Privacy Policy

1. Purpose of Collection and Use of Personal Information

The Company(FirstFluke) processes personal information for the following purposes and does not use it beyond those purposes:

• Membership registration intent verification, user identification, and account management
• Provision of fortune consultation services and contract performance
• Paid payment, settlement, and refund processing
• Handling customer inquiries, complaints, and service quality improvement

2. Items of Personal Information Collected

• Required items: Nickname (or name), email (for login identification and account management)
• Optional items: Date of birth, gender, solar/lunar calendar preference
• Automatically collected items: Cookies (where necessary), service usage records
• Items not collected: Phone number, password, IP address, device information

3. Retention and Use Period of Personal Information

In principle, the Company destroys personal information without delay when membership is withdrawn or the processing purpose is achieved. However, where retention is required by applicable laws, the information is safely stored separately for the required period.

• Records on contracts or withdrawal of subscription: 5 years
• Records on payment and supply of goods/services: 5 years
• Records on consumer complaints or dispute handling: 3 years
• Records on labeling/advertising: 6 months
• Destruction procedure: Destroyed without delay after retention period expires or purpose is achieved
• Destruction method: Electronic files are deleted in a non-recoverable manner, paper documents are shredded or incinerated

4. Provision of Personal Information to Third Parties

In principle, the Company does not provide users' personal information to third parties. Exceptions apply in the following cases:

• Where users have given prior separate consent
• Where required by law or upon lawful request by investigative authorities under due process

5. Outsourcing of Personal Information Processing

The Company may outsource part of its operations as necessary for smooth service provision and supervises trustees through contracts to ensure compliance with personal information laws, security measures, and restrictions on re-outsourcing.

• Outsourced task: Payment processing
• Trustee: Payment gateway provider (PG)

6. Overseas Transfer of Personal Information

As a principle, there is currently no direct overseas transfer of personal information subject to disclosure. If overseas transfer occurs in the future, the Company will disclose and comply with required legal items in advance (legal basis, transferred items, destination country, timing and method of transfer, etc.) under PIPA and its Enforcement Decree.

7. Users' and Legal Representatives' Rights and How to Exercise Them

Under Articles 35 to 37 of PIPA, users may at any time request access, correction/deletion, suspension of processing, and withdrawal of consent regarding their personal information.

• Method of exercising rights: Via customer support or email (our.first.fluke@gmail.com)
• For minors, rights may be exercised by legal representatives

8. Installation/Operation of Automatic Collection Devices and Refusal

The Company may use cookies to provide personalized services and analyze usage patterns. Users may refuse cookie storage through browser settings, but some services may be restricted as a result.

9. Security Measures for Personal Information

• Encryption of personal information and protection of transmission sections
• Technical safeguards against hacking and malware
• Minimization of access rights and staff training for handlers
• Administrative safeguards including log retention and inspection

10. Chief Privacy Officer and Grievance Handling

The Company operates a department responsible for overall personal information processing and grievance handling.

• Responsible department: Customer Support Team
• Contact: our.first.fluke@gmail.com

11. Changes to This Privacy Policy

This Policy may be amended due to changes in laws, policies, or security technologies. Changes will be announced through in-service notices at least 7 days before the effective date. Material changes affecting users' rights will be announced at least 30 days in advance.