Privacy Policy

• At Phoenixdarts Co., Ltd. (the “Company,” “we,” or “us”), we process and manage users’ (“members,” “you,” or “your”) personal information lawfully and securely in accordance with the Personal Information Protection Act and other applicable laws and regulations. Our goal is to protect your freedom and rights as a data subject. In line with the Personal Information Protection Act, we have established and published this Privacy Policy to inform you of the procedures and standards we follow for handling your personal information and to ensure the prompt and efficient resolution of any related concerns or grievances. Unless otherwise expressly provided, references to laws or regulations in this Privacy Policy shall be construed as references to the laws of the Republic of Korea.

1. Purpose and Items of Personal Information Processing

• We collect and process personal information for the following purposes. We do not use your personal information for purposes other than those listed below. If we need to use your information for a different purpose, we will take appropriate steps, including obtaining your separate consent.
1. • Membership Registration and Management: To confirm your intent to register, verify your identity and provide authentication, maintain and manage membership status, prevent unauthorized use of services, and deliver various notices and communications.
2. - Items collected: Name; date of birth, mobile phone number; telecommunications carrier; domestic/foreign national status; duplicate registration verification information (DI); and connection information (CI); email address; ID; nickname, and passwords.
3. - For users under 14, the following legal guardian information is collected: name; gender; date of birth; mobile phone number; telecommunications carrier; domestic/foreign national status; DI; and CI.
4. • Performance of the Service Agreement: To provide the services and fulfill our obligations under the service agreement, including resolving disputes.
5. - Items collected: Name; gender; date of birth; mobile phone number; telecommunications carrier; domestic/foreign national status; DI; CI; email address; ID; nickname; password; and profile photograph.
6. • Hosting and Managing Competitions and Tournaments, and Prizes Distribution: To organize and manage competitions and tournaments held by the Company or its affiliates, issue related notices, maintain records, and distribute commemorative items or prizes.
7. - Basic items collected: Name; mobile phone number; email address; nickname; date of birth; gender; and address.
8. - Items collected for tax and fee purposes in connection with prizes awarded in competitions: full name; mobile phone number; postal address; date of birth; nationality; tax identification number (if applicable); bank account information (for remittance); and other information required by applicable local laws and regulations.
9. • Payment for Paid Services: To process payments, refunds, and debt collection related to paid services.
10. - Items collected for credit card payments: Card issuer name; card number, etc.
11. - Payments through mobile carriers (including billing and micropayments): Mobile phone number; subscriber number; telecommunications carrier; payment authorization number, etc.
12. - Bank transfers (including wire transfers): Bank name; account holder; account number, etc.
13. - Gift certificate use: Gift certificate number.
14. - Refund requests: Payment method selected by the Member; refund processing account number; bank name; account holder, etc.
15. • Service-Related Complaint Resolution: To provide customer service, including the processing of user inquiries and complaints.
16. - Items collected: Name; mobile phone number; email address; nickname; date of birth; gender; address; and call recordings.
17. • Marketing and Advertising: To inform users about new features and services, provide opportunities to participate in competitions, games, or other events, and distribute newsletters.
18. - Items collected: Email address; and mobile phone number.
19. • Event Application Processing and Product Delivery:
20. - Items collected: Membership number; ID; nickname; mobile phone number; email address; social media account information; dart throwing videos; other information necessary for event administration (as disclosed upon collection); and product recipient information (name; contact details; address).
21. • Service Improvement and Customized Service Development: To improve our existing services and to develop and provide customized services tailored to user preferences.
22. - Items collected: All items listed in this Section, as well as the automatically collected items outlined below.
• We automatically collect the following categories of personal information while you use our Services: IP address; cookies; service usage records (including visit history, usage logs, and records of misuse); device information; device model name; operating system name and version; and browser name and version.

2. Processing and Retention Period of Personal Information

• We retain and process your personal information only with the retention and use period consented by you at the time of collection.
• The processing and retention periods for personal information are as follows:
1. • Membership registration and management: Sixty (60) days from the date of membership termination; provided, however, that for Members with records of improper use, such records shall be retained for two (2) years to prevent re-registration;
2. - Information of legal guardian for children under 14 shall be deleted immediately after confirmation of the legal guardian’s consent.
3. • Performance of service use agreements: Sixty (60) days from the date of membership termination;
4. • Hosting and management of competitions and tournaments, and prize distribution: Sixty (60) days from membership termination; provided, however, that the name, contact information, address, and mobile gift certificate delivery contact information of prize recipients shall be retained for four (4) weeks after completion of delivery or transmission;
5. • Payment for paid services: Five (5) years;
6. • Handling of service-related grievances: Three (3) years;
7. • Marketing and advertising: Until you withdraw your consent;
8. • Receipt and management of event applications: Three (3) months from the event end date; provided, however, that when products are provided, the retention period specified above shall apply);
9. • Service improvement and development of customized services: Sixty (60) days from the date of membership termination; and
• Notwithstanding the periods listed above, we may retain and use your personal information for longer periods in the following circumstances, including but not limited to the cases prescribed by applicable laws and regulations. Where required by law, retention will be limited to the scope permitted by the applicable statutes:
1. • In accordance with the Act on the Consumer Protection in Electronic Commerce:
2. - Records of contracts or subscription withdrawals, payments, and supply of goods or services: Five (5) years;
3. - Records related to consumer complaints or dispute resolution: Three (3) years; and
4. - Records concerning advertisements and promotional materials: Six (6) months.
5. • Under Article 15-2 of the Protection of Communications Secrets Act, telecommunication verification data: Three (3) months; and
6. • Under Article 85-3 of the Framework Act on National Taxes, accounting books and supporting documents: Five (5) years.
7. • Where an investigation or inquiry is ongoing due to a violation of applicable laws or regulations, we will retain the relevant information until the conclusion of the investigation or inquiry.
8. • Where any outstanding debt or obligation exists between you and the Company arising from your use of our services, we will retain the relevant information until such obligations are fully resolved.

3. Disclosure of Personal Information to Third Parties

• We process your personal information only within the scope necessary to achieve the purposes described in this Privacy Policy. We disclose personal information to third parties only when permitted under the Personal Information Protection Act, such as when we obtain your consent or where disclosure is required by law. and do not otherwise share your personal information with third parties.

4. Delegation of Personal Information Processing

• To ensure the efficient and secure management of personal information, we outsource certain processing activities to trusted third-party service providers.

• When we enter into a data processing or outsourcing agreement, we set out clear contractual obligations to ensure the secure handling of personal information. These include: a prohibition on processing personal information for any purpose other than performing the entrusted services; requirements for technical and administrative safeguards; restrictions on subcontracting; obligations for management and supervision; and liability for damages. We also monitor and supervise our service providers to confirm that they process personal information safely and in compliance with applicable requirements.
• If a trustee seeks to subcontract any part of the Company’s personal information processing activities, our prior consent is required.
• If there are any changes to the scope of delegated activities or to the trustees themselves, we will update this Privacy Policy without delay.

5. Cross-Border Transfer of Personal Information

• Your personal information may be processed in the Republic of Korea and the United States. We provide and entrust personal information overseas as follows:
• • Google LLC
1. - Categories of personal information transferred: IP address, cookies, device information (mobile device model, operating system name and version, browser name and details), service usage records (access and usage logs, violation records, etc.)
2. - Country of transfer: United States
3. - Timing and method of transfer: Immediately upon service use, by remote transfer over a dedicated network
4. - Recipient (name/contact): Google LLC (https://support.google.com)
5. - Purpose of use by recipient: Collection and analysis of behavioral data for statistical analysis and service improvement
6. - Retention and use period by recipient: Consistent with the retention and use period described in Section 2
7. - How to refuse transfer and consequences: You may refuse the overseas transfer of your personal information by contacting our privacy department. However, refusal may result in restrictions on service use.
8. - Legal basis for overseas transfer: Article 28-8, Paragraph 1, Item 3(a) of the Personal Information Protection Act (Cross-Border Transfer of Personal Information)
• • Amazon Web Services Inc
1. - Categories of personal information transferred: All personal information listed in Section 1 above
2. - Timing and method of transfer: Immediately upon service use, by remote transfer over a dedicated network
3. - Recipient (name/contact): Amazon Web Services Inc (https://aws.amazon.com/ko/contact-us)
4. - Purpose of use by recipient: Provision of cloud services, data storage, and management
5. - Retention and use period by recipient: Consistent with the retention and use period described in Section 2
6. - How to refuse transfer and consequences: You may refuse the overseas transfer of your personal information by contacting our privacy department. However, refusal may result in restrictions on service use.
7. - Legal basis for overseas transfer: Article 28-8, Paragraph 1, Item 3(a) of the Personal Information Protection Act (Cross-Border Transfer of Personal Information)

6. User Rights and How to Exercise Them

• You may exercise the following rights with respect to your personal information at any time: request access, correction; deletion; suspension of processing; or withdrawal of your consent. You may also object to automated decision-making or request an explanation regarding such decisions. You may further exercise any rights afforded to you under the applicable data protection laws of your jurisdiction with respect to your personal information.
• These rights may be exercised through a representative, such as a legal guardian or an authorized agent. In such cases, you must provide a power of attorney or other documentation evidencing the delegation of authority.
• You may exercise your rights in Section 1 in writing, by email, or through other reasonable methods, and we will take action without delay.
1. • To request access to your personal information, you may contact us at privacy@phoenixdarts.com.
2. • To withdraw your consent to the collection and use of your personal information, you may withdraw your membership at any time.
3. • To object to automated decision-making or request an explanation, you may contact us at privacy@phoenixdarts.com.
• Please note that certain rights may be limited under applicable laws, including the Personal Information Protection Act, as shown below:
1. • You may not request deletion of personal information where retention is required under other laws or regulations;
2. • Where you have given consent to automated decision-making; where you have been informed of such processing in advance (for example, through a contract); or where such processing is expressly permitted by law, you may not object to the automated decision itself and may only request an explanation or review; and
3. • We may refuse a request for explanation if there is a legitimate reason, such as where disclosure may unduly infringe upon the life, safety, property, or other rights and interests of third parties.
• You may exercise your rights by contacting the department below:
1. • Department Name: Service Operations Team
2. • Contact: privacy@phoenixdarts.com / Tel: 02-890-6767

7. Destruction of Personal Information

• We promptly destroy personal information when it is no longer needed, such as when the retention period expires or the processing purpose has been fulfilled.
• If we are required to continue retaining personal information under applicable laws and regulations as described in Section 2, Subsection 2, even after the agreed retention period has expired or the processing purpose has been achieved, we will transfer the personal information to a separate database (DB) or store it in a different location.
• The procedures and methods for destroying personal information are as follows:
1. • Destruction procedure: We select personal information subject to destruction and permanently delete it upon approval by our Data Protection Officer; and
2. • Destruction methods: Electronic files are destroyed using technical measures to make the records irrecoverable. Paper records are destroyed by shredding or incineration.

8. Security Measures for Personal Information

• We take the following measures to protect your personal information and ensure its security:
1. • Administrative Measures: Development and enforcement of internal management policies; regular employee training, and other organizational safeguards.
2. • Technical Measures: Implementation of security controls against hacking and other threats; encryption of personal information, management of access rights to personal information systems, retention of access logs; and prevention of tampering or alteration.
3. • Physical Measures: Implementation of access controls for server rooms; data centers; and other facilities where personal information is stored.

9. Use of Cookies and Similar Technologies

• We use “cookies” to store and retrieve usage information in order to provide you with personalized services. Cookies are small files sent by our website server to your web browser and may be stored on your computer’s hard drive or mobile device.
1. • Purpose of Cookies: We use cookies to maintain login sessions, analyze how often users visit and how long they stay; identify and track service usage patterns; verify secure access and user authentication; measure the size of our user base, enhance security management; and improve existing services and develop new ones.
2. • Managing Cookies: You may choose whether or not to accept cookies. You can refuse cookie storage by adjusting your device or browser settings.
3. • Effect of Refusing Cookies: If you refuse cookie storage, some features or services may not function properly.

10. Collection, Use, and Refusal of Behavioral Information

• When you visit or use our Apps, we may use cookies and tags, including third-party software development kits (SDKs), to support effective service delivery.
• The following third party collects behavioral information through our Apps:

• You can adjust your browser or mobile device settings to allow or block behavioral information collected by third parties.

11. Data Protection Officer

• We have designated a Data Protection Officer to oversee all matters relating to the processing of personal information, handle user inquiries and complaints, and provide remedies for any damages arising from personal information breaches.
1. • Data Protection Officer
2. - Responsible Person: Dong-Beom Choi
3. - Contact: privacy@phoenixdarts.com / Tel: 02-890-6767
4. • Personal Information Protection Department
5. - Department: Service Operations Team
6. - Contact: privacy@phoenixdarts.com / Tel: 02-890-6767
• You may contact the above department regarding any inquiries, complaints, requests for damage relief, or other matters related to personal information that arise while using our services.

12. Additional Disclosures for Data Subjects in the EU/EEA

• If you are located in the European Union (“EU”) or the European Economic Area (“EEA”), the processing of your personal information will be carried out in accordance with the General Data Protection Regulation (“GDPR”).
1. • Controller: Phoenixdarts Co., Ltd. acts as the data controller for your personal information.
2. • Lawful Basis for Processing: Depending on the context, we rely on one of the following lawful bases: (a) your consent (e.g., for communications); (b) performance of a contract (e.g., account creation, payment processing, prize delivery); (c) compliance with a legal obligation (e.g., tax and accounting requirements); or (d) legitimate interests pursued by us or a third party (e.g., service improvement, fraud prevention), provided that your fundamental rights are not overridden.
3. • Cross-Border Transfers: Your personal information may be transferred outside of the EU/EEA, including to the Republic of Korea and the United States. In such cases, we implement appropriate safeguards, such as the European Commission’s Standard Contractual Clauses, to protect your information.
4. • Your Rights: You have the right to access; rectify; erase your personal information; restrict or object to its processing; and request data portability. You may also withdraw your consent at any time when processing is based on consent, without affecting prior lawful processing, and you have the right to lodge a complaint with your local data protection authority. If we process special category data, we will do so only where both a lawful basis under Article 6 and a condition under Article 9 of the GDPR apply (for example, your explicit consent). You may object at any time to our use of your data for direct marketing, and in other cases where processing is based on legitimate interests, unless we demonstrate overriding grounds. You also have the right not to be subject to automated decision-making, including profiling, that produces legal or similarly significant effects.
5. • EU Representative: Pursuant to Article 27 of the GDPR, we have appointed Groupoaliaga as our representative in the EU. You may contact them at: [
6. - Email: SOPORTE@GRUPOALIAGA.COM
7. - Address: Francisco Aritio 162 Edif.2 Office 231, 19004 Guadalajara, Spain

13. Additional Disclosures for California Residents

• If you are a California resident, you have additional rights under the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”).
1. • Notice of Collection: In the past twelve (12) months, we have collected the following categories of personal information: identifiers (such as name, phone number, email, address, and user ID); customer records; characteristics of protected classifications (such as gender, date of birth, and nationality); commercial information (such as purchase history, service usage, event participation records, and payment details); internet or electronic activity information (such as device information, cookies, and usage logs); geolocation data; and inferences drawn from the above.
2. • Business Purposes: We use these categories of information for the business purposes described in Cal. Civ. Code § 1798.140(e), including providing services; processing payments; verifying identity; administering promotions; improving services; and complying with legal obligations.
3. • Sensitive Personal Information: We collect certain categories of sensitive personal information, such as credit or debit card numbers with associated security credentials for payment processing, bank account information for refunds or prize payments, and tax identification numbers for statutory reporting. We use or disclose this sensitive personal information only for purposes permitted under Cal. Code Regs. tit. 11, § 7027(m), including providing the services you request, ensuring security and integrity, processing payments, preventing fraud, and performing services on our behalf. We do not use or disclose sensitive personal information for any purposes other than those permitted under applicable law.
4. • Storage/Location of Personal Information: Your personal information may be stored and processed in the United States and the Republic of Korea, consistent with Section 5 (Cross-Border Transfer of Personal Information).
5. • Minors Under 16: We do not have actual knowledge that we sell or share the personal information of consumers under the age of 16. If this changes, we will update this Privacy Policy and provide appropriate opt-in rights for minors between 13 and 16 and parental consent requirements for minors under 13.
6. • Your Rights: California residents have the right to (a) know the categories of personal information we collect and disclose; (b) request access to or deletion of personal information; (c) request correction of inaccurate information or obtain a copy of their personal information in a portable and, to the extent technically feasible, readily usable format; (d) opt out of the sale or sharing of personal information; (e) limit the use of sensitive personal information; and (f) not be discriminated against for exercising these rights.
7. • Opt-Out and Limit Rights: To the extent our processing of personal information is considered a “sale” or “sharing” under the CCPA, you have the right to opt out of such sale or sharing at any time. Where required, we provide a clear and conspicuous link titled “Do Not Sell or Share My Personal Information” on our homepage (and in the footer of our website) that enables you or your authorized agent to exercise this right. We do not use or disclose sensitive personal information for purposes other than those permitted under Cal. Code Regs. tit. 11, § 7027(m); therefore, the right to limit does not apply
8. • Authorized Agent: You may designate an authorized agent to make requests on your behalf, subject to verification of your identity.

14. Additional Disclosures for Nevada Residents

• Under Nevada law (NRS 603A.340), if you are a Nevada resident, you may submit a request directing us not to sell certain kinds of personal information that we have collected or will collect about you. A “sale” under Nevada law means the exchange of personal information for monetary consideration by the business to a third party, for the third party to license or sell the personal information to additional third parties.
• We do not currently sell personal information as defined under Nevada law; however, you may exercise your rights by contacting us at privacy@phoenixdarts.com.

15. Changes to This Privacy Policy

• We may update or amend this Privacy Policy from time to time, including to reflect changes in applicable laws or in our services. If we make changes, we will post the revised Privacy Policy before the effective date, and the updated version will take effect on the stated effective date.
• This Privacy Policy is effective as of [February 24, 2026.].