Privacy Policy

Last updated: January 1, 2025

This Privacy Policy describes how Walkingman (Business Registration Number 7500703149, hereinafter "engles" or "the Company"), the operator of engles, collects, uses, and protects personal information in connection with its website and services (hereinafter "Services"). The Company handles information about students and parents responsibly and complies with the Personal Information Protection Act (PIPA) of the Republic of Korea and, where applicable, the GDPR, CCPA, and other relevant laws.

1. Personal Information We Collect

• Account Information— Name, email address, and the student's grade level and learning goals.
• Usage and Learning Data — Activity records used for personalized learning and level assessment, including learning progress, books read, and learning outcomes.
• Transaction Information — Products purchased, order history, and payment confirmation details (collected by Paddle and shared with the Company; the Company does not receive full card numbers).
• Technical Information — Device, browser, IP address, cookies, and other information used to maintain the security and proper operation of the Services.

2. How We Use Your Personal Information

• To provide, personalize, and improve the Services
• To provide level assessments, learning curricula, and learning analytics
• To process purchases and send service notifications via Paddle
• To send order confirmations and, with your consent, marketing emails
• To detect fraudulent activity and maintain service security

3. Children's Privacy

Purchases and account management are performed by parents or guardians. Where a student is a minor, the Company collects and processes the student's learning data solely for the purpose of providing English learning services, under the consent and supervision of the parent or guardian who holds the account. Parents may request access to or deletion of their child's data at any time.

4. Legal Basis for Processing

Where the GDPR applies, the Company processes personal information on the following legal bases: performance of a contract (service delivery), consent (marketing), legitimate interests (service improvement and security), and compliance with legal obligations.

5. Disclosure of Personal Information

The Company shares personal information only in the following circumstances.

• Paddle, our Merchant of Record, for payment and tax processing
• Service providersacting on the Company's behalf under contract (e.g., hosting, email, analytics)
• Relevant authorities when required by applicable law

The Company does not sell personal information.

6. Retention Period

The Company retains personal information for as long as necessary to provide the Services and fulfill purchases, and for as long as required to comply with legal, tax, and accounting obligations, resolve disputes, and enforce agreements. You may request deletion of your data at any time.

7. Your Rights

Depending on your jurisdiction, you may have the right to access, correct, delete, or port your personal information, to object to or restrict certain processing, and to withdraw consent. To exercise your rights, please contact us at privacy@engles.co.kr. You also have the right to lodge a complaint with your local data protection authority.

8. Cookies

The Company uses cookies that are essential for operating the Services and, with your consent, analytics cookies to understand usage patterns. Cookies can be managed through your browser settings.

9. International Transfers and Security

Your personal information may be processed in countries other than your country of residence, in which case appropriate safeguards are applied. The Company applies technical and organizational security measures, including encryption in transit; however, no transmission method is completely secure.

10. Contact Us

For privacy-related inquiries and requests, please contact us at privacy@engles.co.kr or by mail at [Business Address].