PRIVACY POLICY

Fluenty Inc. ("Fluenty," "we," "our" or "us") respects the privacy rights of its users and protects the personal information collected, stored and used in connection with our services (the "Services"). To further this commitment, we have adopted this Privacy Policy ("Privacy Policy") to guide how we collect, store, and use the information you provide us. Fluenty includes its Affiliates, which shall mean subsidiaries, parent companies, joint ventures and other corporate entities under common ownership.

We may modify this Privacy Policy from time to time, without any liability to you. We will notify you of any revisions to this Privacy Policy in accordance with our Terms of Use. You will be deemed to have agreed to any such modifications by your further use of our Services after any such modification is posted. It is important that you review this Privacy Policy regularly to ensure you are updated as to any changes. If you do not agree with the modifications, please discontinue use of our Services immediately.

BY INSTALLING, USING, REGISTERING TO OR OTHERWISE ACCESSING OUR SERVICES, YOU ARE ACCEPTING THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT INSTALL, USE, REGISTER TO OR OTHERWISE ACCESS OUR SERVICES.

1. Scope of Privacy Policy

This Privacy Policy describes Fluenty's collection and use of personal information submitted and collected through our Services. Personal information includes any individually identifiable information about you, such as your name, address, telephone number, or e-mail address, and information concerning you collected and/or maintained in personally identifiable form.

Please be aware that advertisers or websites with links to and from our Services may collect personal information about you. This Privacy Policy does not apply to, and cannot control the activities of, those other advertisers or websites.

2. Information We Collect

We may collect and process the following data about you.

A. Personal Information

When you access or engage in certain activities on our Services (such as registering a user account, downloading and installing application(s), making purchases, sending and/or posting user content, or sending us feedback), we may collect personal information about you, but only if you voluntarily provide it to us or permit us to access it.

For example, if you make a purchase from us, it is necessary that you provide to us billing and financial information necessary to process your charges, which may include your postal and e-mail addresses.

B. Usage Information

We collect details of your use of our Services and the resources that you access. Such usage information include information about how and when you access or use our Services.

C. Technical Information

We collect general technical data pertaining to you (such as information about the device you use to access our Services, IP address, operating system, browser type, program or system error messages and other system information).

D. Your Communication with Fluenty

If you contact us or respond to messages and communications that we send to you, we may keep a record of that correspondence.

E. Non-Personal Information

Fluenty may use tools or third party analytical software to automatically collect and use certain non-personal information that does not directly enable Fluenty to identify you.

F. Third Party Social Networks or Platforms

You may allow our Services to interact with a third party social networking service or platform ("SNS"), which will provide data about you to us. We may also allow you to "register" with us by using an SNS authentication option to create an account or profile with us. These applications or websites are created and maintained by third parties that are not a part of, or controlled by us. You should ensure that you read their privacy policies to understand how they treat your data and what data they might share with us.

We also collect and store certain information that you provide directly or through the SNS or other third party website that offers our Services.

When you access our Services through an SNS, you allow us to access certain information from your profile for that website. The information you allow us to access varies by the type of services you access on the SNS and the privacy settings you establish at the SNS. For example, we may access and store some or all of the following information, as allowed by you, the SNS and your preferences:

By accessing our Services through an SNS, you are authorizing us to collect, store, and use in accordance with this Privacy Policy any and all information that you agreed the SNS could provide to us.

G. Cookies

Our Services may use cookies and other technologies such as pixel tags, locally shared objects and web beacons to collect technical information and usage data, which may be linked and identified with your account. A "cookie" is a small bit of record-keeping information that sites often store on a user's computer. You can disable cookies or set your browser to alert you when cookies are being sent to your computer, although this may affect your ability to login and use our Services.

H. Mobile Devices

If you access our Services on your mobile telephone or other mobile device, including tablets, we collect mobile device identifiers, including MAC Address and IP Address. Certain aspects of our Services will create and assign to your device an identifier that is similar to an account number. We may also collect the name you have associated with your device, device type, telephone number, country, and any other information you choose to provide, such as user name, contact lists, geo-location or e-mail address.

3. Use and Sharing of Information Collected

A. Use of Information Collected

We may use your personal information to send you messages about us or our Services, or promotional material from some of our partners, or to contact you when necessary, unless you have not consented to allow us to use your data.

We also may use your personal information and non-personal information, both individually or combined together, for editorial and feedback purposes, for marketing and promotional purposes, for statistical analysis of users' behavior, for product development, for content improvement, for customer support and technical support, to operate, improve, manage and provide our Services, and to customize content and layout of our Services.

Names, postal and e-mail addresses and phone numbers collected may be added to our databases and used for future calls and mailings regarding site updates, new products and services, and upcoming events.

We may enhance or merge the personal information we collect with data from third parties (such as an SNS) in order to update your contact information, perform market analysis, or improve our products, services, or systems.

B. Sharing of Information Collected

Fluenty does not sell or rent your personal information to third-parties for marketing purposes without your consent. However, you hereby agree that Fluenty may, without seeking further your consent, share your personal information with affiliate companies of Fluenty to provide you our Services or information about other services and promotional materials. In addition, Fluenty may share personal information with business partners that assist Fluenty in providing you our Services. Fluenty is committed to giving you a choice when your personal information may be used or disclosed for marketing purposes.

We will encourage our service partners to adopt and post privacy policies. However, the use of your personal information by our service partners is governed by the privacy policies of those service partners, and is not subject to our control.

You also understand that where you allow your account with us to interact with any third party social network or platform, we may share data about you with your contacts (and vice versa) in order that you may enjoy using our Services socially. This data may include your name, your social media profile, picture and content you upload to our Services.

C. Business Transfer

In a business transaction, such as a merger, acquisition, dissolution (including bankruptcy), change of control, or a sale of all or a portion of our assets, customer information, including personal information, generally is one of the transferred business assets. In the event that Fluenty undergoes such transactions, including preparation of any of such transactions, we may share, disclose or transfer all of your information, including personal information, to the successor. Any third party to which we transfer or sell our assets will have the right to continue to use the personal and other information that you provide to us in the manner set out in this Privacy Policy.

D. Compliance with Legal Obligations

Occasionally we may be required by law enforcement or judicial authorities to provide personal information to the appropriate governmental authorities. We will disclose personal information upon receipt of a court order, subpoena, or to cooperate with a law enforcement investigation.

4. Safeguards

Fluenty maintains appropriate safeguards that ensure the security, integrity, and privacy of the personal information we collect and store about our account holders. Personal information collected by Fluenty is stored in secure operating environments that are not available to the public and that are only accessible by authorized employees. We also have security measures in place to protect the loss, misuse, and alteration of the information under our control (i.e., maintain data quality). Before we allow web users to access their personal information, for example, we verify their identity by requesting that they submit information such as their username and password. We also take reasonable steps to ensure that third parties to whom we transfer personal information provide sufficient protection of such data.

Your personal information may be transferred to, and stored at, a destination outside the country of your residence. It may also be processed by personnel of our Affiliates and third party service providers who may operate outside the country of your residence. In such case, we will take reasonable steps to require such third party in possession of your personal information to take commercially reasonable security measures to protect the information.

However, unfortunately, no data transmission over the internet or any wireless network can be guaranteed to be secure. As a result, while we strive to protect your personal information, you acknowledge that: (a) the security, integrity and privacy of any and all information and data exchanged between you and us through our Services cannot be guaranteed; and (b) any such information and data may be viewed or tampered with in transit by a third party.

5. Links to Third Party Sites or Services

You should be aware that our Services may from time to time contain links to third-party sites, products or services. Fluenty is not responsible for the privacy practices or the content of such sites or services. If you are concerned about the privacy policy of a certain third party, we recommend that you read the privacy policy of the site or service to which you link before you submit any personal information.

6. Access to Personal Information

Fluenty makes good faith efforts to enable you to review, update or correct your personal information in Fluenty's possession. In order to do so, please contact our Privacy Policy Administrator at support@fluenty.com. Fluenty will need sufficient information from you to establish your identity and to verify your access request, and also to assist us in handling your request. Please note that even if personal information is changed or deleted according to your request, Fluenty may still retain some of your personal information to resolve disputes, enforce Fluenty user agreement(s), and comply with technical and legal requirements and constraints related to the security, integrity and operation of our Services.

7. Deactivated or Terminated Accounts

Please be aware that even after your account is terminated or deleted, some or all of your information may still remain visible to others. A request to delete and/or termination of your account will not result in the removal of information collected and already put in aggregate form or information that cannot, in our sole discretion, be removed without undue burden to us. We are not able and/or obligated to remove any of your information from a third party provider or platform. Moreover, please be aware that even after you delete your account or your account is terminated, your information may not be deleted in its entirety from our servers and servers of the third party with whom such information have been shared.

8. Opting Out

If at any time you wish to opt out of having your personal information shared with third parties and/or receiving information from Fluenty (via e-mail or postal mail) about new products, services, or promotions, you can do so by emailing us at support@fluenty.com.

9. California Residents: Your California Privacy Rights

Under California law, our customers that are California residents may request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not share our customer's personal information with unaffiliated third parties for direct marketing purposes without their approval.

If at any time you wish to opt out of having your personal information shared with third parties and/or receiving information from us (via e-mail or postal mail) about new products, services, or promotions, you can do so.

10. International Privacy Practices

Fluenty Services are operated and managed on servers located and operated within the Republic of Korea ("Korea") and the United States. By using and accessing our Services, residents and citizens of countries and jurisdictions outside of Korea and the United States agree and consent to the transfer to and processing of personal information on servers located in Korea and the United States, and that the protection of such information may be different than required under the laws of your residence or location.

11. Inquiries

If you have any questions or wish to file a complaint, please feel free to e-mail us at support@fluenty.com.