- Article 1. General Provisions
- Article 2. Information Collected
- Article 3. Purpose of Collection and Use
- Article 4. Retention and Use Period
- Article 5. Provision to Third Parties
- Article 6. Outsourcing of Processing
- Article 7. Destruction Procedures and Methods
- Article 8. Rights of Data Subjects
- Article 9. Cookies
- Article 10. Security Measures
- Article 11. Privacy Officer
- Article 12. Duty of Notification
General Provisions
KustodyFi Co., Ltd. (hereinafter the “Company”) establishes and discloses this Privacy Policy as follows, pursuant to Article 30 of the Personal Information Protection Act of the Republic of Korea, in order to protect the personal information of data subjects and to handle related grievances promptly and smoothly.
Scope: This Policy applies to the services provided by the Company (including but not limited to SNAP the Market, MOVE the Money, SEAL the Trust, and ReverseFX), the website, inquiry and consultation requests, and all services incidental thereto.
Personal Information Collected
The Company collects the following personal information in order to provide its services.
| Category | Required | Optional |
|---|---|---|
| Website inquiry form | Full name, email address, inquiry type | Company name, message |
| Waitlist registration | Email address | None |
| Service use (SNAP and others) | Email address | Name, company name, job title |
Automatically collected information:
- IP address, cookies, date and time of visit, service usage records
- Device information (operating system, browser, screen resolution)
- Access logs
- Time of inquiry submission, and the language of the page it was submitted from (Korean or English)
Purpose of Collection and Use
Personal information collected is used solely for the purposes set out below. Separate consent is obtained for any use beyond these purposes.
| Purpose | Details |
|---|---|
| Member management | Identity verification for use of membership services, confirmation of intent to register, prevention of fraudulent use by delinquent members, notices and communications, and grievance handling |
| Service provision | Provision of the SNAP pricing service, receipt of inquiries, and responses thereto |
| Marketing and service improvement | Development of new services, provision of event and promotional information (subject to separate consent), analysis of access frequency, and usage statistics |
Retention and Use Period
The Company processes and retains personal information within the retention period prescribed by statute or the period consented to by the user.
- General rule: Destroyed without delay upon withdrawal of membership
- Inquiry information: One (1) year from the date of submission (destroyed without delay once the purpose is achieved)
Retention required under relevant statutes:
| Records retained | Retention period | Governing statute |
|---|---|---|
| Records on contracts or withdrawal of subscription | 5 years | Act on Consumer Protection in Electronic Commerce, etc. |
| Records on payment and supply of goods and services | 5 years | Act on Consumer Protection in Electronic Commerce, etc. |
| Records on consumer complaints or dispute resolution | 3 years | Act on Consumer Protection in Electronic Commerce, etc. |
| Website visit records | 3 months | Protection of Communications Secrets Act |
Provision of Personal Information to Third Parties
As a general rule, the Company does not provide users’ personal information to external parties. The following are exceptions:
- Where the user has given prior consent;
- Where required under the provisions of a statute, or where an investigative agency so requests for investigative purposes in accordance with the procedures and methods prescribed by statute;
- Where the user or their legal representative is unable to express intent, or prior consent cannot be obtained because the address is unknown or for similar reasons, and the provision is clearly deemed necessary for the urgent life, bodily, or property interests of the data subject or a third party.
Outsourcing of Personal Information Processing
The Company does not currently outsource any personal information processing tasks to external parties.
Destruction Procedures and Methods
When personal information becomes unnecessary — because the retention period has elapsed, the processing purpose has been achieved, or for similar reasons — the Company destroys it without delay.
- Electronic files: Permanently deleted by a method that renders recovery impossible
- Paper documents: Shredded or incinerated
Rights and Obligations of Data Subjects and How to Exercise Them
As data subjects, users may exercise the following rights.
- The right to request access to their personal information
- The right to request correction where there are errors
- The right to request deletion
- The right to request suspension of processing
These rights may be exercised in writing, by email, or through customer support, and the Company will act on such requests without delay.
Installation and Operation of Automatic Collection Devices (Cookies) and Refusal Thereof
Purposes for which cookies are used:
- Analysis of access frequency and visit duration
- Understanding users’ areas of interest
- Service improvement and provision of tailored information
How to refuse cookies: You may refuse the storage of cookies through your web browser settings.
| Browser | Settings path |
|---|---|
| Chrome | Settings → Privacy and security → Cookies and other site data |
| Safari | Settings → Privacy |
| Edge | Settings → Cookies and site permissions |
Measures to Ensure the Security of Personal Information
The Company takes the following measures to ensure the security of personal information.
Administrative measures
- Establishment and implementation of an internal management plan
- Minimization of the number of employees who handle personal information, and regular training
- Designation of a Privacy Officer
Technical measures
- Management of access privileges to personal information
- Operation of an access control system
- Encryption of unique identifying information and similar data
- Installation and periodic updating of security software
Physical measures
- Access control for the server room and document storage areas
Privacy Officer
The Company has designated the following Privacy Officer, who assumes overall responsibility for personal information processing and handles data subjects’ complaints and remedies in relation to such processing.
For complaints, remedies, or infringements of rights relating to the processing of personal information, you may contact the following authorities. All are Korean government bodies, and inquiries are handled in Korean.
| Authority | Contact | Website |
|---|---|---|
| Privacy Infringement Report Center, Korea Internet & Security Agency, KISA (개인정보침해신고센터) | 118 (no area code) | privacy.kisa.or.kr |
| Personal Information Dispute Mediation Committee (개인정보 분쟁조정위원회) | 1833-6972 | kopico.go.kr |
| Cybercrime Investigation Division, Supreme Prosecutors’ Office (대검찰청 사이버수사과) | 1301 (no area code) | spo.go.kr |
| Cyber Investigation Bureau, Korean National Police Agency (경찰청 사이버수사국) | 182 (no area code) | ecrm.cyber.go.kr |
Duty of Notification
This Privacy Policy takes effect on August 26, 2026.
Where content is added to, deleted from, or amended in this Privacy Policy, notice will be given on this Privacy Policy page, stating the changes and the effective date, beginning seven (7) days before that effective date.
Summary of changes
- Service names updated to the current product names (SNAP · MOVE · SEAL · ReverseFX), and the scope clarified
- Article 2 corrected to match the actual inquiry form: the discontinued “monthly transaction volume” field was removed, and the inquiry type, message, and submission language now collected were added
- Article 12 notification method changed from “the website notice board” to “this page”