Somerful – Privacy Policy

Last updated : August, 2025

General Policy – All Users

1. Privacy Policy

Welcome to Somerful. This Privacy Policy applies to Somerful services (the “Platform”), which include Somerful apps, websites, software and related services accessed via any platform or device that link to this Privacy Policy. The Platform is provided and controlled by SOMERFUL PTE. LTD., with its registered address at 1 Raffles Place, #20-02, One Raffles Place, Singapore(048616) (“SOMERFUL”, “we” or “us”).

We are committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, share, and otherwise process the personal information of users, and other individuals in connection with our Platform. If you do not agree with this policy, you should not use the Platform.

2. What information we collect

We may collect the following information about you:

Information You Provide

• Your profile information. You give us information when you register on the Platform, including your username, gender, date of birth (where applicable), email address and/or telephone number, information you disclose in your user profile, and your photograph, audio or profile video.

• User content. We process the content you generate on the Platform, including photographs, audios and videos you upload or create, comments, hashtags, feedback, and reviews you make, and the associated metadata, such as when, where, and by whom the content was created (“User Content”). Even if you are not a user, information about you may appear in User Content created or published by users on the Platform. If you apply an effect to your User Content, we may collect a version of your User Content that does not include the effect.

• Messages. We collect information you provide when you compose, send, or receive messages through the Platform’s messaging functionalities. That information includes the content of the message and information about the message, such as when it was sent, received, or read, and message participants. Please be aware that messages you choose to send to other users of the Platform will be accessible by those users and that we are not responsible for the manner in which those users use or share the messages.

• We may access content, including text, images, audios, and videos, found in your device’s clipboard, with your permission. For example, if you choose to initiate content sharing with a third-party platform, or choose to paste content from the clipboard into the Platform, we access this information stored in your clipboard in order to fulfill your request.

• Purchase information. When you make a purchase or payment on or through the Platform, including when you buy Somerful Coins or purchase goods through our shopping features, we collect information about the purchase or payment transaction, such as payment card information, billing, delivery, and contact information, and items you purchased.

• Proof of your identity or age. We sometimes ask you to provide proof of identity or age in order to use certain features, verified accounts, or when you apply for a subscription, ensure that you are old enough to use the Platform, or in other instances where verification may be required.

• Information in correspondence you send to us, including when you contact us for support or feedback.

• Information through surveys, research, promotion, contests, marketing campaigns, challenges, competitions or events conducted or sponsored by us, in which you participate.

Automatically Collected Information

• Usage Information. We collect information regarding your use of the Platform, e.g., how you engage with the Platform, including how you interact with content we show to you, the advertisements you view, contents you watch and problems encountered, browsing and search history, the content you like or dislike, the users you liked and how you engage with users like you.

• Technical Information we collect about you. We collect certain information about the device you use to access the Platform, such as your IP address, user agent, mobile carrier, time zone settings, identifiers for advertising purposes, model of your device, the device system, device locale information(language and region), network type, device IDs, your screen resolution and operating system, app and file names and types, keystroke patterns or rhythms, battery state, audio settings and connected audio devices. Where you log-in from multiple devices, we will be able to use your profile information to identify your activity across devices. We may also associate you with information collected from devices other than those you use to log-in to the Platform.

• Location Information. We collect information about your approximate location, including location information based on your SIM card and/or IP address. With your permission, we may also collect precise location data (such as GPS). In addition, we collect location information (such as tourist attractions, shops, or other points of interest) if you choose to add location information to your User Content.

• Image and Audio Information. We may collect information about the videos, images and audio that are a part of your User Content, such as identifying the objects and scenery that appear, the existence and location within an image of face and body features and attributes, the nature of the audio, and the text of the words spoken in your User Content. We may collect this information to enable special video effects, for content moderation, for demographic classification, for content and ad recommendations, and for other non-personally-identifying operations.

• Cookies. We and our service providers and business partners use cookies and other similar technologies (e.g., web beacons, flash cookies, etc.) (“Cookies”) to automatically collect information, measure and analyze how you use the Platform, including which pages you view most often and how you interact with content, enhance your experience using the Platform, improve the Platform, provide you with advertising, and measure the effectiveness of advertisements and other content. We and our partners also use Cookies to promote the Platform on other platforms and websites. Cookies enable the Platform to provide certain features and functionality. Web beacons are very small images or small pieces of data embedded in images, also known as “pixel tags” or “clear GIFs,” that can recognize Cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from your computer or device.

Information From Other Sources

We may receive the information described in this Privacy Policy from other sources, such as:

• If you choose to register or use the Platform using a third-party social network account details (e.g., Facebook, Apple, Google, Zalo, Kakao) or login service, you will provide us or allow to provide us with your username, public profile, and other possible information related to such account. We will likewise share certain information with your social network such as your app ID, access token and the referring URL. If you link your Somerful account to another service, we may receive information about your use of that service.

• Advertisers, measurement and other partners share information with us about you and the actions you have taken outside of the Platform, such as your activities on other websites and apps or in stores, including the products or services you purchased, online or in person. These partners also share information with us, such as mobile identifiers for advertising, hashed email addresses and phone numbers, and cookie identifiers, which we use to help match you and your actions outside of the Platform with your Somerful account. Some of our advertisers and other partners enable us to collect similar information directly from their websites or apps by integrating our Somerful Advertiser Tools (such as Somerful Pixel).

• We may obtain information about you from certain affiliated entities within our corporate group, including about your activities on their platforms.

• We may receive information about you from others, including where you are included or mentioned in User Content, direct messages, in a complaint, appeal, request or feedback submitted to us, or if your contact information is provided to us. We may collect information about you from other publicly available sources.

3. How we use your information

As explained below, we use your information to improve, support and administer the Platform, to allow you to use its functionalities, and to fulfill and enforce our Terms of Service. We may also use your information to, among other things, promote the Platform, and customize your ad experience. We generally use the information we collect in the following ways:

• To fulfill requests for products, services, Platform functionality, support and information for internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes and to solicit your feedback.

• To send promotional materials, including by instant messaging or email, from us or on behalf of our affiliates and trusted third parties.

• To improve and develop our Platform and conduct product development.

• To measure and understand the effectiveness of the advertisements and other content we serve to you and others, and to deliver advertising, including targeted advertising, to you on the Platform.

• To support the social functions of the Platform, including to permit you and others to connect with each other (for example, through our People function) and to share whether you are active on the Platform (and other information which you choose to share) with your friends, to provide our messaging service if you choose to use this function, to suggest accounts to you and others, and for you and others to share, download, and otherwise interact with User Content posted through the Platform.

• To enable you to participate in the virtual items program.

• To allow you to participate in interactive features of the Platform, such as enabling your content to be used in other users’ content.

• To use User Content as part of our advertising and marketing campaigns to promote the Platform, to invite you to participate in an event, and to promote popular topics, hashtags and campaigns on the Platform.

• To understand how you use the Platform, including across your devices.

• To help us detect and combat abuse, harmful activity, fraud, spam, and illegal activity on the Platform.

• To ensure content is presented in the most effective manner for you and your device.

• To promote the safety, security of the Platform, including by scanning, analyzing, and reviewing User Content, messages and associated metadata for violations of our Terms of Service, Community Guidelines, or other conditions and policies.

• To facilitate research conducted by independent researchers that meets certain criteria.

• To verify your identity or age.

• To communicate with you, including to notify you about changes in our services.

• To announce you as a winner of our contests or promotions if permitted by the promotion rule, and to send you any applicable prizes.

• To enforce our Terms of Service, Community Guidelines, and other conditions and policies.

Consistent with your permissions, to provide you with location-based services, such as advertising and other personalized content.

• To train and improve our technology, such as our machine learning models and AIs.

• To facilitate and fulfill sales, promotion, and purchases of goods and services and to provide user support.

4. How we share your information

We share your information with the following parties:

Business Partners

If you choose to register to use the Platform using your social network account details (e.g., Facebook, Apple, Google, Zalo, Kakao), you will provide us or allow your social network to provide us with your phone number, email address, username and public profile. We will likewise share certain information with the relevant social network such as your app ID, access token and the referring URL. If you choose to allow a third-party service to access your account, we will share certain information about you with the third party. Depending on the permissions you grant, the third party may be able to obtain your account information and other information you choose to provide.

Where you opt to share content on social media platforms, the video, username and accompanying text will be shared on that platform or, in the case of sharing via instant messaging platforms such as Whatsapp, a link to the content will be shared.

Service Providers

We provide information and content to service providers who support our business, such as cloud service providers and providers of content moderation services to ensure that the Platform is a safe and enjoyable place and service providers that assist us in marketing the Platform.

• Payment processors and transaction fulfillment providers: If you choose to in-app purchase or conduct other payment-related transactions, we will share data with the relevant payment provider to facilitate this transaction.

• Analytics providers: We may use analytics providers to help us in the optimization and improvement of the Platform. Our third-party analytics providers also help us serve targeted advertisements.

Advertisers, Advertising Networks and Measurement Partners

We share information with advertisers and third-party measurement companies to show how many and which users of the Platform have viewed or clicked on an advertisement.

We share information with advertising networks to display personalized advertisements to you on Somerful and elsewhere online. We are not responsible for the privacy practices of these third parties, and the information practices of these third parties are not covered by this Privacy Policy.

Independent Researchers

We share your information with independent researchers to facilitate research that meets certain criteria.

Our Corporate Group

We may also share your information with other members, subsidiaries, or affiliates of our corporate group, including to provide the Platform, to improve and optimize the Platform, to prevent illegal use and to support users.

For Legal Reasons

We will share your information with law enforcement agencies, public authorities or other organizations if legally required to do so, or if such use is reasonably necessary to:

• comply with legal obligations, process or request;

• enforce our Terms of Service and other agreements, policies, and standards, including investigation of any potential violation thereof;

• detect, prevent or otherwise address security, fraud or technical issues; or

• protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction).

Public Profiles

Please note that if your profile is public, your content will be visible to anyone on the Platform and may also be accessed or shared by your friends and followers as well as third parties such as search engines, content aggregators and news sites. You can change who can see a content each time you upload a content. Alternatively, you can change your profile to private by changing your settings in “Disclosure” of Account settings.

Sale, Merger or Other Business Transactions

We may also disclose your information to third parties:

• in the event that we sell or buy any business or assets (whether a result of liquidation, bankruptcy or otherwise), in which case we will disclose your data to the prospective seller or buyer of such business or assets; or

• if we sell, buy, merge, are acquired by, or partner with other companies or businesses, or sell some or all of our assets. In such transactions, user information may be among the transferred assets.

Merchants, Payment and Transaction Fulfillment Providers, and Other Service Providers

When you make a purchase through our shopping features, we share the information related to the transaction with the merchant, payment and transaction fulfillment providers, and other service providers. For example, we will share the order items, contact details and delivery information so your order can be processed. These entities may use the information shared in accordance with their privacy policies.

5. Where we store your information

Your information may be stored on servers located outside the country where you live, such as in Singapore, Malaysia or the United States. We maintain major servers around the world to bring you our services globally and continuously.

6. Your rights and choices

You have rights and choices when it comes to your information. You may be afforded certain rights under applicable laws, which may include the right to access, delete, update, or rectify your data, to be informed of the processing of your data, to file complaints with authorities, and potentially other rights. You may submit a request to exercise your rights under applicable laws to [email protected]. You may appeal any decision we have made about your request by following the instructions in the communication you receive from us notifying you of our decision.

You can access and edit most of your profile information by signing into Somerful. You can delete the User Content you uploaded. We also provide a number of tools in Settings that allow you to control, among others, who can view your content, send you messages, or post comments to your content. Should you choose to do so, you may delete your entire account in Settings.

You may be able to refuse or disable Cookies by adjusting your device browser settings. Because each browser is different, please consult the instructions provided by your browser. Please note that you may need to take additional steps to refuse or disable certain types of Cookies. For example, due to differences in how browsers and mobile apps function, you may need to take different steps to opt out of Cookies used for targeted advertising in a browser and to opt out of targeted advertising for a mobile application, which you may control through your device settings or mobile app permissions. In addition, your opt-out selection is specific to the particular browser or device that you are using when you opt out, so you may need to opt-out separately for each of browser or device. If you choose to refuse, disable, or delete Cookies, some of the functionality of the Platform may no longer be available to you.

7. The security of your information

We take steps to ensure that your information is treated securely and in accordance with this policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will use reasonable measures to protect your personal data, for example, by encryption, we cannot guarantee the security of your information transmitted via the Platform; any transmission is at your own risk.

We have appropriate technical and organizational measures to ensure a level of security appropriate to the risk of varying likelihood and severity for the rights and freedoms of you and other users. We maintain these technical and organizational measures and will amend them from time to time to improve the overall security of our systems.

We will, from time to time, include links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to these websites.

8. How long we keep your information

We retain information for as long as necessary to provide the Platform and for the other purposes set out in this Privacy Policy. We also retain information when necessary to comply with contractual and legal obligations, when we have a legitimate business interest to do so (such as improving and developing the Platform, and enhancing its safety, security and stability), and for the exercise or defense of legal claims.

The retention periods are different depending on different criteria, such as the type of information and the purposes for which we use the information. For example, when we process your information such as your profile information to provide you with the Platform, we keep this information for as long as you have an account. If you violate our Terms of Service, Community Guidelines, or other conditions or policies, we may remove your profile and User Content from public view immediately, but may keep other information about you to process the violation.

9. Information relating to children and teens

Somerful is not directed at children under the age of 18. In certain cases this age may be higher due to local regulatory requirements, please see your local supplemental terms for more information. If you believe that there is a user who is below this minimum age, please contact us to [email protected].

If you are a parent or guardian, our Community Guidelines contains information and resources to help you understand the Platform and the tools and controls you can use.

10. Privacy Policy update

We may update this Privacy Policy from time to time. When we update the Privacy Policy, we will notify you by updating the “Last Updated” date at the top of this policy and posting the new Privacy Policy or providing any other notice required by applicable law. Your continued access to or use of the Platform after the date of the updated policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Platform.

11. Contact

If you have questions, comments, complaints or requests regarding this Privacy Policy, please contact us to: [email protected].

We will endeavor to deal with your request as soon as possible. This is without prejudice to your right to make a complaint with a relevant data protection authority, where applicable.

12. Supplemental Terms – Jurisdiction-Specific

In the event of a conflict between the provisions of the Supplemental Terms – Jurisdiction-Specific that are relevant to your jurisdiction from which you access or use the services, and the rest of policy, the relevant jurisdictions’ Supplemental Terms – Jurisdiction-Specific will supersede and control.

Australia

If you are using the Platform in Australia, the following additional terms shall apply.

Certain entities in our corporate group, located outside of Australia, are given limited remote access to your information so that they can provide certain functions, as described in the section on "How we share your information".

Brazil

If you are using the Platform in Brazil, the following additional terms apply. If any conflict arises between the main Privacy Policy and the additional terms, the following terms shall prevail:

Exercise of data protection rights. Brazilian law provides certain rights to individuals with regard to their personal data. Thus, we seek to ensure transparency and access controls in order to allow users to benefit from the mentioned rights.

We will respond and/or fulfill your requests for the exercise of your rights below, according to the applicable law and when applicable, to the Brazilian General Data Protection Law - LGPD:

I. confirmation of whether your data are being processed;

II. access to your data;

III. correction of incomplete, inaccurate or outdated data;

IV. anonymization, blocking or erasure of data;

V. portability of personal data to a third party;

VI. object to the processing of personal data;

VII. information of public and private entities with which we shared data;

VIII. information about the possibility to refuse providing personal data and the respective consequences, when applicable;

IX. withdrawal of your consent.

X. request a review of decisions made solely based on automated processing of personal data affecting your interests, including decisions made to define your personal, professional, consumer or credit profile, or aspects of your personality.

We encourage you to contact us if you are not satisfied with how we have responded to any of your rights requests. You also have the right to lodge a complaint with the Brazilian Data Protection Authority (ANPD).

Verifying your identity: For your safety and to allow us to make sure that we do not disclose any of your personal data to unauthorized third parties, in order to verify your identity and guarantee the adequate exercise of your rights, we may request specific information and/or documents from you before we can properly respond to a request received concerning your data. All data and documents received from you in the process of responding to your requests will be used for the strict purposes of analyzing your request, authenticating your identity, and finally responding to your request.

Limitations to your rights: In certain situations, we may have legitimate reasons not to comply with some of your requests. For instance, we may choose not to disclose certain information to you when a disclosure could adversely impact our business whenever there is a risk of violation to our trade secrets or intellectual property rights. In addition, we may refrain from complying with a request for erasure when the maintenance of your data is required for complying with legal or regulatory obligations or when such maintenance is required to protect our rights and interests in case a dispute arises. Whenever this is the case and we are unable to comply with a request you make, we will let you know the reasons why we cannot fulfill your request.

Contact: In case of doubt about your privacy, your rights or how to exercise them, please contact us through the form "Contact". If you have any questions about the processing of your personal data, we would like to clarify them.

DPO: If you wish to reach the SOMERFUL’s Data Protection Officer, contact us to: [email protected].

Access Logs. We keep your application access logs, under confidentiality, in a controlled and safe environment for at least 6 months, in order to comply with legal obligations.

International Transfers. International data transfers are necessary for us to provide our services. If you are located in Brazil, we will always rely on one of the international data transfer mechanisms under applicable data protection laws and regulations.

Canada

If you are using the Platform in Canada, the following additional terms apply.

Your Rights. Subject to limited exceptions under applicable law, you have the right to access, update, rectify and correct inaccuracies in your personal information in our custody and control and to withdraw your consent to our collection, use and disclosure of your personal information. To exercise these rights, you may contact us using the contact information set out below. We may require certain personal information for the purpose of verifying the identity of the individual making the request.

Your Choices. You can unsubscribe from our marketing emails at any time by clicking the “unsubscribe” link included at the bottom of each email we send.

Transfer Outside Your Jurisdiction. We and our service providers (including members, subsidiaries, or affiliates of our corporate group) may access, store and otherwise process personal information outside of Canada (and, for residents of Quebec, outside of Quebec), including in the United States, Malaysia, Singapore, and other foreign jurisdictions where we or our service providers are located. For information about the manner in which we or our service providers (including service providers outside Canada) process personal data, please contact us using the contact information set out below.

Egypt

If you are using our services in Egypt, the following additional terms apply.

• You declare that you are over the age of 18. If you are under the age of 18, you cannot use our service. You have read and acknowledged SOMERFUL's Privacy Policy and Terms of Use and agree to the use by yourself of the Platform and registration for an account.

Indonesia

If you are using our services in Indonesia, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this policy, the following terms shall apply.

Age, Parental and Guardian Consent. By accessing and/or using this Platform, you represent that you are at least 21 years of age or married or not under guardianship. If you are below 21 years old and you are not married, or under guardianship: you must cease accessing the Platform.

Your Choices. You may withdraw your consent to SOMERFUL's disclosure of personal data to third parties. Upon your request, we will cease to display, publish, transmit, disseminate, and/or open the access to your personal data to third parties. Please note that by withdrawing your consent to the disclosure and/or collection of your personal data, we may not be able to fulfill your requests and you may not be able to use some of Somerful features and functionality.

You may request SOMERFUL to (i) disclose the history of personal data that we have collected; and/or (ii) erase and dispose of your personal data that we have collected on our server. Please note that by requesting us to erase and dispose of your personal data, you may not be able to use some of Somerful’s features and functionality.

To exercise any of your rights, contact us to: [email protected].

Notification. In the event of any breach of personal data, we will notify you and provide you with information regarding such breach of personal data.

Data retention. We retain your information for as long as it is necessary to provide you with the service. Where we do not need your information in order to provide the service to you, we retain it only for so long as we have a legitimate business purpose in keeping such data. However, there are occasions where we are likely to keep this data for five (5) years (or longer if required) in accordance with our legal obligations or where it is necessary for the establishment, exercise or defense of legal claims.

After you have terminated your use of our Platform and the five (5) years retention period has lapsed, we store your information in an aggregated and anonymized format. Non-personally identifiable information may be retained indefinitely for analytics.

Israel

If you are using our services in Israel, the following additional terms apply.

• You declare that you are over the age of 18. If you are under the age of 18, you must cease accessing the Platform

Japan

If you are using our services in Japan, please refer to our Japanese language Privacy Policy for further information on our compliance with the Telecommunications Business Act.

Mexico

If you are using our services in Mexico, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this policy, the following terms shall prevail.

How we use your personal data.

Almost all purposes of processing stated in this section of the main Privacy Policy are necessary purposes. However, the following are secondary purposes:

• Provide you with personalized advertising.

The above purposes are not necessary for us to provide the Platform but allows us to provide you with a better experience. We offer you the possibility to take decisions regarding how we use and disclose your personal data.

We use both human and automated means to process your data.

How we share your personal data.

We may share your personal data to a third party for purposes other than processing on behalf of us. We will obtain your consent for such sharing as required by applicable laws.

By providing us with your personal data and using our Platform you agree to the transfers that require your consent. You can always revoke your consent and exercise your rights, as stated below.

Your Rights.

You have the following rights with respect to your personal data: access, rectification, cancellation, opposition, consent withdrawal, limitation to the use and disclosure of your data. You can exercise your rights by sending your request to [email protected]. To know more about the applicable requirements and procedure to exercise your rights, contact us to the mentioned email address.

Philippines

If you are using our services in the Philippines, the following additional terms shall apply pursuant to the relevant laws, rules and regulations and issuances by the Philippines National Privacy Commission (“NPC”) on data privacy.

Your Rights. To the extent that the relevant laws, rules and regulations on data privacy recognize your rights and freedoms as data subjects, you shall have the right to information, object, access, rectification, erasure or blocking, lodge complaints before the NPC, damages and data portability. Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details.

Russia

What are legal grounds for data processing. When we process your personal data, we rely on the grounds of your consent, performance of a contract, our legitimate interest and obligations to process personal data, or when we are so required by law.

By signing up and using the Platform, you consent to the processing of personal data in accordance with this Privacy Policy.

Where we store your personal data. Your personal data may be transferred from Russia to Singapore and stored in that location, outside of the country where you live.

Public profiles. We rely on your consent to public distribution of personal data, when your account settings are 'Public Profile'. You can change your profile to private by changing your settings in “Disclosure” of Account settings.

South Africa

If you are using our services in South Africa, the following additional terms apply.

You declare that you are over the age of 18. If you are under the age of 18, you must cease accessing the Platform

South Korea

If you are using our services in South Korea, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this policy, the following terms shall prevail.

• How we share your personal data. In addition to the main text of this policy, in the event we use information such as user-generated content and video content on our Platform as part of our advertising and marketing campaigns to promote the Platform, your personal data contained in such information may be disclosed to the recipients of such advertising or marketing content.

• Customized Ads. We may from time to time provide customized ads on our Platform to provide you our Platform for free.

• Data retention. We destroy personal data whose purpose of collection as consented to by you have been achieved, or whose periods of and use to which you consented to or which were provided in this privacy policy have expired; provided, however, we will continue to store your personal data for the following statutorily-prescribed periods, where applicable, including, but not limited to:

• Act on Consumer Protection in Electronic CommerceRecords on your cancellation of an order, your payment on a purchased item, and our supply of a good/service: 5 yearsRecords on the handling of consumer complaints or disputes: 3 yearsRecords on advertisements and labels: 6 months

• Protection of Communications Secrets Act Records on your visits to our website: 3 months

Destruction of Personal Data. We destroy your personal data in a manner that renders it unrestorable by the relevant department.

• Data rights. You have the right to access personal data we hold about you, to rectify any personal data held about you that is inaccurate, to request the deletion of personal data held about you, and the right to request the suspension of the processing of your personal data. You can exercise your rights by contacting us to [email protected].

• Data Security. We work hard to protect SOMERFUL and our users from unauthorized access to or unauthorized alteration, disclosure or destruction of information we hold. To this end, we have in place technical, managerial and physical safeguards, including internal policy for data protection, limiting the access to personal data on a need-to-know basis and controlling access to the facilities where personal data is processed.

• Information Relating to Children. Somerful is not directed at children under the age of 18.

• Entrustment and/or Overseas Transfer of Personal Data. We entrust your data to our affiliates, cloud storage providers, IT service providers, and data centers, some of whom are located abroad (See the Korean language Privacy Policy), subject to your consents or notifications to you, if applicable. The entities receiving and processing your data are committed to using and storing personal data in compliance with domestic and international regulations and to taking all available physical and technical measures to protect personal data. You may opt-out of such transfer so long as the transfer is not necessary to provide you with the Service, by contacting us here.

• Local representative pursuant to the Personal Information Protection Act

• Please send your inquiries concerning privacy issues in South Korea pursuant to the Personal Information Protection Act. Contact detail : [email protected].

Türkiye

If you are using our services in Turkey, the following additional terms apply along with the contents of the foregoing Policy. In the event of any conflict between the following additional terms and the provisions of the main body of this policy, the following terms shall prevail.

If you wish to reach the SOMERFUL’s Data Protection Officer to handle questions and complaints in connection with the processing of your personal data, contact us to: [email protected]

Methods of collection, processing purposes of, and legal bases for, processing your personal data. Please refer to our Privacy Policy and its Addendum, for detailed information about personal data categories we process, our processing purposes and related legal bases for processing.

Your rights. According to Article 11 of the Data Protection Law, you have the following rights with respect to your personal data:

• the right to learn whether we process your personal data,

• the right to request information with regard to such processing, if we process your personal data,

• the right to learn the purposes of the processing and whether they are used for such purpose or not;

• the right to know the third parties within or outside the country, to whom we transfer your personal data,

• the right to request correction of incomplete or inaccurate personal data,

• the right to request deletion or destruction of your personal data under the conditions set forth in Article 7 of the Data Protection Law,

• the right to request that we notify the third parties, to whom we transferred your personal data, about the correction, deletion and/or destruction of your personal data per your request within the scope of the foregoing two items,

• the right to object to the negative results about you that are due to the analysis of your personal data processed solely by automated means,

• the right to claim indemnification for damages incurred due to illegal processing of your personal data.

You may exercise your rights listed above by contacting us to: [email protected].

The requests found in your application will be resolved as soon as possible according to the nature of your request and within thirty days at the latest free of charge. However, if your request incurs additional cost to our company, then you may be charged over the tariff fee determined by the Turkish Personal Data Protection Board.

Cookies. Please refer to our Turkish Privacy Policy for further information on our use of cookies on our website.

United Arab Emirates

If you are using the Platform in the United Arab Emirates (“UAE”), the following additional terms apply. If any conflict arises between the main Privacy Policy and the additional terms, the following terms shall prevail:

How we share your personal data

In addition to the main text of this policy, by using the Platform in the UAE you agree to the terms of this Privacy Policy and consent to our sharing of your personal data in line with the main text of this Privacy Policy.

Governing law and dispute resolution

By using our Platform in the UAE, this Privacy Policy will be governed by and interpreted in accordance with the laws of the UAE. In the event of a dispute arising between the parties in connection with this Privacy Policy:

where the dispute relates to a claim for a sum within the limits specified by the DIFC Small Claims Tribunal from time to time, then the dispute shall be referred by either party to the said Tribunal; and

for all other disputes, the parties shall seek settlement of that dispute by mediation in accordance with the Mediation Rules of the DIFC-LCIA Arbitration Centre, which Rules are deemed to be incorporated by reference to this clause. If the dispute is not settled by mediation within 30 days of the commencement of the mediation, or such further period as the parties shall agree in writing, the dispute shall be referred to and finally resolved by arbitration under the Arbitration Rules of the DIFC-LCIA Arbitration Centre, which Rules are deemed to be incorporated by reference to this clause. The language to be used in the mediation and in the arbitration, shall be English. In any arbitration commenced pursuant to this clause the number of arbitrators shall be one and the arbitration shall be conducted in Dubai.

Vietnam

If you are using our services in Vietnam, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this policy, the following terms shall prevail.

Age, Parental and Guardian Consent. By accessing and/or using this Platform, you represent that you are at least 17 years of age or not under guardianship. If you are below 17 years old or under guardianship, you must cease accessing the Platform.