RallyCat

Consent to Collection and Use of Personal Information

NeonPocket Co., Ltd. (the “Company”) collects and uses personal information as described below for membership registration, identity verification, provision of the RallyCat service, use of paid services, customer support, safe service operation, and compliance with applicable laws.

Members may refuse to consent to the collection and use of personal information. However, if a Member refuses to consent to the required items, membership registration or use of the RallyCat service may be restricted.

Optional items are collected and used only when a Member directly enters such information or uses the relevant function. Refusal to provide optional items will not restrict membership registration or basic use of the Service.

Article 1. Purpose of Collection and Use

The Company collects and uses personal information for the following purposes:

  1. 1. Membership registration and account creation

  2. 2. Member identification, login, account management, and user verification

  3. 3. Verification of whether the Member is 14 years of age or older and confirmation related to minors’ use

  4. 4. Provision and operation of the RallyCat service

  5. 5. Provision of service functions, including Creator profile browsing, content use, messages, chats, support, and donation-like features

  6. 6. Rally purchase, recharge, use, use of paid services, payment processing, refunds, and response to payment disputes

  7. 7. Customer inquiry handling, delivery of notices, and service-related guidance

  8. 8. Reporting, blocking, sanctions, verification of Operation Policy violations, and creation of a safe service environment

  9. 9. Prevention of abuse, including fraudulent registration, fraudulent payment, account theft, service abuse, and inducement of external transactions

  10. 10. Service quality improvement, error checking, statistical analysis, and analysis of usage patterns

  11. 11. Personalized recommendations, content recommendations, Creator recommendations, fan relationship analysis, monetization setup assistance, operational efficiency, and service improvement using AI, algorithms, statistical analysis, or automated technologies

  12. 12. Compliance with legal obligations and dispute response

The Company may analyze Members’ service usage records, profile information, content usage information, Rally purchase and usage records, and other related information to provide personalized content and Creator recommendations, fan relationship analysis information, Creator monetization setup assistance, and operational efficiency improvements. Such use is intended to improve the Service and enhance user experience.

Members may change settings related to personalized recommendations or data use through settings menus provided by the Company, the customer center, or any other method designated by the Company.

Article 2. Personal Information Collected and Used

The Company may collect and use the following personal information to provide the Service.

  1. 1. Membership Registration and Account Management Information

  2. 2. Required Items

  • - Email address or mobile phone number

  • - Password or authentication information

  • - Confirmation of being 14 years of age or older

  • - Account ID or Member identifier

  1. 1. Optional Items

  • - Nickname

  • - Profile image

  • - Registration source

  1. 1. Items Collected When Using the Relevant Function

  • - Social login identifier

  • - Country and language settings

Optional items are collected only when a Member directly enters such information or uses the relevant function. Refusal to provide optional items will not restrict membership registration or basic use of the Service.

  1. 1. Additional Items Collected When Using Paid Services

When a Member purchases, recharges, or uses Rally or uses Paid Services, the Company may additionally collect and use the following information:

  1. 1. Confirmation of being 19 years of age or older

  2. 2. Confirmation information regarding legal guardian consent

  3. 3. Records of Rally purchase, recharge, use, and expiration

  4. 4. Records of paid content use

  5. 5. Records of paid messages, chats, support, and donation-like feature use

  6. 6. Payment amount, payment date and time, payment status, and payment method information

  7. 7. Payment approval number, transaction identifier, and receipt information

  8. 8. Refund, cancellation, and dispute handling records

  9. 9. Payment-related identifiers provided through app markets or payment service providers

The Company may not directly store full payment method information, such as full credit card numbers or bank account numbers. Payment processing may be handled in accordance with the policies and procedures of external payment service providers, including app markets, payment agencies, and overseas payment service providers.

  1. Information Generated or Collected During Service Use

The following information may be automatically generated or collected during the use of the Service:

  1. Service usage records

  2. Access date and time

  3. IP address

  4. Device information

  5. OS information

  6. App version

  7. Access country

  8. Cookies or similar identifiers

  9. Event logs

  10. In-service activity records, including clicks, views, messages, chats, content use, and Rally use

  11. Reporting, blocking, sanction, inquiry, and handling records

  12. Customer Support and Inquiry Handling Information

When a Member contacts the Company or uses customer support, the Company may collect and use the following information:

  1. Inquiry details

  2. Response and consultation records

  3. Attached files

  4. Information necessary for response, such as email address or contact information

  5. Materials related to errors, inconvenience, or disputes arising during service use

  6. Information That May Be Additionally Collected When Applying for Creator Account Conversion

When a Member applies for Creator account conversion, the Company may additionally collect and use the following information for review and account conversion:

  1. Representative channel information

  2. SNS or external platform links

  3. Activity name or Creator name

  4. Content field and activity details

  5. Submitted materials and review-related information

  6. Information requested by the Company for Creator account conversion review

However, detailed information required for Creator monetization, settlement, tax processing, identity verification, ID document verification, legal guardian consent, and settlement account information shall be collected and used through separate consent at the Creator account conversion or monetization feature use stage.

Article 3. Retention and Use Period of Personal Information

The Company retains and uses personal information until the purpose of collection and use is achieved, and destroys it without delay upon membership withdrawal or withdrawal of consent. However, information required to be retained under applicable laws or information that needs to be retained for a certain period for the Company’s legitimate interests may be retained for the following periods:

  1. Membership registration and account management information: Until membership withdrawal

  2. Service usage records: Until membership withdrawal or achievement of the purpose of collection and use

  3. Payment, Rally, Paid Service, refund, and cancellation records: Until the statutory retention period or the period necessary for dispute response, up to 5 years

  4. Reporting, blocking, sanction, and Operation Policy violation records: For the period necessary for service safety, prevention of abuse, and dispute response, up to 3 years

  5. Customer inquiry and consultation records: For the period necessary for dispute response after completion of inquiry handling, up to 3 years

  6. Records related to fraudulent registration, account theft, fraudulent payment, or service abuse: For the period necessary to restrict re-registration, prevent abuse, and ensure service safety, up to 5 years

  7. Information required to be retained under applicable laws: For the period prescribed by such laws

The Company may retain the following information for a certain period in accordance with applicable laws:

  1. Records of contracts or withdrawal of offer: 5 years

  2. Records of payment and supply of goods or services: 5 years

  3. Records of consumer complaints or dispute handling: 3 years

  4. Records of labeling and advertising: 6 months

  5. Service visit or login records: 3 months

  6. Books and supporting documents related to transactions, including tax invoices: 5 years

The Company destroys personal information without delay when the retention period expires or the processing purpose is achieved. However, where retention is required under other laws, the relevant information shall be stored separately.

Article 4. Provision of Personal Information to Third Parties

The Company does not, in principle, provide Members’ personal information to external parties.

If the Company provides a Member’s personal information to a third party, the Company shall, in principle, notify the Member in advance of the recipient, purpose of provision, items provided, and retention and use period, and obtain separate consent from the Member.

However, personal information may be provided without separate consent in the following exceptional cases prescribed by applicable laws:

  1. Where submission is requested by an institution with lawful authority, such as an investigative agency, court, or supervisory authority, in accordance with applicable laws

  2. Where applicable laws separately require or permit the provision of personal information

  3. Where it is urgently necessary to protect the life, body, or property interests of the Member and it is difficult to obtain the Member’s consent

Article 5. Entrustment of Personal Information Processing

The Company may entrust part of its personal information processing tasks to external service providers for smooth provision of the Service.

Entrusted tasks may include the following:

  1. Service operation and infrastructure provision

  2. Data storage and cloud server operation

  3. Payment processing and refund processing

  4. App market payment verification

  5. Overseas payment processing, refund processing, and payment dispute response

  6. Identity verification and authentication

  7. Sending notifications, emails, text messages, and app push notifications

  8. Customer support and inquiry management

  9. Data analysis, error analysis, and service quality improvement

  10. Detection of abuse, fraudulent payment, and abnormal transactions

  11. Security management

Where personal information processing is entrusted, the Company shall disclose the entrusted party and details of the entrusted tasks in the Privacy Policy.

Article 6. Overseas Transfer of Personal Information

For global service provision, use of cloud infrastructure, app market payment verification, overseas payment processing, refund processing, fraudulent payment detection, payment dispute response, notification delivery, customer support, data analysis, and other purposes, personal information may be transferred overseas or processed overseas.

Where overseas transfer of personal information occurs, the Company shall provide information on the recipient, destination country, transferred items, purpose of transfer, retention and use period, method of refusing the transfer, and disadvantages resulting from refusal through the Privacy Policy or a separate consent procedure.

Specific details, including the destination country, recipient, transferred items, purpose of transfer, timing and method of transfer, retention and use period, and information related to the personal information protection system of the destination country, may be found in the Company’s Privacy Policy.

Members may refuse overseas transfer of personal information in accordance with applicable laws. However, overseas transfer may be necessary for service provision, including global service provision, cloud infrastructure operation, app market payment verification, overseas payment processing, refund processing, fraudulent payment detection, payment dispute response, notification delivery, customer support, and data analysis. Therefore, if a Member refuses overseas transfer, membership registration, payment, refund, or use of certain services may be restricted.

Article 7. Use of Data-based Features and Automated Technologies

The Company may use AI, algorithms, statistical analysis, or automated technologies for service provision, quality improvement, personalized recommendations, Creator monetization support, fan relationship analysis, content recommendations, prevention of abuse, and creation of a safe service environment.

The Company may analyze the following information within the scope prescribed by applicable laws and the Privacy Policy:

  1. Member service usage records

  2. Profile information

  3. Content usage information

  4. Rally purchase and usage records

  5. Interaction records, including messages and chats

  6. Reporting, blocking, and sanction records

  7. Device and access information

  8. Creator account conversion application and activity information

Data-based features, recommendations, analysis, predictions, monetization setup assistance, and operational suggestions provided by the Company are reference information intended to assist Members’ decision-making and do not guarantee any specific revenue, fan inflow, payment occurrence, content sales, increased exposure, or Creator performance.

Members may change settings related to personalized recommendations or data use through settings menus provided by the Company, the customer center, or any other method designated by the Company.

If the Company uses Member Content or personal information for purposes beyond the scope of original service provision, such as AI model training, the Company shall obtain separate consent in accordance with applicable laws or establish an appropriate legal basis, and clearly provide necessary information through the Privacy Policy or AI Feature Policy.

Article 8. Processing of Personal Information of Children Under the Age of 14

  1. The Company does not allow children under the age of 14 to register as Members and does not intentionally collect personal information of children under the age of 14.

  2. If it is confirmed that personal information of a child under the age of 14 has been collected despite the procedures operated by the Company, the Company shall destroy such personal information without delay and restrict use of the relevant Account.

  3. If a legal guardian becomes aware that a child under the age of 14 has provided personal information to the Company, the legal guardian may request access, correction, or deletion of such information through the Company’s customer center.

Article 9. Rights of Data Subjects

Members may request access, correction, deletion, suspension of processing, withdrawal of consent, and other rights regarding their personal information at any time.

Upon receiving a Member’s request, the Company shall take necessary measures without delay in accordance with applicable laws. However, some requests may be restricted where retention is required under applicable laws or where necessary for service operation, dispute response, or prevention of abuse.

Members may directly access, correct, withdraw consent, or withdraw membership through [Settings > Account Management] within the Service. Other rights requests, inquiries, or complaints may be submitted through the Company’s customer center or the contact information stated in the Privacy Policy.

Article 10. Right to Refuse Consent and Disadvantages of Refusal

Members have the right to refuse consent to the collection and use of personal information.

The personal information marked as required in Article 2 is necessary for membership registration and provision of the basic RallyCat service. Therefore, if a Member does not consent to the collection and use of required items, membership registration or use of the Service may be restricted.

Optional items are collected and used only when a Member directly enters such information or uses the relevant function. Refusal to provide optional items will not restrict membership registration or basic use of the Service.

Article 11. Relationship with the Privacy Policy

Details concerning the processing of personal information not specified in this Consent shall be governed by the Company’s Privacy Policy.

The Company’s Privacy Policy may be accessed through [Settings > Privacy Policy] within the Service or through any other route designated by the Company.

[Addendum]

This Consent shall take effect on June 1, 2026.

Version: v2.0