Runcop Company Co., Ltd. (런콥컴퍼니 주식회사; hereinafter the "Company") establishes and discloses this Privacy Policy as follows, pursuant to Article 30 of the Personal Information Protection Act (개인정보 보호법), in order to protect the personal information of data subjects and to handle grievances related thereto promptly and smoothly.
Article 1 (Items of Personal Information Processed)
① The Company processes the following personal information in order to provide the Service.
| Category | Items Collected | Method of Collection |
|---|---|---|
| Membership registration (required) | Unique identifier, email address, name or nickname, and profile photo received from the social login provider (the items for each provider are set out below) | Received from the authentication providers Apple, Google, and Kakao |
| Age verification (required) | Date of birth | Entered directly by the user at the time of sign-up |
| Profile (optional) | Gender, height, weight, running experience, goals, weekly distance, profile photo | Entered directly by the user |
| Running records — stored on the device | Location coordinates of the route traveled (latitude, longitude, altitude, time of measurement) | The App's measurement function. Not transmitted to the Company's servers |
| Running records — stored on the server | Distance traveled, time taken, pace per segment, elevation change, cadence, ground contact time, vertical oscillation, heart rate summary values, calories burned, whether goals were achieved | The App's measurement function and direct entry by the user |
| Derived training metrics | Readiness score, acute-to-chronic training load ratio (most recent 7 days vs. 28 days), weekly distance trend, training monotony, average vertical oscillation, heart rate zone distribution, pace zone distribution, weekly goal, plan for the day | Calculated by the server from running records |
| AI coaching conversations | Original text of questions entered by the member, answers generated and presented by the Company, and the entire prior content of the same conversation | Entered and generated while the member uses the AI coaching feature |
| Coach guidance records (optional) | Original text of training notes written by the member, pain score (0 to 10), rating of perceived exertion (RPE), movement tags, feedback from the assigned coach | Entered directly by the member and the assigned coach |
| Health information (optional) | Exercise-related biometric indicators such as heart rate, resting heart rate, heart rate variability, sleep duration, and maximal oxygen uptake (VO2 max) | The App's measurement function; integration with Apple Health and Google Health Connect |
| Form analysis (optional) | Videos recording running form, skeletal measurements such as joint angles extracted from the videos, form scores, history of recommended corrective exercises, comments from the assigned coach | Recorded or uploaded by the user in the App |
| In-store form analysis (non-members) | Name and contact details entered when booking, form videos recorded at the store, skeletal measurements such as joint angles extracted from the videos, form report | Recorded on the measurement screen (web) at a partner store |
| Class and race participation | Name, mobile phone number, date of birth, gender, emergency contact, souvenir size, bib number, course entered※ Resident registration numbers are not collected | Entered directly by the user |
| RunTrip applications | Name, name in English, mobile phone number, email address, date of birth, gender, and, for overseas products, passport number and passport expiration date※ Passport information is destroyed without delay after it has been delivered to the seller | Entered directly by the user |
| Payment | Transaction number, product name, type of payment method, payment amount, date and time of payment, payment status※ Card numbers and account numbers are processed by the payment gateway, and the Company does not retain them | Generated automatically during the payment process |
| Subscription | Type of subscription product, date and time of application, billing cycle, whether auto-renewal is enabled, renewal date, date and time of cancellation | Generated in the course of applying for and managing a subscription |
| Corporate training (B2B) | Names, departments, contact details, and email addresses of participating employees | Received from the person in charge at the company that requested the training |
| Posts | Text, photos, videos, and comments posted by the user | Entered directly by the user |
| Customer support | Details of the inquiry, date and time of the inquiry, contact details | Collected in the course of customer support |
| Automatically generated information | Date and time of access, IP address of access, service usage records, device model, operating system version, app version, push notification token | Generated automatically in the course of using the Service |
② The Company does not restrict the use of the essential functions of the Service even if a user does not consent to the provision of optional items during membership registration or while using the Service.
③ The items the Company receives from each social login provider are as follows.
| Provider | Items Received |
|---|---|
| Apple | Unique identifier, email address, name |
| Unique identifier, email address, name, profile photo | |
| Kakao | Unique identifier, email address, nickname, profile photo |
④ The Company does not accept independent membership registration by children under the age of 14, and processes the personal information of children only through registration as a companion participant by an adult member who is the child's legal representative. Specific matters are governed by Article 4.
⑤ The Company does not collect advertising identifiers, does not provide personalized advertising, and does not request App Tracking Transparency consent.
⑥ The Company uses the same account for the Runcop Company website and the Zero2Run application, and applies this Privacy Policy equally regardless of the channel through which personal information was collected.
Article 2 (Purposes of Processing Personal Information)
The Company processes personal information for the following purposes. The personal information processed will not be used for any purpose other than the following, and if the purpose of use changes, the Company will take the necessary measures, such as obtaining separate consent pursuant to Article 18 of the Personal Information Protection Act (개인정보 보호법).
| Purpose of Processing | Details |
|---|---|
| Member management | Provision of membership-based services, identification and authentication of the individual, maintenance and management of membership status, prevention of fraudulent use, delivery of various notices and notifications, handling of grievances |
| Provision of running records | Measurement and storage of running records, viewing of records and provision of statistics, display of goal achievement status |
| Provision of coaching features | Calculation of training plans and target times, provision of information on exercise intensity |
| Provision of in-store form analysis services | Recording and analysis of running form at partner stores, generation and delivery of reports |
| Operation of classes, races, and run tours | Receipt of bookings and participation applications, capacity management, attendance checks, timing of results, distribution of souvenirs, safety management and response to emergencies |
| Provision of goods and services | Provision of paid services, payment and settlement of charges, delivery of products, handling of withdrawals of offers and refunds |
| Community operation | Posting and management of posts, provision of features for interaction among users |
| Service improvement | Analysis of service usage statistics, identification of access frequency, development of new features, improvement of the accuracy of the coaching features |
| Marketing and advertising (optional) | Information on new services and events, sending of event and advertising information |
| Fulfillment of legal obligations | Retention of records and response to disputes in accordance with relevant laws, such as the Act on the Consumer Protection in Electronic Commerce, etc. (전자상거래 등에서의 소비자보호에 관한 법률) |
Article 3 (Period of Processing and Retention of Personal Information)
① The Company processes and retains personal information within the retention and use period consented to by the data subject at the time of collection or the retention and use period prescribed by law.
② The retention period for each purpose of processing is as follows.
| Category | Retention Period |
|---|---|
| Member information | Until membership withdrawal. However, the minimum information necessary to prevent fraudulent use is retained for 6 months after membership withdrawal |
| Running records and health information | Until membership withdrawal. If the member deletes an individual record, it is destroyed immediately |
| AI coaching conversation content | Until membership withdrawal. If the member deletes a conversation, it is destroyed immediately |
| Coach guidance records (notes, pain scores, ratings of perceived exertion, coach feedback) | 1 year from the date on which the coach connection ends. If the member requests deletion, they are destroyed immediately |
| Original form analysis videos and skeletal measurements | 1 year from the date of recording. If the member requests deletion, they are destroyed immediately |
| In-store form analysis (non-members) | Automatically deleted 30 days after the date on which the report is provided. If the user requests deletion, it is destroyed immediately |
| Class and race participation information | 1 year after the end of the relevant program. However, if there is potential for a dispute, such as where an accident has occurred, until the dispute is concluded |
| RunTrip application information | 1 year from the end date of the trip. Passport information is destroyed without delay after it has been delivered to the seller |
| Posts | Until the member deletes them or until membership withdrawal |
| Customer support records | 3 years after the inquiry is closed |
| Access logs | 3 months pursuant to the Protection of Communications Secrets Act (통신비밀보호법) |
③ In accordance with relevant laws, the following information is retained for the periods indicated.
| Information Retained | Retention Period | Legal Basis |
|---|---|---|
| Records on contracts or withdrawal of offers, etc. | 5 years | Act on the Consumer Protection in Electronic Commerce, etc. (전자상거래 등에서의 소비자보호에 관한 법률) |
| Records on payment and supply of goods, etc. | 5 years | Act on the Consumer Protection in Electronic Commerce, etc. (전자상거래 등에서의 소비자보호에 관한 법률) |
| Records on consumer complaints or dispute resolution | 3 years | Act on the Consumer Protection in Electronic Commerce, etc. (전자상거래 등에서의 소비자보호에 관한 법률) |
| Records on labeling and advertising | 6 months | Act on the Consumer Protection in Electronic Commerce, etc. (전자상거래 등에서의 소비자보호에 관한 법률) |
| Records on electronic financial transactions | 5 years | Electronic Financial Transactions Act (전자금융거래법) |
Article 4 (Processing of Personal Information of Children Under the Age of 14)
① The Company does not accept independent membership registration by children under the age of 14 and does not create accounts in the name of a child. A child under the age of 14 may participate in offline classes and races only by being registered as a companion participant in the account of an adult member who is the child's legal representative.
② The personal information of children that the Company processes under paragraph (1) is limited to the following items necessary for the operation of classes and races.
| Category | Details |
|---|---|
| Items processed | The child's name, date of birth, and gender, and, for race participation, the bib number and course entered |
| Purposes of processing | Registration for classes and races, on-site operation, safety management, timing of results |
| Retention period | 1 year after the end of the relevant program. However, if there is potential for a dispute, such as where an accident has occurred, until the dispute is concluded |
| Method of consent | The adult member who is the legal representative, while logged in after completing mobile phone identity verification, gives consent to the proxy consent item on the companion participant registration screen. The Company keeps a record of the legal representative's name, contact details, and the date and time of consent |
| Rights of the legal representative | The legal representative may at any time request access to, correction, deletion, or suspension of processing of the child's personal information, and may withdraw consent |
③ The Company also provides information on the processing of children's personal information in a format that is easy for children to understand and in clear and plain language.
④ The Company does not carry out the following processing with respect to children.
1. Recording and storage of form analysis videos of children
2. Collection of children's personal location information
3. Creation of community posts by children and disclosure of children's running records
4. Marketing, advertising, and personalized advertising using children's personal information
5. Training of artificial intelligence models using children's personal information
⑤ The Company does not require children to provide information beyond the minimum necessary to provide the Service to them, and does not restrict their participation on the ground that they do not provide such information.
Article 5 (Processing of Sensitive Information)
① In order to provide the coaching features and running records, the Company processes the following information, which may constitute sensitive information under Article 23 of the Personal Information Protection Act (개인정보 보호법).
| Items Processed | Purposes of Processing | Retention Period |
|---|---|---|
| Exercise-related biometric indicators such as heart rate, maximal oxygen uptake, resting heart rate, heart rate variability, and sleep duration | Display of running records, provision of information on exercise intensity, calculation of statistics, guidance by the assigned coach | Until membership withdrawal or until the member deletes the relevant records |
| Videos recorded for form analysis (side and rear views), joint angles and skeletal measurements extracted from them, and form scores | Analysis of running form, recommendation of corrective exercises, guidance by the assigned coach | 1 year from the date of recording. If the member requests deletion, they are destroyed immediately |
| Form analysis videos recorded by non-member users at partner stores, skeletal measurements such as joint angles extracted from them, and form reports | Provision of in-store form analysis services, generation and delivery of reports | 30 days from the date on which the report is provided. If the user requests deletion, they are destroyed immediately |
| Pain scores (0 to 10) and ratings of perceived exertion (RPE) entered by the member, and content regarding physical condition that the member has personally written in training notes | Guidance by the assigned coach, generation of draft coach feedback | 1 year from the date on which the coach connection ends. If the member requests deletion, they are destroyed immediately |
| Content regarding physical condition that the member has personally written in questions in the AI coaching feature | Generation of answers to questions | Until membership withdrawal. If the member deletes a conversation, it is destroyed immediately |
② In order to process the information in paragraph (1), the Company obtains the data subject's consent separately from consent to the processing of other personal information. The data subject may refuse this consent, and even if the data subject refuses, there will be no restriction on the measurement of running records or the use of other services. However, certain statistical features based on such information will not be available.
③ The Company does not use the information in paragraph (1) for advertising or marketing purposes and does not provide it to third parties.
④ Of the information in paragraph (1), pain scores, ratings of perceived exertion, and training notes are transferred overseas to generate draft coach feedback, and the original text of questions entered by the member in the AI coaching feature is transferred overseas to generate answers. The recipients and the items transferred are as set out in Article 11, and the Company obtains separate consent for such transfer in accordance with Article 11.
⑤ Questions and notes entered by the member are transmitted in their original text. Accordingly, the Company displays on the relevant input screens a message advising members not to enter personal information that is not strictly necessary, such as names, contact details, or names of diseases.
Article 6 (Integration with External Health Platforms)
① If the user permits integration with Apple Health or Google Health Connect, the Company receives exercise-related indicators, such as resting heart rate, heart rate variability, sleep duration, and maximal oxygen uptake, from the relevant platform and uses them for the following purposes. Integration takes place only if the user turns it on in Settings, and it is off by default.
1. Display of running records and calculation of statistics for the member
2. Calculation of reference information on exercise intensity and recovery
3. Viewing and guidance by the assigned coach, if the member has applied for a coach connection
4. Use of summary metrics to generate answers to the member's questions in the AI coaching feature
② The user may disable the integration in paragraph (1) at any time in the permission settings of each platform, and disabling it will not restrict the use of other services.
③ The Company does not use the data received under paragraph (1) for the following purposes.
1. Advertising or marketing
2. Data mining through analysis of usage behavior
3. Training of artificial intelligence models
4. Provision or sale to third parties
④ The data received under paragraph (1) is stored on the Company's servers, and if the member has applied for a coach connection, the assigned coach may view it. In addition, derived metrics calculated from this data, such as heart rate zone distribution and average vertical oscillation, are transferred overseas in accordance with Article 11 in order to generate answers in the AI coaching feature. The original values themselves are not transferred.
⑤ If the user disables the integration, the Company destroys without delay the data that it has received from the relevant platform and retained.
⑥ The Company has not entered into any application programming interface (API) usage agreement with wearable device manufacturers. Data measured by devices of manufacturers such as Garmin is received through the route described in paragraph (1) only if the device has recorded the data in Apple Health or Google Health Connect, and there is no route through which data is received directly from manufacturers.
⑦ Because the data received under paragraph (1) constitutes sensitive information under Article 23 of the Personal Information Protection Act (개인정보 보호법), it is processed with separate consent under Article 5 and is not used for advertising or marketing purposes.
Article 7 (Processing of Personal Location Information)
① The Company processes users' personal location information in order to measure running records and display the measured routes. Specific matters regarding the processing of personal location information are governed by the Location-Based Services Terms.
② The user may stop providing location information at any time in the device settings. If the user stops providing location information, the automatic measurement of running records will not be available, but other services, including manual entry of records, will remain available.
③ The coordinates of the route traveled are stored only on the user's device and are not transmitted to the Company's servers. The Company's servers store summary values that do not include coordinates, namely distance traveled, time taken, pace per segment, elevation change, cadence, ground contact time, vertical oscillation, heart rate summary values, and calories burned. The Company does not provide any feature that discloses the route traveled to other users in the form of a map.
④ Where the Company has used or provided personal location information, it automatically records and retains data that can verify the fact of such use and provision, pursuant to Article 16(2) of the Act on the Protection, Use, etc. of Location Information (위치정보의 보호 및 이용 등에 관한 법률).
Article 8 (Use of Personal Information to Improve the Coaching Features)
① In order to improve the accuracy of the coaching features, the Company may analyze users' running records and service usage records and use them for machine learning.
② Separate consent is obtained for the use under paragraph (1), and even if the user does not consent, there will be no restriction on the use of the Service, including the coaching features.
③ The scope of the information used under paragraph (1) is as follows.
| Items Used | Purpose of Use | Remarks |
|---|---|---|
| Distance traveled, time taken, speed per segment, elevation, cadence | Improving the accuracy of calculating training plans and target times | — |
| Class participation history, goal-setting and achievement history | Presenting training plans suited to the user's circumstances | — |
| Skeletal measurements extracted from form analysis videos, form scores | Improving the accuracy of form evaluation criteria and corrective exercise recommendations | Only where separate consent has been obtained |
| Biometric indicators such as heart rate, and data integrated from Apple Health and Google Health Connect (including data measured by wearable devices) | Not used | Article 6(3) |
| Original form analysis videos | Not used | Only skeletal measurements are used |
| Directly identifying information such as name, contact details, and email address | Not used | — |
| Location coordinates of the route traveled | Not used | — |
| Community posts | Not used | — |
| Information on children registered as companion participants | Not used | Article 4(4) |
④ The user may withdraw the consent under paragraph (1) at any time in the Service settings. If the user withdraws consent, the Company will not use that user's information for machine learning from that point onward.
⑤ When the Company uses information for the analysis and machine learning under paragraph (1), it shall, as a rule, use the information after processing it so that individuals cannot be identified.
⑥ The Company uses external artificial intelligence services to provide the coaching features, and their providers and locations are as set out in Articles 10 and 11.
Article 9 (Provision of Personal Information to Third Parties)
① The Company processes the personal information of data subjects only within the scope specified in Article 2, and provides it to third parties only where it has obtained the data subject's consent or where Article 17 or Article 18 of the Personal Information Protection Act (개인정보 보호법) applies.
② The Company provides personal information to third parties as follows.
| Recipient | Purpose of Provision | Items Provided | Retention and Use Period |
|---|---|---|---|
| Local governments hosting races and organizing bodies | Management of race participant lists and safety management | Name, date of birth, gender, contact details, emergency contact | 1 year after the end of the race |
| Race timing service providers (selected for each race and announced in the race guidelines) | Timing of race results and calculation of results | Name, bib number, gender, date of birth, course entered | 6 months after the end of the race |
| Korea Sports Safety Foundation (스포츠안전재단) | Enrollment of participants in personal accident insurance and liability insurance, and filing of insurance claims | Name, date of birth, contact details (resident registration numbers are not collected) | 3 years after the end of the insurance period |
| Naeiltour Co., Ltd. (주식회사 내일투어) | Conclusion and performance of travel contracts for RunTrip products (booking of flights, accommodation, and participation in local races; enrollment in travel insurance; itinerary information and consultation) | Name, name in English, date of birth, gender, mobile phone number, email address, and, for overseas products, passport number and passport expiration date (separate consent for passport information) | Until performance of the travel contract is completed. However, where retention is required under relevant laws, for the period so required |
③ The Company obtains the data subject's consent for the provision under paragraph (2), and the data subject may refuse to give it. However, if the data subject does not consent to the provision, the data subject may not participate in the relevant race or RunTrip product. Because a passport number is unique identification information under Article 24 of the Personal Information Protection Act (개인정보 보호법), consent for it is obtained separately from other personal information.
Article 10 (Outsourcing of Personal Information Processing)
① For the smooth performance of its business, the Company outsources personal information processing tasks as follows.
| Outsourcee | Details of Outsourced Tasks |
|---|---|
| Snovium Co., Ltd. (주식회사 스노비움) | Development and maintenance of the mobile application |
| HyperRabbit (하이퍼래빗) | Development and maintenance of the web services and the operations management system |
| Toss Payments Co., Ltd. (토스페이먼츠 주식회사) | Payment processing on the Company's behalf and authentication of payment information |
| Amazon Web Services Korea LLC | Provision of cloud infrastructure (Seoul Region) |
| Supabase Inc. | Hosting and operation of databases and server functions (AWS Seoul Region) |
| Vercel Inc. | Hosting of web services and execution of server functions |
| Google LLC | Sending of app notifications, collection of crash records, analysis of usage statistics, display of maps |
| Plus Five Five, Inc. (Resend) | Sending of emails (notices of a subscription's conversion to paid service and auto-renewal, notifications of receipt of B2B class inquiries and race bank transfer applications, verification codes for looking up race applications, etc.) (for overseas transfer, see Article 11) |
| Anthropic PBC, Voyage AI Innovations Inc., OpenRouter, Inc. | Generation of AI coaching answers and draft coach feedback, search of coaching materials (for overseas transfer, see Article 11) |
② When entering into an outsourcing contract, the Company specifies in a contract or other document, pursuant to Article 26 of the Personal Information Protection Act (개인정보 보호법), matters concerning the prohibition of processing personal information for purposes other than the performance of the outsourced tasks, technical and administrative safeguards, restrictions on re-outsourcing, management and supervision of the outsourcee, and responsibilities such as compensation for damages, and supervises whether the outsourcee processes personal information safely.
③ If the details of the outsourced tasks or the outsourcee change, the Company will disclose the change through this Privacy Policy.
④ The business operator that bills and settles the Company's cloud usage fees on its behalf does not process personal information and is therefore not included among the outsourcees in paragraph (1). The hosting service provider indicated pursuant to Article 10(1) of the Act on the Consumer Protection in Electronic Commerce, etc. (전자상거래 등에서의 소비자보호에 관한 법률) is Amazon Web Services Korea LLC.
Article 11 (Overseas Transfer of Personal Information)
① The Company's databases and file storage are located in Korea (Seoul Region), and the Company stores members' personal information in Korea. However, in order to provide certain features of the Service, the Company transfers personal information overseas as follows, and the transferred information is stored overseas by the recipient for the retention periods set out in the table below.
| Recipient | Destination Country | Items Transferred | Date, Time, and Method of Transfer | Purpose of Use | Retention Period |
|---|---|---|---|---|---|
| Anthropic PBC | United States | Original text of questions entered by the member, the entire prior content of the same conversation, derived metrics calculated from running records (readiness score, acute-to-chronic training load ratio, weekly distance trend, training monotony, average vertical oscillation, heart rate zone distribution, pace zone distribution, weekly goal, plan for the day), excerpts from retrieved coaching materials | Transmitted over the network at the time the member uses the AI coaching feature | Generation of coaching answers | For the period necessary to generate the answer after transmission |
| Voyage AI Innovations Inc. | United States | Original text of questions entered by the member, body text of coaching materials | Transmitted over the network at the time the member uses the AI coaching feature and at the time coaching materials are indexed | Search for coaching materials relevant to the question | For the period necessary for the search after transmission |
| OpenRouter, Inc. and the artificial intelligence model providers to which it relays requests | United States | Original text of training notes written by the member, pain score (0 to 10), rating of perceived exertion (RPE), movement tags, length of the form analysis video, the 2 most recent pieces of feedback sent by the assigned coach※ The form analysis video itself is not transferred | Transmitted over the network at the time the assigned coach requests the generation of draft feedback | Generation of draft coach feedback | For the period necessary to generate the draft after transmission |
| Google LLC | United States | Device identifiers for sending app notifications; the title and body of notifications and identifiers attached to notifications (including, for subscription notice notifications, the date of conversion to paid service or the scheduled auto-renewal payment date and the scheduled payment amount, and, for notifications sent to the assigned coach, the member's name or display name); crash records; non-identifying device values relating to usage statistics; and request values, such as the geographic area, transmitted to the map provider in order to display maps | Transmitted over the network at the time the relevant event occurs and at the time a map is displayed | Sending of app notifications, analysis of errors, analysis of usage statistics, display of maps | For the period set out in the policy of each service |
| Plus Five Five, Inc. (Resend)Contact: privacy@resend.com | United States, Japan | Subscription notices: recipient email address, notice content (product name and product identifier, end date of the free trial or discount and the date of conversion to paid service or the scheduled auto-renewal payment date, scheduled payment amount, type of payment method (App Store or Google Play), whether consent to conversion to paid service was given and the outcome of its processing, information on how to cancel), notice identifierB2B class inquiries: company name, name of the person in charge, contact details, expected number of participants and preferred schedule, and inquiry details entered by the inquirerRace application lookups: applicant's email address, race name, one-time verification codeNotifications of receipt of race bank transfer applications: race name, name of the lead applicant, event entered, number of participants, participation fee, application number and order number | Transmitted over the network at the time an email is sent (the body of emails and sending records are stored in the United States, and emails sent from the Company's sending domain are sent via facilities located in Japan) | Sending of emails | 30 days from the date of sending |
② The Company does not, at its own discretion, include information that can directly identify members, such as names, contact details, and dates of birth, or the coordinates of the route traveled in the items transferred under paragraph (1) (excluding recipient email addresses transferred to Plus Five Five, Inc. (Resend) as necessary for sending emails; the names and contact details for B2B class inquiries and race applications listed in the table in paragraph (1); and the member's name or display name included in the body of notifications sent to the assigned coach among the notifications transmitted to Google LLC for sending app notifications). However, because content that the member personally writes in questions or training notes is transmitted in its original text, the Company displays on the relevant input screens a message advising members not to enter personal information that is not strictly necessary.
③ The items transferred under paragraph (1) include health information such as pain scores and training notes. With respect to such information, the Company obtains consent to overseas transfer separately from consent to the processing of sensitive information under Article 5. However, the items transferred to Plus Five Five, Inc. (Resend) do not include health information.
④ OpenRouter, Inc. in paragraph (1) is a business operator that relays the Company's requests to artificial intelligence model providers. The Company limits the model providers to which requests are relayed to a scope designated in advance, and if that scope changes, the Company will disclose the change through this Privacy Policy.
⑤ The data subject may refuse the overseas transfer of personal information. If the data subject refuses, the AI coaching feature and the draft coach feedback feature will not be available, but there will be no restriction on the use of other services. The data subject may request refusal of the transfer to Plus Five Five, Inc. (Resend) for sending emails through the contact details in Article 17; after confirming the request, the Company will stop sending emails to that member without delay and will provide notices of a subscription's conversion to paid service and auto-renewal through the app screen and app notifications. B2B class inquiries may be made by telephone to the Customer Center (02-515-9031) instead of through the inquiry form. Because verification codes for race application lookups are sent only by email, applicants who refuse the transfer may check their application details through the Customer Center. Because notifications of receipt of race bank transfer applications are sent by email to the Company's operators only if the applicant chooses bank transfer, if an applicant who refuses the transfer applies using card payment, no such notification will be sent.
⑥ The Company has secured protective measures pursuant to Article 28-8(4) of the Personal Information Protection Act (개인정보 보호법) so that recipients can process personal information safely.
Article 12 (Destruction of Personal Information)
① When personal information becomes unnecessary, such as when the retention period of the personal information has elapsed or the purpose of processing has been achieved, the Company destroys the personal information without delay.
② If personal information must continue to be retained under other laws even though the retention period consented to by the data subject has elapsed or the purpose of processing has been achieved, the Company retains the personal information by transferring it to a separate database or storing it in a different location.
③ The methods of destruction are as follows.
1. Information in the form of electronic files: permanently deleted using a method that makes recovery and reproduction impossible
2. Information printed on paper: shredded or incinerated
④ Users may apply for deletion of their account directly within the Service, and the Company processes the application immediately upon receipt.
Article 13 (Rights of Data Subjects and Legal Representatives and Methods of Exercising Them)
① Data subjects may exercise the following rights against the Company at any time.
1. Request for access to personal information
2. Request for correction in case of errors
3. Request for deletion
4. Request for suspension of processing
5. Refusal of, or request for an explanation of, automated decisions
② The rights under paragraph (1) may be exercised through the settings screen of the Service, by email, or through the Customer Center, and the Company will take action on such requests without delay.
③ If a data subject has requested correction of an error in personal information, the Company will not use or provide the relevant personal information until the correction is completed.
④ The rights under paragraph (1) may also be exercised through an agent, such as the data subject's legal representative or a person delegated by the data subject. In this case, a power of attorney in the form of Annexed Form No. 11 of the Public Notice on Methods of Processing Personal Information (개인정보 처리 방법에 관한 고시) must be submitted.
⑤ The Company may refuse a data subject's request if it falls under Article 35(4), the proviso to Article 36(1), or Article 37(2) of the Personal Information Protection Act (개인정보 보호법), in which case the Company will notify the data subject of the reasons.
Article 14 (Matters Concerning Automated Decisions)
① Through the coaching features, the Company calculates and provides training plans, target times, and information on exercise intensity based on users' running records.
② The calculation under paragraph (1) follows the criteria and procedures below.
| Category | Details |
|---|---|
| Personal information processed | Distance traveled, time taken, speed per segment, elevation, and cadence measured or entered by the user, and goals set by the userBiometric indicators such as heart rate, if the user has separately consentedGender, date of birth, height, and weight entered by the user |
| Criteria for calculation | The user's current performance capability calculated from records over a certain recent period, the goal and timeframe set by the user, and general standards regarding training frequency and recovery |
| Procedure for calculation | The user's records are aggregated to calculate the user's current level, the gap from the goal is divided over the timeframe to allocate training volume by stage, and generally accepted training principles are applied to present the distance and intensity of each session. |
| Nature of the results | The results are limited to the provision of reference information and are not decisions that affect the user's rights or obligations. The user is under no obligation to follow the plan presented and will not be subject to any restriction on the use of the Service even if the user does not follow it. |
③ The user may request an explanation from the Company regarding the results of the calculation under paragraph (1). Requests may be made through the contact details in Article 17, and the Company will explain the criteria for the calculation and the information used, in a manner that the user can understand, within 30 days from the date of receipt of the request.
④ The user may stop using the coaching features on the App's settings screen, and stopping will not restrict the use of other services.
⑤ The Company uses generative artificial intelligence to provide the coaching features. In this case, the Company indicates on the relevant screen that the content produced has been generated by artificial intelligence.
⑥ The Company does not provide any feature that automatically assesses a member's health condition or risk of injury and notifies the member or the assigned coach. If such a feature is introduced in the future, the Company will disclose its criteria and procedures in this Privacy Policy in advance, in accordance with paragraphs (1) through (5) mutatis mutandis, and will obtain separate consent under Article 5.
Article 15 (Measures to Ensure the Security of Personal Information)
The Company takes the following measures to ensure the security of personal information.
1. The Company limits the employees who process personal information to the minimum, restricts access rights to the scope necessary to perform their duties, and retains access records.
2. Personal information is stored and transmitted in encrypted form.
3. User lists displayed on operator screens are masked by default, and viewing and downloading of the original data are restricted to approved administrator privileges.
4. Intrusion prevention and intrusion detection measures are applied to the personal information processing systems.
5. The Company provides regular training to employees who process personal information.
6. Materials containing personal information are kept in places equipped with locking devices.
Article 16 (Matters Concerning the Collection, Use, and Refusal of Behavioral Information)
The Company does not collect behavioral information for the purpose of analyzing users' interests and preferences in the course of their use of the Service.
Article 17 (Chief Privacy Officer and Department Receiving and Handling Requests for Access)
① The Company has designated a Chief Privacy Officer as follows to take overall charge of and responsibility for work related to the processing of personal information, and to handle complaints and provide remedies for damages of data subjects in connection with the processing of personal information.
| Category | Details |
|---|---|
| Chief Privacy Officer | Myungsung Park (박명성) / General Manager |
| Department | Business Management Team (경영관리팀) |
| Phone | 010-2050-9031 |
| Email address | mspark@runcop.com |
| Department receiving and handling requests for access | Business Management Team / General Manager Myungsung Park / 010-2050-9031 / mspark@runcop.com |
② Data subjects may direct all inquiries concerning personal information protection, complaint handling, and remedies for damages arising in the course of using the Service to the Chief Privacy Officer, and the Company will respond to and handle them without delay.
Article 18 (Remedies for Infringement of Rights and Interests)
Data subjects may apply to the following organizations for dispute resolution or consultation in order to obtain remedies for infringement of personal information.
| Organization | Phone | Website |
|---|---|---|
| Personal Information Infringement Report Center (개인정보침해 신고센터) | 118 (no area code) | privacy.kisa.or.kr |
| Personal Information Dispute Mediation Committee (개인정보 분쟁조정위원회) | 1833-6972 | kopico.go.kr |
| Cyber 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.police.go.kr |
In addition, a person whose rights or interests have been infringed by a disposition or omission of the head of a public institution in response to a request under Articles 35, 36, and 37 of the Personal Information Protection Act (개인정보 보호법) may file an administrative appeal as prescribed by the Administrative Appeals Act (행정심판법).
Article 19 (Amendments to the Privacy Policy)
① If there are additions, deletions, or corrections to the content due to changes in laws or the Service, the Company will give notice through the announcements of the Service from 7 days before the changes take effect. However, if a material change to the rights of data subjects occurs, the Company will give notice 30 days in advance and, where necessary, obtain the data subject's consent again.
② The Company also posts the previous versions of the Privacy Policy so that users can review them.