sending mail, fax, or emails).

Article 1Information collected and method of collection

(1) Personal information collected

Personal information collected by the Company are as follows:

- Information provided by users

The Company may collect the following information directly from users.

Title of Service

Information collected


- wallet address, user name

Customer Service

- email address, wallet address, Exos Heroes game account NID, DESPERADO B218 game account NID, personal information user provides for resolving inquiries

Personalized Advertising

- Website visit history of the user, application usage history of the user, search history of the user, advertising ID


- SNS ID, email address, wallet address, nickname, equipment information

- Information collected during service usage by users

Besides information provided directly by users, the Company may collect information in the course of users’ use of the service


Information collected

Equipment information

Equipment identifier, operation system, hardware version, equipment set-up, type and set-up of browser, usage information of website or application and telephone number

Log information

IP address, log data, usage time, search word input by users, internet protocol address, cookie and web beacon

Other information

Preference, advertisement environment, visited pages regarding service usage of users.

- Optional information

Users may reject the collection and use of optional information and, even in the case of rejection, no limitations will be placed on the user’s use of the service.

Purpose of Collection

Information collected

Provision of customized ad

Contents and result of marketing activities and event participation

Delivery of urgent notice

Information provided by users regarding the management of other agreements, maintenance, implementation and event participation.


Preference, advertisement environment, visited pages regarding service usage of users.

(2) Method of collection

The Company collects the information of users through the following means:

- Webpage, documents, fax, telephone, email, tools for collection of created information

- Provided by partner companies

(3) Delegation of collected personal information

For carrying out services, the Company delegates external professional companies (subcontractors) to process personal information as follows. The Company delegates such processing work only if necessary for providing the services.

When delegating the task of processing personal information to the subcontractors, the Company supervises the subcontractors and ensures the agreement with subcontractors contain the necessary requirements in order to secure safety of personal information. The requirements include, but are not limited to, strict compliance with directions regarding personal information protection, confidentiality of personal information, prohibition of disclosure to 3rd parties, accountability for accidents, responsibility of returning or destruction of personal information upon termination of assignment agreement or completion of processing.

Name of subcontractors

Name of sub-subcontractors

Description of assigned works (services)


Nerdy Star Inc.

Operation management


Good touch Inc.

Customer Service

Among the delegated personal information processing work, the work delegated to foreign entities is as follows.

- Jurisdiction and Name: Republic of Korea, Nerdy Star Inc.

- Items of Personal Information Transferred and Transfer Method: All personal information processed by the Company; transferred by delegation of collection and processing of personal information

- Purpose of Use: Performance of delegated work regarding personal information

- Retention Period of Personal Information: Until the termination of the delegated work regarding personal information

(4) Details of provision of personal information to 3rd Parties

Except for the following cases, the Company does not disclose or provide personal information of users to 3rd parties:

Recipient of information

Purpose of use of recipient

Items to be provided

Period of retention and use of recipient


(5) Period of retention and use of personal information

In principle, the Company destroys personal information of users without delay when: the purpose of its collection and use has been achieved; the legal or management needs for collection and use of such information are satisfied; or upon user request.

The Company will retain the information if it is required to retain the information by relevant laws and regulations. In such event, such personal information will be stored and managed separately and will not be used for other purposes.

The information to be retained as required by the relevant laws and regulations are as follows:

Relevant laws and regulations

Personal Information

Retention period

The Act on Consumer Protection in Electronic Commerce

Record regarding contract or withdrawal of subscription

5 years

Record on payment and supply of goods

5 years

Record on consumer complaint or dispute processing

3 years

Record on labeling and advertising

6 months

The Act on Use and Protection of Credit Information

Record on collection/process, and use of credit information

3 years

The Protection of Communications Secrets Act

Log record of users such as internet/data detecting the place of user connection

3 months

Other data for checking communication facts

12 months

(6) Procedure and method of destruction of personal information

The Company destroys: hard copies of personal information by shredding with a shredder or by incineration; and deletes personal information stored in electronic form by using technical methods that ensure that the personal information cannot be restored.

(7) Technical, managerial and physical measures for protection of personal information

In order to prevent the loss, theft, leakage, alteration or damage of personal information of users, the Company takes technical, managerial and physical measures for securing safety as follows:



Technical measures

- Utilize security servers for transmitting encryption of personal information

- Take encryption measures for confidential information

- Install and operate antivirus software

- Install and operate access control devices and equipment

- Establish and execute internal management plan

Managerial measures

- Appoint staff responsible for protecting personal information

- Provide education and training for staff treating personal information

- Establish and execute internal management plan

- Establish rules for writing passwords that are difficult to speculate

- Ensure safe storage of record of access to personal information processing system

- Classify the level of authority to access to personal information processing system

Physical measures

- Establish and operate the procedure for access control for the facilities for storing personal information

- Store documents and external storage device that are containing personal information in safe places that have locking device

Article 2Use of collected information

The Company uses the collected information of users for the following purposes:

- User management and identification

- To detect and deter unauthorized or fraudulent use of or abuse of the Service

- Performance of contract, service fee payment and service fee settlement regarding provision of services demanded by the users

- Improvement of existing services and development of new services

- Making notice of function of company sites or applications or matters on policy amendment

- Use of information with prior consent of the users (for example, utilization of marketing advertisement)

- To make statistics on member’s service usage, to provide services and place advertisements based on statistical characteristics

- To provide information on promotional events as well as opportunity to participate

- To comply with applicable laws or legal obligation

- When necessary for uninterrupted provision of Service

The Company agrees that it will obtain a consent from the users, if the Company desires to use the information other than expressly stated in this Policy.

Article 3Disclosure of collected information

Except for the following cases, the Company will not disclose personal information with a 3rd party:

1) When the Company discloses the information with its affiliates, partners and service providers;

- when the Company's affiliates, partners and service providers carry out services such as bill payment, execution of orders, products delivery and dispute resolution (including disputes on payment and delivery) for and on behalf of the Company

2) When the users consent to disclose in advance;

- when the user selects to be provided by the information of products and services of certain companies by sharing his or her personal information with those companies

- when the user selects to allow his or her personal information to be shared with the sites or platform of other companies such as social networking sites

- other cases where the user gives prior consent for sharing his or her personal information

3) When disclosure is required by the laws:

- if required to be disclosed by the laws and regulations; or

- if required to be disclosed by the investigative agencies for detecting crimes in accordance with the procedure and method as prescribed in the laws and regulations

Article 4User’s rights

The users or their legal representatives, as main agents of the information, may exercise the following rights regarding the collection, use and sharing of personal information by the Company:

- exercise right to access personal information;

- make corrections or deletions;

- request temporary suspension of personal information handling; or

- request the withdrawal of their prior consent.

In order to exercise the above rights, the user may use the menu of 'edit member information’ or contact the Company by sending a document or email to the Company (or Chief Privacy Officer), and the Company will take measures without delay: However, the Company may reject such request to the extent there is just cause pursuant to relevant laws or other similar causes.

Article 5Chief Privacy Officer & Responsible Personnel

The Company has designated the following person as the Chief Privacy Officer to remain responsible for responding to user inquiries regarding personal information and resolving any related complaints.

Chief Privacy Officer

Name: Sung Wook Huh

Position: CPO

Phone: 82-10-2721-6988


Article 6Modification of Privacy Policy

The Company retains the right to amend or modify this Policy. In such cases, the Company makes public notice of such amendments or modifications through the bulletin board of its website (or through individual notice such as through writing, fax, or email) and obtains consent from the users if required by relevant laws.

Article 7Governing Law and Jurisdiction

This Policy shall be governed and construed in accordance with the laws of the Republic of Korea, and in the event of any dispute regarding this Policy shall be resolved before the courts of Panama having jurisdiction over the area in which the Company is located.

Notification Date : Nov 3rd, 2022

Effective Date : Nov 17th, 2022

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