Privacy Policy (South Korea)

Last updated:

This Privacy Policy applies only to South Korean users.

Welcome to imo!

imo takes your privacy seriously. We are committed to promoting transparency by disclosing our privacy practices. This Privacy Policy explains how we collect, use, maintain, protect, disclose, and otherwise process your information. This Privacy Policy applies to you and the information you may provide to us, or that may be collected from you, when you purchase, download, install, register, access, or use the imo communication service that we provide through applications that we offer on various mobile operating systems and on Windows and Mac personal computer operating systems or via the imo.im website or imo Public Service Account Platform (collectively referred to as imo, the “App,” or the “Service”). We sometimes use capitalized terms in this Privacy Policy; if they’re not defined here, they’re defined in our Terms of Service.

PLEASE READ THIS POLICY CAREFULLY AS IT DESCRIBES OUR PRIVACY POLICIES AND PRACTICES. IF YOU DO NOT AGREE WITH OUR PRIVACY POLICIES AND PRACTICES, DO NOT DOWNLOAD, INSTALL, REGISTER WITH, OR USE THE SERVICE.

BY DOWNLOADING, INSTALLING, REGISTERING WITH, OR USING THIS SERVICE, YOU WILL BE REQUIRED TO CONFIRM THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO COMPLY WITH THIS POLICY.

THIS POLICY MAY CHANGE FROM TIME TO TIME (SEE THE “CHANGES TO OUR PRIVACY POLICY” SECTION BELOW) WITH NOTICE TO YOU. BY CONTINUING TO USE THE SERVICE AFTER YOU ARE NOTIFIED OF ANY CHANGES, YOU ACCEPT AND AGREE TO THOSE CHANGES.

Table of Contents

  1. Who We Are
  2. How This Policy Applies
  3. Information We Collect and How We Use It
  4. Cookies
  5. Information We Share with Third Parties
  6. Opting Out of Receiving Communications
  7. Rights of access, rectification, erasure, and restriction
  8. Data Retention
  9. Data Destruction
  10. Data Security
  11. International Transfer
  12. Children’s Privacy
  13. Redress and Accountability
  14. Changes to our Privacy Policy
  15. Contact Us

1. Who We Are

Thanks for using our Service! imo is brought to you by PageBites, Inc., a company based in California, USA (PageBites is referred to herein as “imo”, “us”, “our”, and “we”).

2. How This Policy Applies

When you access and use the Service, you agree, by checking the “I Agree” box, to be subject to and bound by: (i) this Privacy Policy (this “Policy”), and (ii) our Terms of Service (the “Terms”) (collectively, the “Agreement”). If you are unwilling or unable to be bound by the Agreement, you must not use the Service.

This Policy applies strictly to information collected through the Service. It does not apply to any third-party applications, services, or websites, even if you access them through the Service. This Policy does not apply to information provided to or collected by any third party. When this Policy does not apply, you should read the applicable privacy policy and related terms posted on the website, application, or other service you are using before providing any information.

3. Information We Collect and How We Use It

We must collect some of your personal information to provide, support, improve, and market the Service. Some of the ways that we may collect personal information include information that you provide us directly; information about you that we automatically collect from log data, IP addresses, and aggregated user data; cookies and similar technologies; information that you give us about your friends; and your chat histories.

Most commonly, we will use your personal data in the following circumstances:

We do not use your personal information for making any automated decisions affecting or creating profiles other than as described herein. Please note that the examples below include types of personal data we may have concerning you, and not necessarily information that we have received about you.

Personal Data Purpose of Use Retention Period
Required Data which is mandatory to provide the fundamental features of our Service.
Phone number, country, username; (Mandatory) ·To create and manage an imo account; Will be erased within 15 days upon the deletion of your account.
Device model, device identifiers, IP address, mobile device’s SIM serial number, the connection type (e.g., cellular or WiFi), mobile carrier, and the operating system of your device(Mandatory) ·To improve our Services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, and to keep our services safe and secure;
·To customize your experience, to conduct research and development to test and introduce new features and products, and to improve and monitor the effectiveness of our Service;
Will be erased within 15 days upon the deletion of your account.
Usage data such as traffic data, logs and other communication data such as time and date of your communications, content and number of messages exchanged between you and your friends, the time you spent using imo Out, missed calls and etc. ·To deliver you with the Service of imo messengers, audio/video call, and other concerned features;
·To improve and personalize our Service to you;
·To perform research and data analysis in an aggregated way;
Will be erased after 90 days unless earlier erased by you. Please note that certain public usage data will not be erased unless erased by yourself.
Optional Data which will be collected if you choose to use the additional features or is provided to us upon your option/consent.
Profile photos, your interest and preferences ·To display your account image; Will be erased within 15 days upon the deletion of your account.
User-generated contents (“UGC”), such as comments, texts, messages, pictures, images, videos, sounds, code or other data or materials that you upload or share on imo ·To enable you to share user content and interact with other users;
·To review the contents you share for the purpose of compliance with laws;
Will be erased within 15 days upon the deletion of your account.
Data we collect from device access permissions which are granted by you such as (i) photos and videos on your device with camera and video access permission; (ii) mobile phone number, cellular network information, status of ongoing calls with phone access permission; (iii) your mobile address book with address book access permission; (iv) the audio of your voice with speech recognition permission; (v) your iCloud account and files stored on your iCloud drive with iCloud access permission; (vi) you voice and the status of Siri with Siri integration permission; (vii) push notification access. You may opt-out of imo’s access and device access permissions by changing the settings on your device, which, however, will disable the associated features in our Service. ·To allow you save photos and videos on your device and access photos and videos stored on your device when you use concerned features of our Service;
·To allow us to access your telephony features so that we can provide you certain Service;
·To connect you to your friends and other users on the Service;
·To analyze your voice in order to delivering you with the Service of recognizing verbal commands and handling text dictation;
·To enable you to share files via the Service from your iCloud account;
·To deliver you with the Service of commanding Siri with your voice such as opening the application and sending messages to your imo friends;
·To allow us to send you notifications on your device which may be of your interest;
Will be erased within 15 days upon the deletion of your account.
Name, email address, phone number, and/or other contact information or other information as required when providing you customer support ·To contact you to answer requests for customer support or technical support; Will be erased within 15 days upon the deletion of your account.
Location data such as the location of your mobile device when you grant us to collect. ·To enable you to access and use certain location-based features, such as Nearby and Who’s Online;
·To improve and personalize our Service and to target advertisements and/or content that may be more relevant to you;
Will be erased within 15 days upon the deletion of your account.
a list of your live stream followers and a list of users and/or the public group chats you follow ·To deliver you with the Service of live streaming and public group chats;
·To monitor live streams and public group chats to improve the quality of the service and to enforce our Terms of Service. But we do not record or store your audio in the live streaming feature;
Will be erased within 15 days upon the deletion of your account.
Mobile advertising identifiers. You can change the mobile advertising identifiers in your mobile device or limit advertising tracking through your mobile device’s privacy settings ·To provide ads or help advertisers provide ads that may be more relevant to your interests;
·To invite you to participate in activities or surveys;
Will be erased within 15 days upon the deletion of your account.
Payment data such as your purchase history, your imo Out credit, your virtual currency status, payment method and etc.
Please note that our third party payment service providers may collect other information from you in order to provide the payment service to you.
·To facilitate your purchases through a third-party application, such as the Apple App Store or Google Play App Store; Will be erased within 15 days upon the deletion of your account.
To access your camera and collect your facial data, including designated facial expression and movement in the form of video or photo when you use AI Avatar. You may use your personalized AI Avatar in your profile photo or share it with other users. ·To generate a personalized AI Avatar for you.
·We will use the facial data solely for the purpose of generating your AI Avatar and will not further analyze your biological data.
Six months;the profile photo will be destroyed within a month after you cease to use such profile photo.

4. Cookies

We use cookies and/or other similar technologies to distinguish you from other users of the Service and the distribution platform (App Store and Play Store) and to remember your preferences. This helps us to provide you with a good experience when you use the Service and also allows us to improve the Service. If you choose to disable cookies and/or similar technologies, some areas and features of our Service may not work properly.

Purpose of using Cookie

Analytical or performance cookies allow us to recognize and count the number of visits and to see how users move around a website when they are using it. This helps to improve the way a website works. Functionality cookies are used to remember you when you return to a website. This enables the website to personalize content for you or remember your preferences. Targeting 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.

How to reject Cookies

You can block cookies by activating the setting on your browser or mobile device that allows you to refuse the setting of all or some cookies. For example, if you use IE browser, you may go to Privacy setting: “Tools” on the toolbar > “Internet Options” > “Personal Information” > “Close” However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access to some of our website.

You can read our Cookie Policy to learn more.

5. Information We Share with Third Parties

We will not share any of your personal data to any third parties except as explicitly provided in this Policy or where we have your consent or are permitted to do so by law. In particular, we may share your personal data with third parties in the following contexts. For more details of such third parties, you may refer to Section 11 of this Privacy Policy.

6. Opting Out of Receiving Communications

You have the right to opt out of certain uses and disclosures of your personal information, as discussed below.

Emails and Text Messages. We will only send you direct marketing communications by email or text if we have your consent or when permitted by law. If you decide that you do not want to receive marketing email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future marketing emails. We will process your request within a reasonable time after receipt.

In contrast, we also use email or in-app messaging to respond to customer service requests from you, to provide certain transaction-related communications regarding products or services you have requested, and to communicate certain non-promotional issues regarding imo and our Service (e.g., communications regarding updates to our Terms or this Privacy Policy). You cannot opt out of these communications without deactivating your account, and you will continue to receive these communications from us even if you opt out of receiving marketing communications from us.

Push Notifications on Mobile devices. imo may occasionally send you push notifications through our Service. You may at any time opt out from receiving these types of communications by changing the settings on your mobile device.

Do Not Track. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers and devices. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

Interest-based advertising technologies. As noted above, you may limit advertising tracking via advertising identifiers through your mobile device’s privacy settings. The online advertising industry also provides websites through which you may opt out of receiving targeted ads from our data partners and our other advertising partners that participate in the self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at http://www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, and http://www.aboutads.info/choices/.

7. Rights of access, rectification, erasure, and restriction

Absent exceptional circumstances, we offer you reasonable access to and control over your personal data at any time, at no charge. Please inform yourself of your rights by reviewing the list below. You may use the “Contact Us” details at the end of this Policy to exercise your rights and choices.

For those users in the European Union (EU) or the European Economic Area (EEA), we generally consider ourselves to be the “controller” of the “personal data” we collect and process, and we do so in compliance with the EU General Data Protection Regulation, 2016/679 (GDPR).

We try to respond to all legitimate requests regarding your personal information within one month. Occasionally, it could take us longer than a month if your request is particularly complex or if you have made a number of requests. In such cases, we will notify you and keep you updated. The timeframes described here do not apply to our response times for addressing ordinary customer service and support requests unrelated to the exercise of personal information access rights.

Although imo uses commercially reasonable efforts to provide individuals with access to their personal information and to respond to their requests, there may be circumstances in which imo needs to ask you for more information in order to identify your account, and we may ask you to demonstrate your identity. If you cannot demonstrate your identity, imo may be unable to provide access. This may occur (a) when the information contains legal privilege; (b) when complying with the request would compromise others’ privacy or other legitimate rights; (c) when the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question; or (d) where the information is commercially proprietary. If imo determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, imo will take commercially reasonable steps to verify your identity before granting access to or making any changes to your personal information.

We are not responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.

8. Data Retention

We will retain your personal data for as long as needed to fulfill the purposes for which it was collected and to provide the Service to you. As a result, data retention periods may depend upon the feature of the Service for which the data was provided.

We also will retain and use your personal data as long as necessary to comply with our business requirements and legal obligations, to resolve disputes, to protect our assets, to provide our services, and to enforce our agreements. For example, we may collect aggregated data from your chat history that is used to build language models which help us improve the Service. This data helps us to better understand our users’ interests, analyze trends, and customize the user experience.

When we no longer have a purpose for retaining your personal data, we will use commercially reasonable efforts to securely destroy your personal data in accordance with applicable law and our policies.

9. Data Destruction

Personal information, which has fulfilled the purpose for which it was collected or used, and has reached the period of time during which personal information was to be possessed, will be destroyed in an irreversible way. Personal information stored in electronic files will be automatically deleted in an irreversible way by using technical methods, and printed information will be destroyed by shredding or incinerating such information.

10. Data Security

We maintain appropriate technical and organizational measures to prevent your personal information under our control from being accidentally lost, used or accessed in an unauthorized manner, altered or disclosed during collection, storage, and processing. All information you provide to us is stored on our secure, limited-access servers behind firewalls. Access to your account, personal data, and information is restricted within our organization to those employees and trusted partners that need access to your personal information in order to correspond with you and provide the products and/or services that you requested from us. Your personal data and information is also password-protected so that only you can log in to your account. Any additional safeguards used to protect personal information will depend on the sensitivity of the personal information; the amount, distribution and format of the information; and the method of storage.

While our security measures seek to protect your personal information in our possession, no security system is perfect and we cannot guarantee that your personal information will remain absolutely secure in all circumstances or that any privacy settings or security measures used in connection with the Service cannot be circumvented. Therefore, we cannot guarantee that unauthorized third parties will not be able to circumvent those measures or other safeguards in use, or access and/or use your personal information for improper purposes.

Most communications on our Service, including any submissions through available forms, are sent through the standard HTTP protocol and completed forms may be delivered using regular e-mail. Information sent over HTTP and email is not encrypted; and, while these are convenient communication mechanisms, use of these unsecure communication methods presents privacy and security risks (e.g., e-mail is not a secure form of communication, is unreliable, can be forwarded, etc.). Any transmission of information that you make to us or through our Service is at your own risk.

The safety and security of your personal information also depends on you. Where you use a password for access to restricted parts of the Service, you are responsible for keeping the password confidential. Do not share your password with anyone else. Restricted areas of the Service include social networking, chat room, or forum features. Please ensure that, when using these features, you do not submit any personal data that you do not want to be seen, collected or used by other users.

If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice within the Service. If a security breach causes an unauthorized intrusion into our Service or systems that compromises your data, we will notify you and any applicable regulator when we are required to do so by applicable law.

11. International Transfer

Our company headquarters are located in California, United States. We store and process your personal data and information on servers in the United States, Asia, and other countries outside of the EU, EEA or your home country. Be aware that your personal data and information is transferred to, stored in, and processed in these third countries which may not have the same adequate level of data protection as in your home country. However, all transfers of personal data will be performed in accordance with the requirements of applicable law. For example, we apply appropriate safeguards such as EU Standard Contractual Clauses for EU/EEA users’ personal information.

You may contact us at privacy@imo.im if you do not agree to the transfer of personal data outside of the EU/EEA or your home country. However, if you refuse such transfer, you may not be able to access to part of our Service to the extent such transfer is a must.

While the data protection, privacy, and other laws of the United States and other jurisdictions might not be as comprehensive as those in your country, we take steps to protect the security and privacy of your personal information as set forth above.

Specifically, we might transfer your personal data to third parties overseas as follows:

Recipient (Contact Information of Information Manager) Country to which Your Personal Data is to be Transferred Date and Method of Transfer Types of Your Personal Information to be Transferred Purposes of Use by Recipients Period of Retention Use by Recipient
Google Payment Korea Limited PHONE NO. 080-085-1500 U.S. Online and encrypted upon SDK integration Payment related information such as purchase record, payment amount Google Play Payment Process Will be held for so long as an account exists.
Google Inc. https://policies.google.com/privacy U.S. Online and encrypted upon SDK integration Wireless and mobile network connections Statistical Collection and Analysis Will be held for so long as an account exists.
AppsFlyer Limited, privacy@appsflyer Ireland Online and encrypted upon SDK integration Wireless and mobile network connections
Device unique identifier
Statistical Collection and Analysis Will be held for so long as an account exists.
Pagebites. Inc, privacy@imo.im Singapore Online and encrypted upon account creation All personal data System operation and maintenance In accordance with the Retention Period of Section 3 in this Privacy Policy
BYTEDANCE PTE. LTD., global_privacy@bytedance.com Singapore Online and encrypted upon SDK integration GAID, country, IP address Advertisement Will be held for so long as an account exists.
Click Tech Solution Limited, support@clicktech.com U.S. Online and encrypted upon SDK integration GAID, country, IP address Advertisement Will be held for so long as an account exists.
ALGORIX TECHNOLOGY PTE.LTD., dpo@algorix.co Singpore Online and encrypted upon SDK integration GAID, country, IP address Advertisement Will be held for so long as an account exists.

12. Children’s Privacy

The Service is not directed to children under 14 years of age if you are in Korea, and if you are in the EU/EEA regions, 16 years of age (or the relevant age in your country where you are considered a minor), and imo does not knowingly collect personal data from children. If you learn that your child has provided us with personal information without your consent, you may delete your child’s entire account, by selecting the “Delete imo account” option in your child’s imo app settings or alert us at privacy@imo.im. If we learn that we have collected any personal information from a child, we will promptly take steps to delete such information and terminate the child’s account. This section supersedes any age limitations that may be listed in connection with the ratings listed in an application store.

13. Redress and Accountability

If you have any questions about our privacy practices or this Privacy Policy, please contact us by email at privacy@imo.im or via the methods listed below. We will address your concerns and attempt to resolve any privacy issues in a timely manner.

14. Changes to our Privacy Policy

We reserve the right, in our sole discretion, to update, change, modify, add or remove portions of this Policy from time to time. If we make material changes to how we treat our users’ personal information, we will post the new Policy on this page and provide notice that an update has occurred by either (a) sending notice to you at the email address specified in your account, or (b) using an in-app alert on the first time that you use the mobile application after we make the change You are responsible for providing us with an active, up-to-date, and deliverable email address for contacting you. It also is your responsibility to carefully review this Policy prior to using the Service and from time to time so you are aware of any changes. The date this Policy was last revised is identified at the top of this Policy. Continuing to use our Service constitutes your consent to this Policy and any changes thereof. If you do not agree to any changes of this Policy, please stop using our Service.

15. Contact Us

If you have questions or comments about this Policy, wish to access personal information we hold about you, believe the personal information we have about you is incorrect, or wish to lodge a complaint with us about how we have handled your personal information, please use the contact details below and we will do our best to assist you:

Privacy Protection Officer
Name: Ivan Wu
Address: 3000 El Camino Real, Suite 5-300 Palo Alto, California 94306
Email: privacy@imo.im

Revision History
Privacy Policy Version June, 2023 and the Comparision
Privacy Policy Version December,2022 and the Comparision
Privacy Policy Version January,2022 and the Comparision