BAGEL Privacy Policy

1. Introduction

Welcome to BAGEL!🙌 🥳 Metascalecorp, Inc., collects your personal data to provide our communication app, BAGEL (hereinafter simply “BAGEL Services”). 🙌 We strive to comply with all applicable laws and regulations (hereinafter simply “Applicable Laws”) and securely and properly protect your personal data in accordance with this Privacy Policy (hereinafter simply “this Policy”).

2. Scope of Application

(1) This Policy applies to all personal data obtained in connection with BAGEL Services. This Policy is available in several languages. The Korean version applies to users in Korea, the Japanese version to users in Japan, and the English version to users in other countries and regions to the extent permitted by Applicable Laws! (2) We may apply individual privacy policies, terms of use, or additional provisions to this Policy for specific services (together simply “Individual Policies”). If there is an inconsistency between such Individual Policies and this Policy (which you are reading now), please note that the Individual Policies will prevail on the matter at issue!

3. Personal Data of Children Under 13

We are sorry, but you may not use BAGEL Services if you are under the age of 13 or if you are a child under the minimum age set forth by Applicable Laws. 😢 Therefore, we do not intentionally collect information from children under the age of 13 or the minimum age set by Applicable Laws. We take steps to prevent children as defined above from signing up for BAGEL Services, and if we find that personal data has been collected from a child under the age of 13 in the course of providing services, we delete the data from our records and close the account. 🚫

4. Personal Data We Collect

In order to provide services to you, we collect the following personal data. We have organized it in a way that is easy for you to grasp, so feel easy to read on.🙂 (1) Personal data that you provide (i) To use BAGEL Services, you must provide your email address or phone number, zodiac sign, date of birth, and nickname. Your zodiac sign will be automatically generated based on your birth date, and you may change your nickname as you please at any time. If you do not want to provide the aforementioned personal data, please understand that your use of BAGEL Services may be restricted! (ii) Address book on your device. Bagel offers an Add Friends feature which provides an option to add other users as your friends in Bagel when you upload information of your friend in your address book on your device. We will access only the phone numbers registered in your mobile device’s address book when you have enabled this feature. We will use the phone numbers in your address book only for recommending possible friends, and preventing unauthorized use. (iii) Data for avatar creation: If you use our 3D avatar creation service, POP creation service, avatar call service, or other services that use facial or motion data, voice data, or photos or videos, we may collect such data. (iv) Location information: If you use our location sharing service, we may collect your location data. This allows you and your friends to share one another’s location. 🙋🌐 However, if you don’t want your whereabouts to be known, simply go to the settings of your device and turn off location sharing. No one can know where you are unless you want them to know. (v) Information needed to identify and contact you for customer service or events: If you contact us with an inquiry or apply for an event, we may ask for your information to verify your identity and contact you. (2) Information generated and collected during service use: Dates and times of your visits, as well as your records of fraudulent use, service use records, cookies, advertising identifiers, device information (type, model, OS version, app version, device identifier, language and country, and screen size), and network information (IP address)

5. Purposes of Personal Data Use

We never use your personal data that we obtain beyond the purposes and scope for which we obtained your consent, except as permitted by Applicable Laws. Specific uses of personal data are as follows: 📋 (1) Provision of BAGEL Services • Opening a BAGEL account, verifying age, identifying user • Providing various BAGEL Services features, such as messenger, 3D avatar services, location sharing, and post sharing • Sending messages, notifying of read ore response statuses of your messages and posts • Building and managing connections between users, by for example informing friends of activities searching for or recommending users • Customer support activities, such as handling inquiries and complaints and sending notices/notifications • Forwarding content or prizes if you participate in an event • Other purposes for providing BAGEL Services (2) Development and Improvement of BAGEL Services, New Services, and Content • Collecting service use statistics, creating models, and improving services • Identifying trends and developing of new services and content • Conducting surveys about services that are provided or considered for future provision • Other purposes for developing and improving services and content (3) Prevention of Improper Use • Monitoring, confirming, analyzing, preventing, and sanctioning violations of the Terms of Use, torts, unauthorized access, and other improper use • Developing improper use prevention tools • Discovering facts about confirmed or suspected improper use and contacting individuals involved • Other purposes for preventing improper use (4) Personalized Content and Ad Serving, and Marketing • Displaying our ads (including on third-party services; BAGEL does not display third-party ads within BAGEL Services.) • Displaying personalized content recommendations • Measuring the effectiveness of recommendations and ads served • Other purposes for personalized content and ads serving, and marketing

6. Personal Data Sharing

We may share your data as follows: (1) Share Data with Other BAGEL Users • Your nickname, date of birth, zodiac sign, and other information about you • Your location information. Only with users who are your friends, if you have expressly permitted such sharing • Information about your use of BAGEL Services, such as your sign-up date • Content that you send or post on Space. Your Space posts are visible only to your friends. • Other information you consent to sharing (2) Provide Personal Data to Third Parties We do not provide or disclose your personal data to third parties except with your consent or as permitted by Applicable Laws. (3) Subcontracting We may subcontract certain personal data processing tasks required for providing Bagel Services(e.g. service development, operation, and marketing, including ad performance measurement and optimization) to a subcontractor, including our subsidiaries and affiliates located in South Korea, Japan, and the US. Please see “Article 7. Cross-Border Data Transfer” below for current specific international data transfer information. You may rest assured that such subcontractors have access only to the minimum personal data necessary to handle it on our behalf and do not use it beyond the scope of subcontracting! We thoroughly screen subcontract candidates to ensure they abide by Applicable Laws and are qualified. We also ensure that our subcontract agreements state that personal data may not be processed for other purposes than those for subcontracting, as well as technical and administrative security measures and restrictions on re-outsourcing. In addition, we vigilantly manage and supervise our subcontractors to ensure their compliance with personal data related laws. Information on the personal data protection regimes of the countries or regions where the third parties mentioned above are located can be found at the links below: https://www.ppc.go.jp/files/pdf/california_report.pdf https://www.ppc.go.jp/files/pdf/USA_report.pdf https://www.ppc.go.jp/files/pdf/korea_report.pdf We may add other service providers, subsidiaries, or affiliates to whom we provide personal data if needed for the provision of BAGEL Services. If we add a third party located in country or region other than those mentioned above, we will inform you through this Policy! (4) Non-personal information. We may also share aggregated, non-personally identifiable, or de-identified information with third parties that provide services to us or perform business purposes for us.

7. Cross-Border Data Transfers

The following data is currently transferred overseas for the purpose of service provision. 📋 Please refer to Paragraph (3) Subcontracting under Article 6. Personal Data Sharing above for more details.

Receivers	Purposes	Data Type	Countries	Transfer Method
Affiliate	System development and maintenance for service provision	All data	South Korea	Standard contract terms
Affiliate	Operational tasks for service provision All data	All data	Japan	Standard contract terms
Cloud Storage Service Provider	Provision of cloud IT infrastructure	All data	US, Japan, South Korea	Standard contract terms
Marketing Measurement Partner	Measurement of the effect of advertisements, pixel tracking, targeting	Non-identifiable device information	US	Standard contract terms

8. Disclosure by You

You Space posts and others’ reactions and comments to them are visible only to your friends. Those who are not your friends cannot see them. One-on-one conversations are also limited to friends, but you may talk to those who are not your friends in a group chat. 💬 A word of caution here: the very nature of digital data makes it possible for recipients of such information to copy, store, or share it. This means that unintended audiences can receive and access it. If you don’t want your personal data to be widely available, pay close attention to what you write in your posts and the disclosure and audience settings! ⚠️

9. Personal Data Retention Period

We will destroy your personal data immediately once the purposes of its collection have been fulfilled and when there is no longer a legal basis for retaining it. 🗑 Please note that you may not sign up for BAGEL Services again within 30 days from your account cancellation, and all your personal data will be destroyed 30 days after your cancellation. Nonetheless, we may keep your personal data even after that period if permitted or required by Applicable Laws. Please rest assured that we will never use your personal data for purposes other than those stated in any case! We collect your location information to provide BAGEL’s location-based services, but we destroy such information after 90 days of collection without delay. However, if you share your location in a chat room or indicate it in a post or any other content on Space, that location data will be retained during the retention period of the message, post, or content. Besides, we may retain your location data for a certain minimum period of time to fulfill the purpose of its use if necessary to provide BAGEL’s location-based services.

10. Security Measures for Personal Data

At BAGEL Services, we value your account more than anything else. 🔐 In order to protect accounts from security risks or unauthorized use due to a password leak, BAGEL Services use one-time authentication codes as a login method rather than passwords. We have also put in place appropriate administrative and technical security measures to securely manage your personal data and protect it against leakage, loss, or damage in accordance with Applicable Laws. The security measures we are implementing include the following: (1) Administrative security measures: Operation of a personal data protection organization, establishment and execution of data protection and management plans, minimization of personal data handlers, regular training in personal data protection, etc. (2) Technical security measures: Encryption of sensitive personal data, encryption of communication channels, use of antivirus software, frequent backups, etc. (3) Physical security measures: Installation and operation of the system in an off-limits area with controlled access from the outside As much as we try, you do understand that no data transfer and storage methods are 100 percent foolproof, don’t you? So, your cooperation and understanding are essential to protecting your personal data and its confidentiality. If you suspect unauthorized use of your account or any other security breach, please contact us at support@bagel.com without delay.

11. Where We Store Your Persona Data

We store your personal data in data centers located in South Korea, Japan, and the US.

12. Your Rights

(1) You may demand access to your personal data that we retain (including the records of our provision of your personal data to third parties) and the purposes of our use of your personal data, corrections, additions, or deletions thereof, deletion of your personal data or cessation of use or provision to third parties of your personal data, to the extent permitted by Applicable Laws. We will promptly act upon such demand after verifying that the demand has indeed been made by you except as otherwise stipulated by Applicable Laws! (2) We strive to provide features allowing you to edit your own profile and set and manage personal data acquisition, use, and sharing options within BAGEL Services. The specific features that we currently provide are as follows: • Set and change your nickname (Settings > Nickname) • Delete a post on Space (click ‘...’ at the top right of the post > Delete) • Promotional email opt-in/opt-out setting (Settings > Receive BAGEL News) • Change your location data shared (Map > ghost icon in the upper right corner; There is another feature that can be used to allow or deny access to your location, though it is not provided by the BAGEL App. The feature is found in Home > Settings > Location > Bagel on Android, and in Home > Settings> Privacy & Security> Location Services> Bagel on iOS.) • Delete your account (Settings > Delete account) You may withdraw your consent to our collection and use of your personal data by deleting your account at any time. If you would like to access your personal data or the purposes of our use, or to correct, add, or delete inaccurate personal data, which is beyond your control on BAGEL Services, please contact us at support@bagel.com. Moreover, if you wish to exercise any of your rights recognized by Applicable Laws, feel free to contact us at any time. 📞 In the event you ask for the correction of an inaccuracy in a piece of your personal information, we will neither use it nor provide it to third parties until completion of the correction. If the incorrect information has already been provided to third parties, we will promptly notify them and ensure that they also make the correction as quickly as possible! (3) If you no longer wish to use BAGEL Services or if you wish to withdraw your consent to our processing of your personal data that is needed for the provision of BAGEL Services, you may delete your entire account. However, please understand that your withdrawal of the consent does not affect the lawfulness of our processing of your personal data based on your consent prior to the withdrawal.

13. Use of Third-Party Modules, Cookies, Etc.

We may use cookies, third-party software development kits (SDKs), or similar technologies to achieve the purposes stated in this Policy. (1) Third-Party Modules We may install SDKs and other modules provided by third parties within BAGEL Services for the following purposes: • To analyze the use of BAGEL Services • To display ads or measure their effectiveness on our behalf Please note that regarding your personal data that third parties handle through the modules that they provide, the privacy policies of those third parties will apply. (2) Cookies and Other Analytics Tools We may use cookies or similar web tracking technologies (web beacons, pixels, etc.) for the following purposes: • To remember login status, authenticate visitors, maintain sessions, and execute security measures • To improve convenience by remembering language and other settings, the date and time of your last visit, and so forth • To provide better services by identifying the number of your visits and your usage patterns • To serve ads that are more relevant and intriguing to you • To measure the effectiveness of ads You can control whether or not to accept cookies by changing your device’s settings. You can deny the use of cookies after going to “Home > Settings > Google > Ads > Opt out of Ads Personalization” on Android and “Home > Settings > Privacy > Tracking > Allow apps to request to track” on iOS. Please note, however, that if you deactivate or restrict cookies, you may not be able to experience the full benefit of personalized services, which may limit your overall user experience. (3) Information on the Use of Google Analytics We continually strive to improve BAGEL Services. To that end, we may use Google Analytics to measure BAGEL Services such as comprehending the status of use of BAGEL Services. In the process, Google may set cookies for data collection or read cookies, and the URLs, IP addresses, and other information of the webpages that you visit may be automatically sent to Google. To learn more about how Google processes data in Google Analytics, please read the Google Analytics Terms of Service and Google’s Privacy Policy. (4) Information on the Use of True Depth API, provided by Apple We genuinely hope that you have the best possible experiences with us at all times, and we will work hard to ensure that happens. We may use Apple’s TrueDepth camera to collect additional information from your device camera in order to improve the quality of the camera and video call that we provide, or improve functions such as effects. 📷 Such information is processed in real time for delivering and improving these features only. This information is not saved on our servers or shared with any third parties.

14. Contact Us

Except as otherwise provided in this Policy, we manage all personal data collected through BAGEL Services. Do you have any inquiries on this Policy? Or do you have any complaints, suggestions, or opinions about our handling of personal data? If so, please contact us at the email below. We are always ready to talk to you. 🥰 🗣️ Personal data processor (Data collector): Metascalecorp, Inc. Representative : CEO Seoung Jo Kwon Address: 400 Spectrum Center Dr. Suite 1900, Irvine, CA 92618, USA Email: support@bagel.com

15. Business Succession

In the event of a change in the corporate structure with respect to our BAGEL Services business, such as a merger, acquisition, or change in business entity, your personal data may be shared with or transferred to the successor before and after the conclusion of the deal to the extent permitted by Applicable Laws.

16. Amendment to This Policy

This Policy may be amended from time to time, and the latest version will always be posted on our website. 🖥️ If any significant change is made to this Policy, we will promptly inform you in the manner most easily and readily available to you, including posting it on the BAGEL website, emailing you, or making a notification within BAGEL Services. So, please don’t forget to always check out the latest version of this Policy. 😊 If you use BAGEL Services after notice or notification of a change to this Policy, it means that you have accepted the change and agree to be bound by the amended version of this Policy. Please note that we may seek your consent to certain changes if required by Applicable Laws!