Karrot Privacy Policy

Introduction

This policy (together with our Terms of Use applies to your use of:

Karrot mobile application software (App) hosted on the cloud via Amazon Web Services (App Site) once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).
Any of the services accessible through the App (Services) that are available on the App Site or other sites of ours (Services Sites).

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This App is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

Important information and who we are

Danggeun Market Inc is the controller and is responsible for your personal data (collectively referred to as the "Company", "we", "us" or "our" in this policy). We have appointed a data protection representative. If you have any questions about this privacy policy, please contact them using the details set out below.

Contact details

Our full details are:

Full name of legal entity: Danggeun Market Inc
Name of Data Protection Representative: Changhun Jung
Email address: seapy@daangn.com
Postal address: 14, Teheran-ro 4-gil, Gangnam-gu, Seoul, Republic of Korea
Telephone number: +44-7446-250299

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated in October 2019. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you when you next start the App. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

Third party links

The App may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services. The data we collect about you We may collect, use, store and transfer different kinds of personal data about you as follows:

Identity Data.
Contact Data.
Financial Data.
Transaction Data.
Device Data.
Content Data.
Profile Data.
Usage Data.
Marketing and Communications Data.
Location Data.

We explain these categories of data below.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy

We will only process Special Categories of Personal Data about you if you voluntarily place such information in the course of using the App (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data such as fingerprints or facial boimetrics). We do not collect any information about criminal convictions and offences.

How is your personal data collected?

We will collect and process the following data about you:

Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the App Site or Service Sites (together our Sites) or by corresponding with us (for example, by email or chat). It includes information you provide when register to use the App Site, you download or register an App, subscribe to any of our Services, search for an App or Service, make an in-App purchase, share data via an App's social media functions, enter a competition, promotion or survey, and when you report a problem with the App, our Services, or any of our Sites. If you contact us, we will keep a record of that correspondence.
Information we collect about you and your device. Each time you use the App or access our Sites we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy below for further details.
Location Data. We also use GPS technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings. We will not pass your Location Data onto a third party (including those External Third Parties identified in the Glossary below) unless it is strictly necessary to provide the Services to you or to comply with a legal obligation imposed on Us.
Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties as set out below
Device Data from analytics providers such as Google Analytics and BigQuery based outside the EU;
Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Data Collect based inside the EU
Identity and Contact Data from Google accessing your Google login data;
Unique application numbers. When you want to install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.

Cookies

We use cookies and/or other tracking technologies to distinguish you from other users of the App, the App Site and the distribution platform (Appstore or Googleplay) and to remember your preferences. This helps us to provide you with a good experience when you use the App or when you use any of Our Sites and also allows us to improve the App and our Sites. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy below.

How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

Where you have consented before the processing.
Where we need to perform a contract we are about to enter or have entered with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.

See below to find out more about the types of lawful basis that we will rely on to process your personal data. We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Purposes for which we will use your personal data

Purpose/activity	Type of data	Lawful basis for processing
To install the App and register you as a new App user	Identity Contact Financial Device	Your consent Performance of a contract with you
To process in-App purchases and deliver Services including managing payments and collecting money owed to us	Identity Contact Financial Transaction Device Marketing and Communications Location	Your consent Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you including notifying you of changes to the App or any Services	Identity Contact Financial Profile Marketing and Communications	Your consent Performance of a contract with you Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services) Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
To enable you to participate in a prize draw, competition or complete a survey	Identity Contact Device Profile Marketing and Communications	Your consent Performance of a contract with you Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business)
To administer and protect our business and this App including troubleshooting, data analysis and system testing	Identity Contact Device	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)
To deliver content and advertisements to you To make recommendations to you about goods or services which may interest you To measure and analyse the effectiveness of the advertising we serve you To monitor trends so we can improve the App	Identity Contact Device Content Profile Usage Marketing and Communications Location	Consent Necessary for our legitimate interests (to develop our products/Services and grow our business)
To enable you to use the Services	Content (Special Category)	Consent and Explicit Consent (Article 9 (2)(a)) Processing relates to personal data which has been made manifestly public by the data subject (Article (2) (e)

Disclosures of your personal data

When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table Purposes for which we will use your personal data:

External Third Parties as set out in the Glossary.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

International transfers

Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Where we transfer data to countries that are not deemed to provide an adequate level of protection, we will anonymise any personal data before transferring the data to such countries. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data security

All information you provide to us is stored on secure servers operated on the public cloud by Amazon Web Services (AWS). Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using SSL. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way. We will collect and store personal data on your Device using application data caches and browser web storage (including HTML5 and other technology. Certain Services include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

Data retention

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request by contacting us. By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. We will only retain Location Data for a maximum period of six months. In some circumstances you can ask us to delete your data: see Your legal rights below for further information. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your legal rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data.

Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer or your personal data.
Right to withdraw consent.

You also have the right to ask us not to continue to process your personal data for marketing purposes. You can exercise any of these rights at any time by contacting us at help@karrotmarket.com.

Glossary

Lawful basis

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us. Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Third parties

External third parties

Service providers acting as processors based in the UK and US who provide IT and system administration services. Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK and South Korea who provide consultancy, banking, legal, insurance and accounting services. Regulators and other authorities acting as processors or joint controllers based in the UK and South Korea who may require reporting of processing activities in certain circumstances. Service providers acting as processors based in the United States such as Google Analytics, BigQuery, Appsflyer to provide website and App analytics and analysis.

Your legal rights

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Description of categories of personal data

Identity Data: first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender, passport number, educational or professional background, job title or function
Contact Data: billing address, delivery address, email address and mobile telephone numbers.
Financial Data: bank account and payment card details and any other data necessary for processing payments and fraud prevention including security code numbers and related billing information
Transaction Data: includes details about payments to and from you and details of in-App purchases.
Device Data: includes the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting, browser plug-in types and versions, operating systems and platform.
Content Data: includes information stored on your Device, including contact lists, login information, photos, videos or other digital content
Profile Data: includes your username and password, in-App purchase history, your interests, preferences, feedback and survey responses.
Usage Data: includes details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preference.
Location Data: includes your current location disclosed by GPS technology. We will use this data only for the purpose of authenticating your location when you select a particular market to enter.
Sensitive personal data: In the event you voluntarily or accidently reveal sensitive information about you (that is your racial or ethnic origin, political opinions, religious beliefs, trade union activities, physical or mental health, sex life or sexual orientation, details or criminal offences or genetic or biometric data.

Cookie Policy

What are cookies?

Cookies are very small text files that the server used to operate the website sends to the user’s web browser. They are saved on your computer or mobile device. When you visit the website or App, the server reads the contents of the cookies saved in your device.

What are cookies for?

Karrot uses cookies that save and frequently retrieve the user’s information in order to:

Recognise you when you re-visit Our Sites. This helps us to personalise our content and information such as optimised advertisements. It also enables us to recognise your preferences each time you visit.
Recognise how many visitors to Our Sites and visitor behaviour. This helps us to improve our services and functionality. We use the following cookies:
Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie Title Cookie Name Type of Cookie	Purpose	Cookie Expiry
Third Party Cookies Facebook Pixel _fbp	This Cookie is placed by Facebook. It enables Karrot to measure, optimize and build audiences for advertising campaigns served on Facebook. In particular it enables Karrot to see how our users move between devices when accessing the Karrot web site and Facebook, to ensure that Karrot Facebook advertising is seen by our users most likely to be interested in such advertising by analysing which content a user has viewed and interacted with on the Karrot web site. To opt-out please see https://www.facebook.com/ads/preferences	3 Months

Please note that the following third parties may also use cookies, over which we have no control. These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third party cookies are likely to be analytical cookies or performance cookies or targeting cookies:

Facebook – For further information about the cookies which may be used by Facebook, please visit Facebook’s privacy page https://en-gb.facebook.com/policies/cookies/

To deactivate the use of third party advertising cookies, you may visit the consumer page of Facebook to manage the use of these types of cookies.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

If using Internet Explorer -

Internet Explorer: Tool Bar (top of the web browser) > Internet Options > Privacy > Settings

If using Chrome -

Chrome: Settings (top right of the web browser) > “Advanced” at the bottom of the screen > Privacy and Security > Site Settings > Cookies