Introduction
Data Town Inc. ("FanWork," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use the FanWork platform, including our website and mobile applications (collectively, the "Service").
Please read this Privacy Policy carefully. By accessing or using the Service, you acknowledge that you have read, understood, and agree to the practices described in this policy.
Table of Contents
- Information We Collect
- How We Use Your Information
- Legal Bases for Processing (EEA/UK)
- How We Share Your Information
- International Data Transfers
- Data Retention
- Your Privacy Rights
- Cookies and Tracking Technologies
- Children's Privacy
- Data Security
- Third-Party Links and Services
- Changes to This Policy
- Regional Privacy Notices
- Contact Us
1. Information We Collect
1.1 Information You Provide Directly
Account Information
| Data Category | Data Elements | When Collected |
|---|---|---|
| Basic Profile | Username, nickname, profile image, country, preferred language | Sign up (Required) |
| Authentication | Email address, social login ID, social platform name | Sign up (Required) |
| Fandom Information | Favorite artists, interests | Fandom tier upgrade (Optional) |
| Producer Information | SNS platform, SNS username, verified email, ZIP code, address, skillsets, skillset URLs | Producer tier upgrade (Optional) |
User Content
- Posts (text, images, videos)
- Comments and reactions
- Mission descriptions and submissions
- Profile biography
- Direct messages to other users
Communications
- Customer support inquiries
- Feedback and surveys
- Email correspondence
1.2 Information Collected Automatically
Device and Technical Information
| Data Type | Examples |
|---|---|
| Device Information | Device type, operating system, unique device identifiers |
| Browser Information | Browser type, version, language settings |
| Network Information | IP address, mobile network information |
| Usage Data | Pages visited, features used, time spent, click patterns |
Location Information
- General location derived from IP address
- Country/region for content localization
- We do not collect precise GPS location without explicit consent
1.3 Information from Third Parties
Social Login Providers
When you authenticate using social login (Google, Apple, Kakao, etc.), we may receive:
- Basic profile information (name, email, profile picture)
- Unique identifier from the platform
- Information you have made public on that platform
We only access information that you authorize and that the platform allows.
Other Sources
- Public databases
- Business partners (with your consent)
- Other users (e.g., when they tag you or send you messages)
2\. How We Use Your Information
2.1 Primary Purposes
| Purpose | Description | Data Used |
|---|---|---|
| Provide the Service | Create and manage your account, deliver core features | Account info, content |
| Personalization | Customize your experience, recommend content | Interests, usage data |
| Communication | Send service updates, respond to inquiries | Email, contact info |
| Safety & Security | Detect fraud, enforce policies, protect users | All data categories |
| Analytics | Understand usage patterns, improve the Service | Usage data, device info |
2.2 Additional Purposes
- Research and Development: Improve existing features and develop new ones
- Marketing: With your consent, send promotional communications
- Legal Compliance: Comply with legal obligations, respond to legal requests
- Business Operations: Conduct business analysis, audits, internal operations
2.3 Respect Points Processing
We process activity data to calculate Respect Points, including:
- Social engagement (likes, comments, reactions given and received)
- Content creation activities
- Mission participation and feedback
- Collaboration outcomes
This data is processed to operate the reputation system as described in our Terms of Service.
3\. Legal Bases for Processing (EEA/UK)
For users in the European Economic Area and United Kingdom, we process your personal data based on the following legal grounds:
| Legal Basis | Examples |
|---|---|
| Contract Performance | Account creation, service delivery, responding to requests |
| Legitimate Interests | Security, fraud prevention, service improvement, analytics |
| Consent | Marketing communications, optional cookies, certain data sharing |
| Legal Obligation | Compliance with laws, responding to legal requests |
You may withdraw consent at any time for processing based on consent, without affecting the lawfulness of prior processing.
4\. How We Share Your Information
4.1 Public Information
The following information is publicly visible on FanWork:
- Username and nickname
- Profile image
- Country (if you choose to display it)
- Posts and comments you create
- Missions you create or participate in
- Respect Points (in your activity area only)
4.2 Sharing with Third Parties
| Recipient | Purpose | Data Shared |
|---|---|---|
| Service Providers | Hosting, analytics, customer support, email delivery | As necessary for services |
| Social Platforms | Login authentication, sharing features | Authentication data |
| Analytics Partners | Usage analysis, performance monitoring | Anonymized/aggregated data |
| Legal Authorities | Legal compliance, law enforcement requests | As required by law |
| Business Transfers | Merger, acquisition, asset sale | All data (with notice) |
4.3 Service Providers
We engage the following categories of service providers:
- Cloud hosting providers (AWS, Google Cloud)
- Content delivery networks
- Analytics services (Google Analytics, Mixpanel)
- Customer support platforms
- Email service providers
- Payment processors (for future paid features)
All service providers are contractually obligated to protect your data and use it only for specified purposes.
4.4 We Do Not Sell Your Personal Information
FanWork does not sell your personal information to third parties. We do not share personal information for third-party advertising purposes without your consent.
5\. International Data Transfers
5.1 Data Location
FanWork is operated from South Korea. Your data may be transferred to and processed in:
- South Korea (primary)
- United States (cloud services)
- Other countries where our service providers operate
5.2 Transfer Safeguards
For transfers from the EEA/UK, we use:
- Standard Contractual Clauses (SCCs) approved by the European Commission
- Additional technical and organizational measures
- Assessment of destination country data protection laws
5.3 Your Consent
By using FanWork, you consent to the transfer of your data to countries outside your residence, subject to the safeguards described above.
6\. Data Retention
6.1 Retention Periods
| Data Category | Retention Period | Reason |
|---|---|---|
| Active Account Data | Duration of account \+ 30 days | Service provision |
| Deleted Account Data | 30 days after deletion request | Recovery period |
| User Content | Indefinitely (attributed to DeletedAccount) | Community integrity |
| Transaction Records | 7 years | Legal/tax requirements |
| Support Communications | 3 years | Service improvement |
| Analytics Data | 26 months (aggregated) | Service improvement |
6.2 Account Deletion
When you delete your account:
- Days 1-14: Account recoverable, data retained
- Days 15-30: Account not recoverable, data being processed for deletion
- Day 30+: Personal data permanently deleted
Note: Content you created (Posts, Missions, Comments) remains attributed to "DeletedAccount\_\[number\]" to maintain community continuity.
6.3 Exceptions
We may retain data longer when required to:
- Comply with legal obligations
- Resolve disputes
- Enforce agreements
- Protect against fraud
7\. Your Privacy Rights
7.1 Universal Rights
All users have the right to:
| Right | Description | How to Exercise |
|---|---|---|
| Access | Obtain a copy of your personal data | Settings \> My Data \> Download |
| Correction | Update inaccurate information | Profile \> Edit |
| Deletion | Request deletion of your account and data | Settings \> Account \> Delete |
| Portability | Receive your data in a structured format | Settings \> My Data \> Export |
7.2 Regional Rights
See Section 13 for additional rights based on your location.
7.3 Exercising Your Rights
Self-Service Options: Most rights can be exercised through your account settings.
Contact Us: For requests requiring assistance:
- Email: townhall@fanwork.kr
- Response time: Within 30 days (may be extended for complex requests)
Verification: We may need to verify your identity before processing certain requests.
7.4 Appeals
If you disagree with our response to your request, you may:
- Request a review by contacting townhall@fanwork.kr
- File a complaint with your local data protection authority
8\. Cookies and Tracking Technologies
8.1 What We Use
| Technology | Purpose | Duration |
|---|---|---|
| Essential Cookies | Authentication, security, basic functionality | Session |
| Functional Cookies | Preferences, language settings | 1 year |
| Analytics Cookies | Usage patterns, performance | 26 months |
| Marketing Cookies | Ad personalization (with consent) | 12 months |
8.2 Cookie Management
In-App Settings: You can manage cookie preferences in Settings \> Privacy \> Cookie Preferences.
Browser Settings: You can also control cookies through your browser settings. Note that disabling essential cookies may affect Service functionality.
8.3 Do Not Track
We currently do not respond to "Do Not Track" browser signals due to the lack of an industry standard.
8.4 Detailed Cookie Policy
For more information, see our Cookie Policy.
9\. Children's Privacy
9.1 Age Restrictions
FanWork is not intended for children under the minimum age specified for your country:
| Country/Region | Minimum Age |
|---|---|
| United States | 13 years |
| European Union | 16 years (or member state minimum, not less than 13\) |
| United Kingdom | 13 years |
| Brazil | 18 years (or with parental consent) |
| India | 18 years |
| Indonesia | 17 years |
| Other | 13 years |
9.2 No Knowing Collection
We do not knowingly collect personal information from children under the applicable minimum age. If we learn we have collected such information, we will delete it promptly.
9.3 Parental Notice
If you believe a child has provided us with personal information, please contact us at townhall@fanwork.kr. We will take steps to delete the information and terminate the child's account.
9.4 COPPA Compliance (United States)
For users in the United States, we comply with the Children's Online Privacy Protection Act (COPPA). We do not knowingly collect personal information from children under 13\.
10\. Data Security
10.1 Security Measures
We implement appropriate technical and organizational measures to protect your data:
Technical Measures:
- Encryption in transit (TLS 1.3)
- Encryption at rest (AES-256)
- Secure authentication protocols
- Regular security assessments
- Access controls and logging
Organizational Measures:
- Employee training on data protection
- Access limited to need-to-know basis
- Incident response procedures
- Regular policy reviews
10.2 Breach Notification
In the event of a data breach that poses a risk to your rights:
- We will notify affected users without undue delay
- We will notify relevant authorities as required by law (within 72 hours for GDPR)
- We will provide information about the breach and mitigation steps
10.3 Your Responsibilities
You are responsible for:
- Keeping your login credentials secure
- Using a strong, unique password
- Logging out from shared devices
- Reporting suspicious activity
11\. Third-Party Links and Services
11.1 External Links
FanWork may contain links to third-party websites and services. We are not responsible for the privacy practices of these third parties. We encourage you to read their privacy policies before providing any information.
11.2 Social Features
When you use social features (sharing, social login), you may be subject to the privacy policies of those social platforms.
11.3 Embedded Content
Our Service may include embedded content (videos, images) from third parties. This content may collect data about you, use cookies, and monitor your interaction.
12\. Changes to This Policy
12.1 Updates
We may update this Privacy Policy from time to time. Material changes will be communicated through:
- In-app notifications
- Email to your registered address
- Prominent notice on the Service
12.2 Effective Date
Changes will be effective:
- 30 days after notice for existing users (for material changes)
- Immediately for new users
12.3 Your Choices
If you disagree with changes, you may:
- Delete your account before changes take effect
- Contact us with concerns at townhall@fanwork.kr
13\. Regional Privacy Notices
13.1 European Economic Area (EEA) and United Kingdom
Additional Rights under GDPR/UK GDPR:
| Right | Description |
|---|---|
| Restriction | Request limitation of processing |
| Objection | Object to processing based on legitimate interests |
| Automated Decision-Making | Not be subject to solely automated decisions with legal effects |
| Lodge Complaint | File a complaint with your supervisory authority |
Data Protection Officer: Email: townhall@fanwork.kr
EU Representative: \[To be appointed \- Contact information will be provided\]
UK Representative: \[To be appointed \- Contact information will be provided\]
Supervisory Authority: You have the right to lodge a complaint with your local data protection authority.
13.2 California, USA (CCPA/CPRA)
Your California Privacy Rights:
| Right | Description |
|---|---|
| Know | Categories and specific pieces of personal information collected |
| Delete | Request deletion of personal information |
| Opt-Out of Sale | We do not sell personal information |
| Non-Discrimination | No discrimination for exercising privacy rights |
| Correction | Request correction of inaccurate information |
| Limit Use of Sensitive Information | Limit processing of sensitive personal information |
Categories of Personal Information Collected (past 12 months):
| Category | Collected | Sold | Disclosed for Business Purpose |
|---|---|---|---|
| Identifiers | Yes | No | Yes (service providers) |
| Customer Records | Yes | No | Yes (service providers) |
| Commercial Information | No | No | No |
| Internet/Network Activity | Yes | No | Yes (analytics) |
| Geolocation | Yes (general) | No | Yes (analytics) |
| Professional Information | Yes (optional) | No | No |
| Inferences | Yes | No | No |
Shine the Light: California residents may request information about disclosure of personal information to third parties for direct marketing. We do not disclose personal information for third-party direct marketing.
Do Not Sell or Share My Personal Information: While we do not sell personal information, you can submit a "Do Not Sell or Share" request at townhall@fanwork.kr.
13.3 Brazil (LGPD)
Your Rights under LGPD:
| Right | Description |
|---|---|
| Confirmation | Confirm whether we process your data |
| Access | Access your personal data |
| Correction | Correct incomplete, inaccurate, or outdated data |
| Anonymization/Blocking/Deletion | For unnecessary or excessive data |
| Portability | Transfer data to another service provider |
| Deletion | Delete data processed with consent |
| Information | Know about sharing with third parties |
| Revoke Consent | Withdraw consent at any time |
Data Protection Officer (DPO): Email: townhall@fanwork.kr
ANPD Contact: You may file complaints with the National Data Protection Authority (ANPD).
13.4 India (DPDP Act 2023\)
Your Rights:
- Right to access information about your personal data
- Right to correction and erasure
- Right to grievance redressal
- Right to nominate (in case of death or incapacity)
Grievance Officer: Name: \[TBD\] Email: townhall@fanwork.kr Response: Acknowledgment within 24 hours, resolution within 15 days
Consent Manager: You can manage your consents through Settings \> Privacy \> Consent Preferences.
13.5 Indonesia (PDP Law)
Your Rights:
- Right to be informed about data collection
- Right to access, correct, and delete personal data
- Right to withdraw consent
- Right to object to automated decision-making
Data Controller: Data Town Inc. Email: townhall@fanwork.kr
13.6 Other Jurisdictions
Philippines (DPA 2012\): National Privacy Commission: https://www.privacy.gov.ph
Malaysia (PDPA 2010\): We comply with the seven data protection principles under PDPA.
Mexico (LFPDPPP): You have ARCO rights (Access, Rectification, Cancellation, Opposition).
Chile, Colombia, UAE: We comply with local data protection requirements. Contact townhall@fanwork.kr for specific inquiries.
14\. Contact Us
14.1 General Inquiries
Data Town Inc. Seoul Center, Korea Tourism Organization 40 Cheonggyecheon-ro, Jung-gu, Seoul, South Korea
Email: townhall@datatown.ai Website: https://fanwork.kr
14.2 Specific Contacts
| Purpose | Contact |
|---|---|
| General Privacy Questions | townhall@fanwork.kr |
| Data Protection Officer | townhall@fanwork.kr |
| Data Subject Requests | townhall@fanwork.kr |
| Grievance Officer (India) | townhall@fanwork.kr |
| DMCA/Copyright | townhall@fanwork.kr |
14.3 Response Times
- General inquiries: Within 5 business days
- Data subject requests: Within 30 days (may be extended for complex requests)
- Grievances (India): Acknowledgment within 24 hours, resolution within 15 days
Summary of Key Points
| Topic | Summary |
|---|---|
| What we collect | Account info, content you create, usage data |
| How we use it | Provide service, personalization, safety, analytics |
| Who we share with | Service providers, as required by law; we do not sell data |
| Your rights | Access, correction, deletion, portability, and more |
| Data retention | Active account \+ 30 days after deletion |
| Security | Encryption, access controls, regular assessments |
| Children | Not intended for users under minimum age (13-18 depending on country) |
| Contact | townhall@datatown.ai |