For the purposes of service usage statistics and screen usability analysis, the Company transfers users' personal data abroad as set out below.
① Google LLC — Google Analytics 4
| Item | Details |
|---|---|
| Transferee | Google LLC · 1600 Amphitheatre Parkway, Mountain View, California 94043, USA |
| Contact for the officer responsible for information management | Overseas transfer inquiries googlekrsupport@google.com · Domestic representative 구글코리아 유한회사(대표 낸시 메이블 워커 부마), 서울특별시 강남구 테헤란로 152, 22층, 02-722-7778, data-access-requests@google.com |
| Country of transfer | United States |
| Date and method of transfer | Transmitted from time to time over the information and communications network at the moment the user uses the Company's website |
| Items transferred | Cookie-based online identifiers; service usage records such as page views and clicks; the approximate region inferred from the access IP address; device and browser information ※ The user's name, email address and phone number are not transferred. |
| Purpose of transfer | Compilation of service usage statistics and service improvement through Google Analytics 4 |
| Retention and use period | As set by the Company in Google Analytics. Event data 2 months · User data 14 months. The “Reset on new activity” setting is enabled, so when a user uses the service again the retention period for that user's identifier is counted afresh from that point. The above settings apply to exploration analyses and attribution reports; the standard aggregate reports provided by Google are not subject to these settings. |
② Microsoft Corporation — Microsoft Clarity
| Item | Details |
|---|---|
| Transferee | Microsoft Corporation · One Microsoft Way, Redmond, Washington 98052, USA |
| Contact for the officer responsible for information management | Microsoft Privacy, +1 (425) 882 8080 · Domestic representative 한국마이크로소프트 유한회사(대표 조원우), 서울특별시 종로구 종로1길 50 더케이트윈타워 A동 12층, 02-722-7725, mskoreaprivacy@microsoft.com |
| Country of transfer | United States |
| Date and method of transfer | Transmitted from time to time over the information and communications network at the moment the user uses the Company's website |
| Items transferred | Cookie-based online identifiers; screen interaction records such as page views, clicks and scrolls; the approximate region inferred from the access IP address; device, browser and screen information ※ The user's name, email address and phone number are not transferred. |
| Purpose of transfer | Analysis of screen usability and service improvement through Microsoft Clarity |
| Retention and use period | Governed by the Clarity data retention policy published by Microsoft, which the Company cannot change. The currently published terms are as follows. Session playback data 30 days · Click data and heatmaps 9 months · Sessions that have been labelled or favourited 9 months. After the retention period elapses the data is deleted, including from backups, and is not recoverable. The latest terms can be checked in the official Microsoft guidance (learn.microsoft.com/clarity/setup-and-installation/data-retention). |
③ Right to refuse consent
You have the right not to consent to the transfers abroad set out above. Even if you do not consent, there is no restriction whatsoever on signing up for, purchasing, or using the Company's services. Even after consenting, you may withdraw your consent at any time by the method described in Article 11 of the Privacy Policy.
④ For reference — what this consent does not cover
- Payment processing (토스페이먼츠 주식회사) and server and database hosting (Tencent Cloud) are entrustments of processing under Article 26 of the Personal Information Protection Act; they are disclosed in the Privacy Policy and are not subject to separate consent.
- The Company passes product and activation information to the upstream telecommunications supplier in order to activate the eSIM, but does not pass identifying information such as the user's name, email address or phone number.
- With 카카오 / 네이버 / 구글 / Apple account login, the Company ‘receives’ information from those operators; the Company does not provide users’ personal data to them.
- The Company does not sell users’ personal data.
Contact
privacy@roamis.com · 1555-1850
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