Effective Date: January [*], 2025
Lemon Sound Inc. (hereinafter referred to as "Lemon Sound") highly values the personal information of users, including clients and artists (hereinafter referred to as "data subjects"), and complies with the relevant laws and regulations that information and communication service providers must adhere to.
To protect the freedom and rights of data subjects, Lemon Sound lawfully processes and securely manages personal information in accordance with the Personal Information Protection Act, Telecommunications Business Act, Act on the Consumer Protection in Electronic Commerce, Act on Promotion of Information and Communications Network Utilization and Information Protection, Electronic Signature Act, and other relevant laws and regulations. Pursuant to Article 30 of the Personal Information Protection Act, this Privacy Policy (hereinafter referred to as "this Policy") is established and disclosed to inform data subjects of the procedures and standards for processing personal information and to promptly and smoothly handle related concerns.
This Privacy Policy includes the following contents:
- Purpose and Scope of Personal Information Processing
- Processing and Retention Period of Personal Information
- Processing of Personal Information of Children Under the Age of 14
- Provision of Personal Information to Third Parties
- Delegation of Personal Information Processing Tasks
- Destruction of Personal Information
- Rights and Obligations of Data Subjects and Their Legal Representatives & How to Exercise Them
- Measures to Ensure the Security of Personal Information
- Installation, Operation, and Rejection of Automatic Data Collection Devices
- Collection, Use, Provision, and Rejection of Behavioral Information
- Personal Information Protection Officer and Responsible Department
- Remedies for Personal Information Infringement
- Responsibilities Regarding Linked Websites
- Changes to the Privacy Policy
- Effective Date
1. Purpose and Scope of Personal Information Processing
Lemon Sound collects only the minimum personal information necessary for service provision, except as permitted by law. The collected information is not used for purposes beyond the originally intended scope, nor is it disclosed to external parties without the consent of the data subject. If the purpose of use changes, necessary measures, such as obtaining separate consent, will be taken in accordance with Article 18 of the Personal Information Protection Act.
[Mandatory Consent]
| Processing Task | Purpose of Collection | Collected Information | Collection Method |
|---|---|---|---|
| Membership Registration | Creating a user account, email verification, service provision, artist and client information management, communication for project execution, notifications, and handling complaints | Email address | Collected when users register for Lemon Sound services (including PC web, mobile web, and mobile apps) |
| Artist Account Conversion | Artist identification, artist and client information management, project-related communication, membership verification, fraud prevention, notifications, complaint handling, and posting artist information within the service | Stage name, phone number, nationality, artist photo, bio, professional experience, and project-related details | Collected when users switch to an artist account within Lemon Sound services |
| Client Project Request | Request management, service provision, customer support, and revenue settlement for game soundtracks sold by game companies | Name (or company name), business registration information, phone number, email address, request details, and bank account information (if using ChannelTalk, additional information such as IP address, browser type, device information, page navigation history, chat logs, and location data may be collected) | Collected when users submit requests through Lemon Sound services, ChannelTalk, or separate email forms |
| Artist Project Application | Verification of participation intent, artist-client matching, project assignment, management, and future project-related information provision | Name, photo, phone number, email address, nationality, budget, bio, professional experience, and project-related details | Collected through Lemon Sound services or separate email submission forms |
| Artist Contract and Settlement | Contract execution, communication, quality management, contract signing, payment processing, tax reporting, and music distribution management | Name, gender, national ID number, copies of identification documents (e.g., resident registration card, passport), bank account number, SWIFT code, ACH routing number, and other banking details required for international transactions | Collected through Lemon Sound services or separate email submission forms |
| Consultation | Handling inquiries related to membership registration, artist account conversion, project requests, artist project applications, contracts, and settlements | Name (or company name), phone number, consultation details, and email address (if using ChannelTalk, additional information such as IP address, browser type, device information, page navigation history, chat logs, and location data may be collected) | Collected through Lemon Sound services, email, chat (ChannelTalk), and phone |
[Optional Consent]
| Processing Task | Purpose of Collection | Collected Items | Collection Method |
|---|---|---|---|
| Providing advertisements, promotions, and service improvement & analysis for Lemon Sound and its affiliates | Providing information on Lemon Sound and its affiliates' products/services, promotions, and marketing materials, as well as service improvement and analysis | Name (Company Name), Business Registration Information (for identity verification), Phone Number, Email Address, IP Address, Click Events, Page Views | Information entered in the Lemon Sound service |
[Personal Information Collected Without User Consent]
| Legal Basis | Purpose of Collection | Collected Items | Collection Method |
|---|---|---|---|
| Income Tax Act Articles 127, 128, Value-Added Tax Act Article 32 | Income tax withholding payment or issuance of tax invoices | Resident Registration Number recorded on a copy of an ID | Information entered in the Lemon Sound service or submitted via a separate email form |
2. Processing and Retention Period of Personal Information
Lemon Sound processes and retains personal information within the legally mandated period or the period agreed upon when collecting the information. When a user requests account deletion, withdraws consent for personal information collection, or when the purpose of collection is fulfilled, the Company promptly deletes the information. However, if otherwise specified in this Privacy Policy, the Company may retain personal information for the following periods:
- Personal information collected for membership registration and artist account conversion: Retained until account deletion. However, in the following cases, retention continues until the respective issue is resolved:
- If an investigation is ongoing due to a violation of applicable laws, retention continues until the investigation is completed.
- If financial obligations exist due to service use, retention continues until settlement.
- Personal information collected for project requests, artist participation applications, contract execution, and settlement: Retained for 10 years from the completion date of the project.
- Personal information collected for advertisements, promotions, and service improvement for Lemon Sound and its affiliates: Retained until consent withdrawal or account deletion.
- Information required for withholding tax under the Income Tax Act (Articles 127 & 128): Retained for 5 years after the corporate tax filing deadline for the applicable tax period.
- Information required for tax invoices under the Value-Added Tax Act (Article 32): Retained for 5 years after the final reporting deadline for the applicable tax period.
- Records related to transactions under the Act on Consumer Protection in Electronic Commerce, etc.:
- Advertising and promotional records: 6 months
- Records of contracts, withdrawals, payments, and supply of goods/services: 5 years
- Records of customer complaints or dispute resolution: 3 years
Even if a user no longer uses Lemon Sound, their personal information may remain unless they request account deletion. To ensure data removal, users must request account deletion.
3. Processing of Personal Information for Children Under 14
The Company does not provide services to children under 14 and does not collect personal information from them.
4. Provision of Personal Information to Third Parties
Lemon Sound processes personal information only within the scope specified for processing purposes and provides personal information to third parties only when the data subject has given consent, when special provisions in the law apply, or when it falls under Articles 17 and 18 of the Personal Information Protection Act. Except for these cases, Lemon Sound does not provide personal information to third parties.
For smooth service provision, Lemon Sound obtains the data subject's consent under Article 17(1)(1) of the Personal Information Protection Act and provides personal information only within the minimum necessary scope in the following case:
| Recipient | Purpose of Use | Provided Items | Retention & Usage Period |
|---|---|---|---|
| Cuo Music Co., Ltd. | Music distribution and release | Name, artist name, artist type, biography, images (artist-related information), agency, distributor (company-related information), phone number, email address (contact information), album type, album description & cover, title track, music files, song titles & lyrics (music-related information), contract type | Duration of transactions under the music distribution contract |
5. Delegation of Personal Information Processing Tasks
1. Domestic Delegation
Lemon Sound entrusts the processing of personal information to external companies for efficient handling, as follows:
| Recipient | Entrusted Task |
|---|---|
| Bridgecode Co., Ltd. | Issuance of tax invoices and cash receipts |
| Channel Corporation Co., Ltd. | Operation of customer support system (Channel Talk) |
| Modusign Co., Ltd. | Electronic contract services |
| MOIN Co., Ltd. | Overseas remittance services |
| Bridged Korea Co., Ltd. | User data management |
2. Overseas Delegation
For efficient personal information processing, Lemon Sound entrusts certain tasks to overseas corporations as follows:
| Recipient & Contact | Country | Transferred Items | Purpose of Transfer | Time & Method of Transfer | Retention & Usage Period | Rejection Method & Effect |
|---|---|---|---|---|---|---|
| Google LLC (privacy@google.com) | USA | Cookies, device info, visit records, user behavior data | Marketing activities and personalized ads | Transferred via network at the time of data analysis | Same as the retention period specified in this privacy policy | Users can request to refuse overseas data transfer through the data protection officer or relevant department, but refusal may limit service usage. |
| The Rocket Science Group LLC (Mailchimp) (privacy@mailchimp.com) | USA | Email address | Marketing email delivery | Transferred via network at the time of user registration | Same as the retention period specified in this privacy policy | Users can request to refuse overseas data transfer through the data protection officer or relevant department, but refusal may limit service usage. |
| Resend Inc. (support@resend.com) | USA | Email address | Email verification during user registration | Transferred via network at the time of email verification | Same as the retention period specified in this privacy policy | Users can request to refuse overseas data transfer through the data protection officer or relevant department, but refusal may limit service usage. |
| Supabase Inc. (privacy@supabase.io) | USA | All personal information collected by Lemon Sound as defined in Section 1 of this policy | Data storage and processing | Transferred via network at the time of service usage | Same as the retention period specified in this privacy policy | Users can request to refuse overseas data transfer through the data protection officer or relevant department, but refusal may limit service usage. |
6. Destruction of Personal Information
Lemon Sound promptly destroys personal information when it is no longer necessary, such as after the retention period has expired or the processing purpose has been achieved, unless it is required to be preserved under other laws.
The procedures and methods for destroying personal information are as follows:
- Destruction Procedure
Personal information that requires disposal is selected from the database and then destroyed.
- Destruction Method
- Personal information recorded and stored in electronic file format is permanently deleted using an irreversible method.
- Other types of records, printed materials, written documents, or other media are shredded or incinerated for disposal.
7. Rights and Obligations of Data Subjects and Their Legal Representatives, and How to Exercise Them
Data subjects may exercise their rights regarding personal information, such as requesting access, correction, deletion, or suspension of processing, at any time with Lemon Sound.
These rights can be exercised via written documents, email, or fax. They may also be exercised through a legal representative or an authorized agent. In this case, a power of attorney must be submitted following the format specified in the "Notice on Personal Information Processing Methods (Personal Information Protection Commission Notice No. 2023-12), Annex 11."
Requests for access or suspension of processing may be restricted under Article 35, Paragraph 4, and Article 37, Paragraph 2 of the Personal Information Protection Act. Additionally, requests for correction or deletion cannot be made if the personal information is legally required to be collected under other laws.
Lemon Sound verifies whether the requester is the data subject or an authorized representative before processing requests for access, correction, deletion, or suspension of processing. If a request for correction is made, the relevant personal information will not be used or provided until the correction is completed. Lemon Sound handles user requests without delay.
8. Measures to Ensure the Security of Personal Information
Lemon Sound takes the following measures to ensure the security of personal information:
- Technical Safeguards
- Encryption of personal information
- Access control management for personal information processing systems
- Installation of access control systems
- Installation and regular updates of security programs
- Administrative Safeguards
- Establishment and compliance with internal management regulations
- Regular security training for employees
- Inspections of personal information processing status
- Physical Safeguards
- Access control and security measures for servers and data storage locations
9. Installation, Operation, and Rejection of Automatic Data Collection Devices
Lemon Sound uses "cookies" to store and retrieve user information from time to time in order to provide personalized services. When a user accesses the service, the server reads the cookie stored on the user's device to maintain the user's environment settings and provide customized services.
- Purpose of Using Cookies
Cookies allow users to access the website as they have set it and use it conveniently. They are also used to provide personalized information such as optimized advertisements based on users' website visit history and usage patterns.
- Installation, Operation, and Rejection of Cookies
Users have the option to accept or reject cookie installation. They can configure their web browser settings to allow all cookies, prompt a confirmation before storing cookies, or reject all cookies. However, rejecting cookies may result in inconvenience when using the website and difficulties accessing some services that require login.
- How to Disable Cookie Collection
- Web Browsers
- Edge: Browser settings > Cookies and site permissions > Manage and delete cookies and site data
- Chrome: Browser settings > Privacy and security > Clear browsing data
- Safari: Preferences > "Prevent cross-site tracking" and "Block all cookies"
- Mobile Devices
- Chrome: Mobile browser settings > Privacy and security > Clear browsing data
- Safari: Mobile device settings > Safari > Advanced > Block all cookies
- Samsung Internet: Mobile browser settings > Internet usage history > Clear browsing data
- Web Browsers
10. Collection, Use, Provision, and Rejection of Behavioral Information
Lemon Sound also uses Google Analytics, a web log analysis tool provided by Google, to offer better services.
Google Analytics collects behavioral data of website users through cookies, but only non-identifiable information that cannot personally identify users is collected.
The processing of information collected via Google Analytics is subject to Google's Privacy Policy and Google Analytics Terms of Service:
- Google Privacy Policy: https://www.google.com/intl/ko/policies/privacy/
- Google Analytics Terms of Service: https://www.google.com/analytics/terms/kr.html
Nevertheless, users can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on or by adjusting their web browser's cookie settings to reject cookies.
11. Personal Information Protection Officer and Responsible Department
Lemon Sound has designated a Personal Information Protection Officer responsible for overseeing personal information processing and a Personal Information Protection Manager handling practical matters to address users' complaints and provide remedies regarding personal data processing.
- Personal Information Protection Officer
- Name: Shinjung Park
- Email: sj@lemonsound.co
- Position: Representative, In-House Director
- Personal Information Protection Manager
- Name: Jiwon Moon
- Email: legal@lemonsound.co
- Position: Legal Affairs Manager
Users may contact the Personal Information Protection Officer or Manager for any inquiries, complaints, or remedies related to personal information protection while using Lemon Sound's services.
Lemon Sound will respond promptly and handle inquiries without delay.
12. Remedies for Personal Information Infringement
Users can seek dispute resolution or consultation regarding personal information infringement through the Personal Information Dispute Mediation Committee, the Korea Internet & Security Agency's Personal Information Infringement Report Center, or other relevant institutions.
For further reporting or consultation, please contact the institutions below:
- Personal Information Dispute Mediation Committee: (No area code) 1833-6972 (www.kopico.go.kr)
- Personal Information Infringement Report Center: (No area code) 118 (privacy.kisa.or.kr)
- Supreme Prosecutors' Office: (No area code) 1301 (www.spo.go.kr)
- Korean National Police Agency: (No area code) 182 (ecrm.cyber.go.kr)
Lemon Sound is committed to protecting users' personal information rights and providing consultation and remedies in case of any infringement. If you need to report or seek advice, please contact our Personal Information Protection Officer or Manager:
- Personal Information Protection Officer: Shinjung Park (sj@lemonsound.co)
- Personal Information Protection Manager: Jiwon Moon (legal@lemonsound.co)
13. Responsibilities Regarding Linked Websites
Lemon Sound may provide links to other websites for users. However, these external websites are not governed by Lemon Sound's Privacy Policy. Users should review the respective privacy policies of linked websites when using them.
14. Changes to the Privacy Policy
Any changes to this Privacy Policy will be announced at least seven (7) days before the effective date through a notice on the website or via email. If necessary, user consent may be obtained again.
15. Effective Date
This Privacy Policy is effective from January [*], 2025.