Table of Contents

Advance notice of amendments to the Terms and Privacy Policy for optional Instagram connection

INTELLIEFFECT plans to amend Castera's Terms and Privacy Policy concerning optional Instagram account connection. The amendments cover processing connected-account identifiers and encrypted access tokens, retrieving the account's own posts, obtaining separate consent to publish selected official links, and data retention, disconnection and deletion. They do not introduce downloading, rehosting or embedding original media, or publishing Instagram posts.

Published 2026-10-19

Planned effective date 2026-11-18

Scope

  • The currently effective Terms and Privacy Policy continue to apply until the amendments take effect. This notice does not open the feature to ordinary members. Testing with approved testers will use separate information and consent. Connecting an account is optional and separate from registration; it is not identity, copyright or Meta verification. The changes and the current and proposed documents are available with this notice. Questions: dev@intellieffect.com.

Contact — dev@intellieffect.com

Read the currently effective document · v9 · 2026-09-17

Privacy Policy

Effective Date 2026-09-17

IntelliEffect (the "Company") complies with the Personal Information Protection Act (PIPA, Korea) and other applicable laws, and establishes and discloses the following Privacy Policy in order to safely process users' personal information. This Policy applies to the Castera service operated by the Company.

At a Glance

Information We Collect
Account information such as email address and display name, service usage records, and cookies and advertising identifiers used for analytics and advertising performance measurement.
Purpose of Use
Used to provide the Service, including member authentication, Creator–Brand matching, contract execution, payment, and settlement.
Retention Period
Destroyed without delay upon withdrawal of membership. Only information subject to a statutory retention obligation is retained as an exception.
Contact
For privacy-related inquiries, please contact dev@intellieffect.com.

1. Personal Information Collected and Methods of Collection

The Company collects the following personal information during member registration, provision of the Service, and the payment/settlement process.

1. Personal Information Collected and Methods of Collection
CategoryApplicable ToItems CollectedTime of Collection
RequiredAll MembersEmail address, password (for email registration · stored using one-way encryption), display name, role information (Creator/Brand)At registration and onboarding
RequiredAll membersAge confirmation consent — the member confirms they are 19 or older; only the consent and its timestamp are recorded (no additional identity data is collected for this)At sign-up and onboarding
RequiredWhen using social loginSocial account identifier, email address, profile name (provided by Google · LINE)When linking a social account
RequiredCreator MembersSNS handle in operation (account URL), area of activityAt Creator registration
RequiredBrand MembersCompany (brand) name, contact person information, industryAt Brand registration
RequiredWhen using payment/settlementPayment approval information (original payment instrument data not retained), settlement account information, tax invoice issuance informationAt payment/settlement
Automatically collectedAll usersAccess logs, device/browser information, service usage records, error logs, cookies and advertising identifiers, ad referral and conversion recordsDuring use of the Service

The original data of payment instruments, such as card numbers, is processed by the electronic payment service provider (Toss Payments), and the Company does not store it.

2. Purposes of Processing Personal Information

Personal information collected is processed for the following purposes, and where the purpose changes, separate consent will be obtained in accordance with applicable laws.

  1. Member registration, authentication, and management — identity verification, prevention of fraudulent use, and various notices
  2. Age verification — blocking registration by anyone under 19 (confirmed by the member's own consent)
  3. Provision of the Service — Creator–Brand matching, support for executing and performing Campaign contracts, inter-Member messaging functions
  4. Payment processing, escrow deposit, and settlement processing
  5. Maintaining a safe transaction environment — preventing circumvention transactions, responding to disputes, protecting accounts
  6. Service improvement and statistical analysis (in a form that does not identify individuals)
  7. Fulfilling obligations under applicable laws

Where personal information is used for marketing purposes, separate consent will be obtained, and use of the Service is not restricted if consent is not given.

3. Retention and Use Period of Personal Information

In principle, the Company destroys personal information without delay upon a Member's withdrawal. However, in the following cases, the information is stored separately for the relevant period before being destroyed.

3. Retention and Use Period of Personal Information
Basis for RetentionItems RetainedPeriod
Act on the Consumer Protection in Electronic Commerce, etc. (Korea)Records relating to contracts or withdrawal of subscription5 years
Act on the Consumer Protection in Electronic Commerce, etc. (Korea)Records relating to payment and supply of goods, etc.5 years
Act on the Consumer Protection in Electronic Commerce, etc. (Korea)Records relating to consumer complaints or dispute handling3 years
Protection of Communications Secrets Act (Korea)Service access records3 months
Internal policy (fraud prevention)Records relating to fraudulent registration or restriction of use1 year after withdrawal

A Creator's SNS handle is deleted within 30 days of the Member's withdrawal, in accordance with the SNS Handle Non-Disclosure Policy.

4. Provision of Personal Information to Third Parties

In principle, the Company does not provide users' personal information to outside parties, and provides it only where the user has given prior consent or there is a legal basis for doing so.

Given the nature of the Service, the following provision occurs during the process of executing a Campaign contract.

4. Provision of Personal Information to Third Parties
RecipientItems ProvidedPurpose of ProvisionRetention/Use Period
The counterparty Brand Member with whom a Campaign contract has been executedCreator's SNS handlePerformance of the executed Campaign contract — disclosed upon execution of the contract and full deposit of the payment into escrowUntil the purpose of the contract is achieved

Before a contract is executed, a Creator's SNS handle is not provided to any advertiser under any circumstances. Please refer to the SNS Handle Non-Disclosure Policy for details.

5. Outsourcing of Personal Information Processing

To provide a stable Service, the Company outsources personal information processing tasks as follows.

5. Outsourcing of Personal Information Processing
ProcessorOutsourced Task
Supabase, Inc.Database operation and member authentication infrastructure
Vercel Inc.Service hosting and web analytics (cookieless)
Google LLCWebsite usage analysis (Google Analytics 4) and targeted advertising and conversion measurement (Google Ads)
Meta Platforms, Inc.Targeted advertising and ad performance and conversion measurement (Meta Pixel and server-side transmission via Conversions API)
Toss Payments Co., Ltd.Electronic payment processing (including escrow)

When entering into an outsourcing agreement, the Company stipulates compliance with applicable personal information protection laws, restrictions on re-outsourcing, and technical and administrative protective measures, and supervises the processor.

6. Overseas Transfer of Personal Information

The servers of some cloud services used by the Company are located overseas, and personal information is transferred overseas as follows in the course of using the Service.

6. Overseas Transfer of Personal Information
RecipientCountryItems TransferredMethod/Time of TransferRetention Period
Supabase, Inc.United States, etc.Account information, service usage dataTransmitted and stored via the information and communications network when using the ServiceUntil termination of the outsourcing agreement or withdrawal of membership
Vercel Inc.United States, etc.Access records, de-identified web analytics dataTransmitted via the information and communications network when accessing the ServiceUntil the purpose of collection is achieved
Google LLCUnited StatesCookie and advertising identifiers, visit and page view records, referral sources, ad click and conversion records (such as signup started and signup completed), hashed email address (for members who completed sign-up), device and browser information, approximate location (city level)Transmitted via the information and communications network when accessing the Service14 months for usage analysis; ad conversion data until the end of the period under Google's retention policy
Meta Platforms, Inc.United StatesCookie and advertising identifiers, IP address, visit and page view records, ad click and conversion records (sign-up, inquiry, etc.), device and browser information, approximate location, hashed email address, hashed member identifierTransmitted via the information and communications network when accessing the Service and when a conversion occursUntil the end of the period under Meta's retention policy

Users may refuse the overseas transfer of their personal information. However, because overseas transfer is essential infrastructure for providing the Service, use of the Service may be restricted if refused. A refusal request may be made to dev@intellieffect.com.

7. Procedure and Method for Destruction of Personal Information

The Company destroys personal information without delay once it becomes unnecessary, such as upon expiry of the retention period or achievement of the processing purpose.

Information in electronic file form is deleted using a technical method that prevents recovery, and paper documents are destroyed by shredding or incineration. Information that must be retained under applicable law is stored separately in a separate storage space and destroyed immediately upon expiry of the retention period.

8. Users' Rights and How to Exercise Them

Users may exercise the following rights against the Company at any time, and the Company shall take action without delay within the period prescribed by applicable law.

Rights may be exercised through the settings screen within the Service or by email (dev@intellieffect.com), and may also be exercised through a legal representative or an authorized agent. In such a case, a power of attorney in accordance with applicable law must be submitted.

  1. Request to access personal information
  2. Request for correction where there is an error
  3. Request for deletion
  4. Request to suspend processing
  5. Withdrawal of consent to the collection and use of personal information (withdrawal of membership)

The exercise of rights may be restricted where applicable law mandates the collection or retention of the relevant personal information, and in such a case the reason will be provided.

9. Cookies, Analytics, and Advertising Tools

The Company uses cookies essential to providing the Service, such as for maintaining login sessions. Essential cookies are required for use of the Service, and if blocked in the browser, some functions such as login may not be available.

The Company uses Vercel Web Analytics and Speed Insights to understand service usage (visitor counts, page views, referral sources) and web performance (loading speed, etc.). These tools do not use cookies (cookieless) and do not collect information that can identify an individual user.

Separately from the above, the Company uses Google Analytics 4 to analyze how the Service is used. This tool stores cookies on the user's device to distinguish visitors (such as _ga and cookies beginning with _ga_), and collects visit date and time, session duration, pages viewed, referral source, device and browser information, and approximate location (city level). The information collected is processed in a form that does not directly identify an individual, and is retained for 14 months.

Through the use of Google Analytics 4, the above information is transferred to and processed on servers operated by Google LLC (United States). The items transferred are the same as those described in the preceding paragraph, and the purpose of the transfer is analysis of Service usage. Users who do not wish for such transfer may block collection using the methods described below.

The Company uses Meta Pixel (Meta Platforms, Inc.) and Google Ads tags (Google LLC) to deliver targeted advertising and measure advertising performance. These tools store cookies and advertising identifiers on the user's device and collect ad clicks, referral paths, and conversion actions within the Service (such as sign-up and inquiry). The information collected is used for advertising performance measurement, delivery of targeted advertising, and delivery of advertising to similar audiences, and is transferred to and processed on servers operated by each provider (United States).

To measure Google Ads advertising performance, the Company sends signup started (a secondary conversion) and signup completed (split into creator and brand) to Google Ads as conversions. Submitted inquiries are not sent to Google Ads as conversions. When a user arrives by clicking an ad, the ad click identifier (gclid) is stored on the user's device as a cookie (such as _gcl_aw) and used to link that ad to the conversion; when a conversion occurs, the conversion type and conversion value are sent with it. The Company also sends a SHA-256 hash of the email address of the member who completed sign-up to Google Ads together with the conversion, to improve Enhanced Conversions matching accuracy — the plain-text email address is never sent. The Company also sets the defaults of Google Consent Mode (Consent Mode v2) to 'granted' for all of ad cookie storage (ad_storage), analytics cookie storage (analytics_storage), sending user data for advertising purposes (ad_user_data), and ad personalization (ad_personalization), and provides notice through this Policy instead of displaying a separate consent banner. Users can opt out of collection and targeted advertising using the methods below.

Users can block collection by enabling their browser's tracking prevention features (such as Safari's 'Prevent Cross-Site Tracking,' Chrome's 'Block third-party cookies,' or Firefox's 'Enhanced Tracking Protection'), or by installing the 'Google Analytics Opt-out Browser Add-on' provided by Google (https://tools.google.com/dlpage/gaoptout). Targeted advertising can be opted out of separately through Meta Ad Preferences (https://www.facebook.com/adpreferences) and Google Ads Settings (https://adssettings.google.com). This has no effect on use of the Service.

10. Measures to Ensure the Safety of Personal Information

The Company takes the following measures to ensure the safety of personal information.

  1. Administrative measures — establishing and implementing an internal management plan, minimizing access privileges to personal information, and managing access records
  2. Technical measures — one-way encrypted storage of passwords, encryption of data in transit (TLS), database access control, and application of Row Level Security
  3. Physical measures — utilizing the cloud provider's physical access controls and security certification systems
  4. Minimizing access privileges to, and managing access logs for, highly sensitive information such as SNS handles

11. Data Protection Officer and Contact

The Company designates a Data Protection Officer as set out below, who oversees personal information processing and handles users' complaints and remedies relating to the processing of personal information.

Users may direct any inquiry, complaint, or request for remedy relating to personal information arising from use of the Service to the contact below, and the Company will respond and address it without delay.

11. Data Protection Officer and Contact
CategoryDetails
Data Protection OfficerCEO of IntelliEffect
Contact Emaildev@intellieffect.com

12. Remedies for Infringement of Rights

Users who need to report or consult regarding an infringement of personal information may contact the following institutions.

12. Remedies for Infringement of Rights
InstitutionContactWebsite
Personal Information Dispute Mediation Committee1833-6972 (no area code)www.kopico.go.kr
KISA Privacy Center (Korea Internet & Security Agency)118 (no area code)privacy.kisa.or.kr
Supreme Prosecutors' Office Cyber Investigation Division1301 (no area code)www.spo.go.kr
National Police Agency Cyber Investigation Bureau182 (no area code)ecrm.police.go.kr

13. Duty to Notify and Amendments

Where the content of this Privacy Policy is added, deleted, or amended, notice will be given through the Service's announcements starting 7 days before the effective date. However, where an amendment materially affects users' rights, such as a change in the items collected or provision to third parties, notice will be given 30 days before the effective date, and separate consent will be obtained again where necessary.

Data Protection Officer & Contact

Data Protection Officer

CEO of IntelliEffect

dev@intellieffect.com

Handles inquiries and requests to access, correct, delete, and suspend processing of personal information.

Revision History

  • v9 · 2026-09-17 — Removed submitted inquiries from Google Ads conversions and reorganized to signup started (secondary conversion) and signup completed (split by creator/brand) — for Enhanced Conversions matching, a SHA-256 hash of the completing member's email is now sent with the conversion; the plain-text email is never sent
  • v8 · 2026-09-16 — Specified Google Ads conversion measurement (sign-ups and inquiries, gclid cookie, conversion value) and the 'granted' defaults of Google Consent Mode (Consent Mode v2) in the cookies and advertising tools section — notice given through this Policy instead of a consent banner; no new items collected
  • v7 · 2026-08-25 — Reflected the hashed email address and hashed member identifier that are now included in server-side transmission to Meta (Conversions API) — hashed with SHA-256 at sign-up; raw values are never transmitted
  • v6 · 2026-08-19 — Reflected the IP address already being transmitted via Meta server-side transmission (Conversions API) in the transferred items — outsourced tasks now note server-side transmission (Conversions API), and IP address was added to the overseas transfer items
  • v5 · 2026-08-05 — Removed date of birth as a collected item — the 19+ check is now a member's own confirmation consent (only the consent and its timestamp are recorded)
  • v4 · 2026-08-04 — Added date of birth as a collected item for the 19+ age check — stated as not retained after verification
  • v3 · 2026-08-03 — Reflects the introduction of advertising tools — discloses the use of Meta Pixel and Google Ads tags, adds cookies/advertising identifiers and conversion records to automatically collected items, adds Meta Platforms to processors and overseas transfers, and provides opt-out methods for targeted advertising
  • v2 · 2026-07-28 — Complete revision — reorganized the table of items collected; added outsourcing of processing, overseas transfer, provision to third parties, safety measures, and remedies for infringement of rights
  • v1 · 2026-05-18 — Initial enactment
Instagram

Proposed amended document

Privacy Policy

v10Planned effective date 2026-11-18

IntelliEffect (the "Company") complies with the Personal Information Protection Act (PIPA, Korea) and other applicable laws, and establishes and discloses the following Privacy Policy in order to safely process users' personal information. This Policy applies to the Castera service operated by the Company.

At a Glance

Information We Collect

Account information such as email address and display name, service usage records, and cookies and advertising identifiers used for analytics and advertising performance measurement.

Purpose of Use

Used to provide the Service, including member authentication, Creator–Brand matching, contract execution, payment, and settlement.

Retention Period

Destroyed without delay upon withdrawal of membership. Only information subject to a statutory retention obligation is retained as an exception.

Contact

For privacy-related inquiries, please contact dev@intellieffect.com.

1. Personal Information Collected and Methods of Collection

The Company collects the following personal information during member registration, provision of the Service, and the payment/settlement process.

Optional Instagram connection: we store the account ID, username, app ID, connection and expiration times, encrypted access token, and selected post IDs and official links. During connection we use a session-bound, single-use state hash valid for up to ten minutes. Unselected posts are fetched transiently for selection and are not stored. We associate these records with Castera member, persona and internal connection IDs. For connection security, we also store a browser-binding hash, locale, and state expiration and consumption times. Post types are used transiently in the selection screen and are not stored.

1. Personal Information Collected and Methods of Collection
CategoryApplicable ToItems CollectedTime of Collection
RequiredAll MembersEmail address, password (for email registration · stored using one-way encryption), display name, role information (Creator/Brand)At registration and onboarding
RequiredAll membersAge confirmation consent — the member confirms they are 19 or older; only the consent and its timestamp are recorded (no additional identity data is collected for this)At sign-up and onboarding
RequiredWhen using social loginSocial account identifier, email address, profile name (provided by Google · LINE)When linking a social account
RequiredCreator MembersSNS handle in operation (account URL), area of activityAt Creator registration
RequiredBrand MembersCompany (brand) name, contact person information, industryAt Brand registration
RequiredWhen using payment/settlementPayment approval information (original payment instrument data not retained), settlement account information, tax invoice issuance informationAt payment/settlement
Automatically collectedAll usersAccess logs, device/browser information, service usage records, error logs, cookies and advertising identifiers, ad referral and conversion recordsDuring use of the Service

The original data of payment instruments, such as card numbers, is processed by the electronic payment service provider (Toss Payments), and the Company does not store it.

2. Purposes of Processing Personal Information

Personal information collected is processed for the following purposes, and where the purpose changes, separate consent will be obtained in accordance with applicable laws.

We use this data to verify Instagram account access, select posts belonging to the account and publish explicitly approved official links. Tokens are encrypted in server-only storage and are never provided to visitors or brands. The operator is INTELLIEFFECT. This connection is not real-name, know-your-customer (KYC), or content-rights verification, and does not guarantee recommendations or increased algorithmic exposure. Publication uses official links only; original images and videos are not downloaded or rehosted.

  1. Member registration, authentication, and management — identity verification, prevention of fraudulent use, and various notices
  2. Age verification — blocking registration by anyone under 19 (confirmed by the member's own consent)
  3. Provision of the Service — Creator–Brand matching, support for executing and performing Campaign contracts, inter-Member messaging functions
  4. Payment processing, escrow deposit, and settlement processing
  5. Maintaining a safe transaction environment — preventing circumvention transactions, responding to disputes, protecting accounts
  6. Service improvement and statistical analysis (in a form that does not identify individuals)
  7. Fulfilling obligations under applicable laws

Where personal information is used for marketing purposes, separate consent will be obtained, and use of the Service is not restricted if consent is not given.

3. Retention and Use Period of Personal Information

In principle, the Company destroys personal information without delay upon a Member's withdrawal. However, in the following cases, the information is stored separately for the relevant period before being destroyed.

Connection data is retained while connected. Connection data and selected links are deleted on disconnect, processing of deletion requests, account/persona deletion or confirmed authorization loss. Expired connections are hidden and deleted on next access. Single-use OAuth states become unusable after ten minutes and are removed when the same persona next starts a connection, disconnects or is deleted; there is no scheduled cleanup job. When revalidation detects that source posts are deleted, private or inaccessible, links are hidden; stored selections are not necessarily deleted immediately.

3. Retention and Use Period of Personal Information
Basis for RetentionItems RetainedPeriod
Act on the Consumer Protection in Electronic Commerce, etc. (Korea)Records relating to contracts or withdrawal of subscription5 years
Act on the Consumer Protection in Electronic Commerce, etc. (Korea)Records relating to payment and supply of goods, etc.5 years
Act on the Consumer Protection in Electronic Commerce, etc. (Korea)Records relating to consumer complaints or dispute handling3 years
Protection of Communications Secrets Act (Korea)Service access records3 months
Internal policy (fraud prevention)Records relating to fraudulent registration or restriction of use1 year after withdrawal

A Creator's SNS handle is deleted within 30 days of the Member's withdrawal, in accordance with the SNS Handle Non-Disclosure Policy. The connection-data deletion rules above apply to optional Instagram connection data; the general 30-day SNS-handle retention period after withdrawal does not extend token retention.

4. Provision of Personal Information to Third Parties

In principle, the Company does not provide users' personal information to outside parties, and provides it only where the user has given prior consent or there is a legal basis for doing so.

Given the nature of the Service, the following provision occurs during the process of executing a Campaign contract.

4. Provision of Personal Information to Third Parties
RecipientItems ProvidedPurpose of ProvisionRetention/Use Period
The counterparty Brand Member with whom a Campaign contract has been executedCreator's SNS handlePerformance of the executed Campaign contract — disclosed upon execution of the contract and full deposit of the payment into escrowUntil the purpose of the contract is achieved

Private SNS handles are not provided to advertisers before a contract. However, official links selected and explicitly approved for publication in the Instagram connection screen are public to visitors and brands and can reveal the account. Unselected handles and other private information remain protected.

5. Outsourcing of Personal Information Processing

To provide a stable Service, the Company outsources personal information processing tasks as follows.

5. Outsourcing of Personal Information Processing
ProcessorOutsourced Task
Supabase, Inc.Database operation and member authentication infrastructure
Vercel Inc.Service hosting and web analytics (cookieless)
Google LLCWebsite usage analysis (Google Analytics 4) and targeted advertising and conversion measurement (Google Ads)
Meta Platforms, Inc.Targeted advertising and ad performance and conversion measurement (Meta Pixel and server-side transmission via Conversions API)
Toss Payments Co., Ltd.Electronic payment processing (including escrow)

When entering into an outsourcing agreement, the Company stipulates compliance with applicable personal information protection laws, restrictions on re-outsourcing, and technical and administrative protective measures, and supervises the processor.

6. Overseas Transfer of Personal Information

The servers of some cloud services used by the Company are located overseas, and personal information is transferred overseas as follows in the course of using the Service.

6. Overseas Transfer of Personal Information
RecipientCountryItems TransferredMethod/Time of TransferRetention Period
Supabase, Inc.United States, etc.Account information, service usage dataTransmitted and stored via the information and communications network when using the ServiceUntil termination of the outsourcing agreement or withdrawal of membership
Vercel Inc.United States, etc.Access records, de-identified web analytics dataTransmitted via the information and communications network when accessing the ServiceUntil the purpose of collection is achieved
Google LLCUnited StatesCookie and advertising identifiers, visit and page view records, referral sources, ad click and conversion records (such as signup started and signup completed), hashed email address (for members who completed sign-up), device and browser information, approximate location (city level)Transmitted via the information and communications network when accessing the Service14 months for usage analysis; ad conversion data until the end of the period under Google's retention policy
Meta Platforms, Inc.United StatesCookie and advertising identifiers, IP address, visit and page view records, ad click and conversion records (sign-up, inquiry, etc.), device and browser information, approximate location, hashed email address, hashed member identifierTransmitted via the information and communications network when accessing the Service and when a conversion occursUntil the end of the period under Meta's retention policy

Users may refuse the overseas transfer of their personal information. However, because overseas transfer is essential infrastructure for providing the Service, use of the Service may be restricted if refused. A refusal request may be made to dev@intellieffect.com.

7. Procedure and Method for Destruction of Personal Information

The Company destroys personal information without delay once it becomes unnecessary, such as upon expiry of the retention period or achievement of the processing purpose.

Information in electronic file form is deleted using a technical method that prevents recovery, and paper documents are destroyed by shredding or incineration. Information that must be retained under applicable law is stored separately in a separate storage space and destroyed immediately upon expiry of the retention period.

8. Users' Rights and How to Exercise Them

Users may exercise the following rights against the Company at any time, and the Company shall take action without delay within the period prescribed by applicable law.

Rights may be exercised through the settings screen within the Service or by email (dev@intellieffect.com), and may also be exercised through a legal representative or an authorized agent. In such a case, a power of attorney in accordance with applicable law must be submitted.

  1. Request to access personal information
  2. Request for correction where there is an error
  3. Request for deletion
  4. Request to suspend processing
  5. Withdrawal of consent to the collection and use of personal information (withdrawal of membership)

The exercise of rights may be restricted where applicable law mandates the collection or retention of the relevant personal information, and in such a case the reason will be provided.

9. Cookies, Analytics, and Advertising Tools

The Company uses cookies essential to providing the Service, such as for maintaining login sessions. Essential cookies are required for use of the Service, and if blocked in the browser, some functions such as login may not be available.

The Company uses Vercel Web Analytics and Speed Insights to understand service usage (visitor counts, page views, referral sources) and web performance (loading speed, etc.). These tools do not use cookies (cookieless) and do not collect information that can identify an individual user.

Separately from the above, the Company uses Google Analytics 4 to analyze how the Service is used. This tool stores cookies on the user's device to distinguish visitors (such as _ga and cookies beginning with _ga_), and collects visit date and time, session duration, pages viewed, referral source, device and browser information, and approximate location (city level). The information collected is processed in a form that does not directly identify an individual, and is retained for 14 months.

Through the use of Google Analytics 4, the above information is transferred to and processed on servers operated by Google LLC (United States). The items transferred are the same as those described in the preceding paragraph, and the purpose of the transfer is analysis of Service usage. Users who do not wish for such transfer may block collection using the methods described below.

The Company uses Meta Pixel (Meta Platforms, Inc.) and Google Ads tags (Google LLC) to deliver targeted advertising and measure advertising performance. These tools store cookies and advertising identifiers on the user's device and collect ad clicks, referral paths, and conversion actions within the Service (such as sign-up and inquiry). The information collected is used for advertising performance measurement, delivery of targeted advertising, and delivery of advertising to similar audiences, and is transferred to and processed on servers operated by each provider (United States).

To measure Google Ads advertising performance, the Company sends signup started (a secondary conversion) and signup completed (split into creator and brand) to Google Ads as conversions. Submitted inquiries are not sent to Google Ads as conversions. When a user arrives by clicking an ad, the ad click identifier (gclid) is stored on the user's device as a cookie (such as _gcl_aw) and used to link that ad to the conversion; when a conversion occurs, the conversion type and conversion value are sent with it. The Company also sends a SHA-256 hash of the email address of the member who completed sign-up to Google Ads together with the conversion, to improve Enhanced Conversions matching accuracy — the plain-text email address is never sent. The Company also sets the defaults of Google Consent Mode (Consent Mode v2) to 'granted' for all of ad cookie storage (ad_storage), analytics cookie storage (analytics_storage), sending user data for advertising purposes (ad_user_data), and ad personalization (ad_personalization), and provides notice through this Policy instead of displaying a separate consent banner. Users can opt out of collection and targeted advertising using the methods below.

Users can block collection by enabling their browser's tracking prevention features (such as Safari's 'Prevent Cross-Site Tracking,' Chrome's 'Block third-party cookies,' or Firefox's 'Enhanced Tracking Protection'), or by installing the 'Google Analytics Opt-out Browser Add-on' provided by Google (https://tools.google.com/dlpage/gaoptout). Targeted advertising can be opted out of separately through Meta Ad Preferences (https://www.facebook.com/adpreferences) and Google Ads Settings (https://adssettings.google.com). This has no effect on use of the Service.

10. Measures to Ensure the Safety of Personal Information

The Company takes the following measures to ensure the safety of personal information.

  1. Administrative measures — establishing and implementing an internal management plan, minimizing access privileges to personal information, and managing access records
  2. Technical measures — one-way encrypted storage of passwords, encryption of data in transit (TLS), database access control, and application of Row Level Security
  3. Physical measures — utilizing the cloud provider's physical access controls and security certification systems
  4. Minimizing access privileges to, and managing access logs for, highly sensitive information such as SNS handles

11. Data Protection Officer and Contact

The Company designates a Data Protection Officer as set out below, who oversees personal information processing and handles users' complaints and remedies relating to the processing of personal information.

Users may direct any inquiry, complaint, or request for remedy relating to personal information arising from use of the Service to the contact below, and the Company will respond and address it without delay.

11. Data Protection Officer and Contact
CategoryDetails
Data Protection OfficerCEO of IntelliEffect
Contact Emaildev@intellieffect.com

12. Remedies for Infringement of Rights

Users who need to report or consult regarding an infringement of personal information may contact the following institutions.

12. Remedies for Infringement of Rights
InstitutionContactWebsite
Personal Information Dispute Mediation Committee1833-6972 (no area code)www.kopico.go.kr
KISA Privacy Center (Korea Internet & Security Agency)118 (no area code)privacy.kisa.or.kr
Supreme Prosecutors' Office Cyber Investigation Division1301 (no area code)www.spo.go.kr
National Police Agency Cyber Investigation Bureau182 (no area code)ecrm.police.go.kr

13. Duty to Notify and Amendments

Where the content of this Privacy Policy is added, deleted, or amended, notice will be given through the Service's announcements starting 7 days before the effective date. However, where an amendment materially affects users' rights, such as a change in the items collected or provision to third parties, notice will be given 30 days before the effective date, and separate consent will be obtained again where necessary.

Data Protection Officer & Contact

Data Protection Officer

CEO of IntelliEffect

dev@intellieffect.com

Handles inquiries and requests to access, correct, delete, and suspend processing of personal information.

Revision History

  • v10 · 2026-11-18 — Advance notice of amendments to the Terms and Privacy Policy for optional Instagram connection — Publication date: October 19, 2026 / Planned effective date: November 18, 2026
  • v9 · 2026-09-17 — Removed submitted inquiries from Google Ads conversions and reorganized to signup started (secondary conversion) and signup completed (split by creator/brand) — for Enhanced Conversions matching, a SHA-256 hash of the completing member's email is now sent with the conversion; the plain-text email is never sent
  • v8 · 2026-09-16 — Specified Google Ads conversion measurement (sign-ups and inquiries, gclid cookie, conversion value) and the 'granted' defaults of Google Consent Mode (Consent Mode v2) in the cookies and advertising tools section — notice given through this Policy instead of a consent banner; no new items collected
  • v7 · 2026-08-25 — Reflected the hashed email address and hashed member identifier that are now included in server-side transmission to Meta (Conversions API) — hashed with SHA-256 at sign-up; raw values are never transmitted
  • v6 · 2026-08-19 — Reflected the IP address already being transmitted via Meta server-side transmission (Conversions API) in the transferred items — outsourced tasks now note server-side transmission (Conversions API), and IP address was added to the overseas transfer items
  • v5 · 2026-08-05 — Removed date of birth as a collected item — the 19+ check is now a member's own confirmation consent (only the consent and its timestamp are recorded)
  • v4 · 2026-08-04 — Added date of birth as a collected item for the 19+ age check — stated as not retained after verification
  • v3 · 2026-08-03 — Reflects the introduction of advertising tools — discloses the use of Meta Pixel and Google Ads tags, adds cookies/advertising identifiers and conversion records to automatically collected items, adds Meta Platforms to processors and overseas transfers, and provides opt-out methods for targeted advertising
  • v2 · 2026-07-28 — Complete revision — reorganized the table of items collected; added outsourcing of processing, overseas transfer, provision to third parties, safety measures, and remedies for infringement of rights
  • v1 · 2026-05-18 — Initial enactment

This document is currently under legal review, and some content may be adjusted based on the review outcome.