Privacy Policy

totle Privacy Policy

This Policy (the "Policy") explains the way of treatment of the information which is provided or collected in the web sites on which this Policy is posted.

For the purpose of this Privacy Policy, the terms “Company”, “we”, “us”and “our” refer to e-glue Cloud. The terms “service” and “software” refers to our product “totle”. “Users” and “you” refers to you as a user of the service or visitor to the website, as applicable.

We do not give out any of your personal information to others, unless we have your specific permission to do so, or we are required by law or litigation to disclose your personal information. We may also find it necessary to disclose information about you if we determine that it is an issue concerning national security, law enforcement, or other issues of public importance.

This Privacy Policy is effective from June 13, 2022, and we reserve the right to change this policy, which we will do through posting on the website bulletin board or individual notice sent through mail or emails.

1. Information We Collect

We collect and use the following information to provide, improve, protect, and promote our Services:


Personal Information

We collect, and associate with your account, the information you provide to us when you do things; such as sign up for your account or upgrade to a paid plan:

  1. Registration Information: Name, email address, ID, national information, encoded identification information(CI), identification information overlapped membership (DI).
  2. Order and Payment Information: Name, address, phone number, payment information – including account number and card number.
  3. Organization and Receipt Confirmation Information: Name, job title, department, mail address, phone number, company telephone number, well as sender/receiver email address, and mail subject.

Device Information

  1. We collect information from and about the devices you use to access the Services. This includes things like IP addresses, operating system, the type of browser and device you use, the webpage you visited before coming to our sites, and identifiers associated with your devices.
  2. Your devices (depending on their settings) may also transmit location information to the Services. For example, we use device information to detect abuse and identify as well as troubleshoot bugs.

2. Use of Information

2.1. Purpose of Use

The Company uses collected information for sales, marketing, advertising, promotions, and similar purposes. Information is disclosed to affiliates, partners, and service providers for service execution with user consent or as required by law.

Such as:

  1. Member management and prevention of fraudulent use.
  2. Performance of contractual obligations and service fee settlements.
  3. Improvement and development of services
  4. Notification of policy changes and company site / application features
  5. Connection facilitation between users.
  6. Statistical analysis of service usage for improving and providing services.
  7. Promotional event information and participation opportunities.
  8. Compliance with applicable laws and legal obligations.

2.2. Lawful processing of personal information under GDPR

Processing of personal information by the Company is lawful based on GDPR conditions, including user content , contract performance, legal obligations, protection of vital interests, public interests, and legitimate interests in this Policy.

3.  Cookies and Other Technologies

The Company may collect collective and impersonal information through cookies and web beacons for service improvement and user experience enhancement. Various types of cookies we use, including:

  • Strictly Necessary Cookies: This cookie does not collect any information which may be used for marketing or memorizing the sites visited by the users. Unless the user allows this cookie, services such as online or electronic bill payment cannot be provided.
  • Performance Cookies: This cookie collects information on how the users use the website of the Company such as the information of the pages which are visited by the users most. This data helps the Company to optimize its website so that users can search that website more comfortably. This cookie does not collect any information about who are the users. Any and all information collected by this cookie will be processed collectively and anonymity will be guaranteed.
  • Functionality Cookies: This cookie is used for memorizing the set-ups so that the Company provides services and improves the visits of the users. Any information collected by this cookie does not identify the users individually.

4. Prohibited Content

  1. Users agree not to use the Service to upload any unlawful, harmful, defamatory, vulgar, obscene, pornographic, libelous, invasive of privacy or publicity rights, hateful, or racially, sexually, ethnically or objectionable content; as well as any content that contains software viruses, worms, trojan horses, time bombs, trapdoors, or any other computer code, files, or programs or repetitive requests for information designed to interrupt, destroy or limit the functionality of any computer software or hardware or telecommunications equipment or to diminish the quality of, interfere with the performance of, or impair the functionality of the Services. The Company reserves the right to delete such content without notice.

5. User's Right

  1. Users or their legal representatives may exercise rights regarding personal information, including access, correction, deletion, suspension of treatment, and withdrawal of consent. In order to exercise the right, user must contact the Company by sending a document or email, or dial the company contact number and the Company will take prompt measures. The Company may reject the request if there are proper cause suggested by the laws or equivalent cases.

6. Security

The company employs security measures, including encryption, hacking countermeasures, internal management plans, and access controls, to protect user information from unauthorized access or modification.

7. Measures for Data Stability

7.1. Regular self-audits

  1. Regular self-audit ensure stability in handling personal information

7.2. Employee Authorization and Education

  1. Limited employee access, password protection, and regular education for authorized personnel.

7.3. Internal Management Plan

  1. Establishment and implementation of an internal management plan for secure information processing.

7.4. Technical Countermeasures

  1. Security programs and regular inspections to prevent information leakage and damage.

7.5. Encryption of Personal Information

  1. Storage and management of encrypted passwords and important data.

7.6. Storage of Access Records

  1. Maintenance of access records for a minimum of two (2) years.

7.7. Restricting Access

  1. Measures to control access and prevent unauthorized access using intrusion prevention systems.

7.8. Document Security

  1. Secure storage of documents and storage media with personal information.

7.9. Access Control

  1. Restriction of access to unauthorized persons.

8. Changes to Privacy Protection Policy

  1. The Company reserves the right to amend or modify its security and data protection measures, provided this is necessary as a result of technical or legal developments. In these cases, we will also update our data protection information accordingly. Please make sure, therefore, that you always use the latest version of our data protection declaration. Notice will be provided through the website or individual channels, and user consent will be obtained if required by law.

9. Additional Information

9.1.    Data Transfer to Other Countries

In global operations, the Company may transfer user information to companies in other countries, ensuring compliance with relevant regulations and privacy standards.

Guide for Users Residing in the European Union (EU) or Switzerland: The Company complies with the US-EU Privacy Shield and Swiss-US Privacy Shield taking other measures or obtain consent from users when obtaining personal information.

Guide for Users Residing in California: California residents have specific rights, including the right to request information about personal information leakage and modify their information.

Guide for Users Residing in Korea: Additional information disclosure as per Korean information network laws and personal information protection laws. Personal Information to be collected:

a. InformationProvided by Users:

  1. Internet Membership Service: Name, email address, ID, national information, encoded identification information(CI), identification information of overlapped membership (DI). For minors, information of legal representatives (name, birth date, CI, and DI of legal representatives)
  2. Online Payment Service: Name, address, telephone number, and email address.

b. Information Collected During Service Usage

  1. Device & OS Information: Device identifier, operation system, hardware version, equipment set-up, type and set-up of the browser, use information of the website or application, and telephone number.
  2. Log Information: IP address, log data, use time, search words input by users, internet protocol address, cookie, and web beacon.
  3. Organization Information: Name, job title, department, mail address, phone number, company telephone number.
  4. Receipt Confirmation Information: Sender/receiver mail address, mail subject.

9.2. Period for Retention and Use of Personal Information

In principle, the Company destructs personal information of users without delay when:

a. The purpose of its collection and use has been achieved.

b. Legal or management needs are satisfied, or users request.

c. If retention is required by relevant laws, the Company will retain member information for a designated period:

  1. Record regarding contract or withdrawal of subscription: 5 years (The Act on Consumer Protection in Electronic Commerce)
  2. Record on payment and supply of goods: 5 years (The Act on Consumer Protection in Electronic Commerce)
  3. Record on consumer complaint or dispute treatment: 3 years (The Act on Consumer Protection in Electronic Commerce)
  4. Record on collection/process, and use of credit information: 3 years (The Act on Useand Protection of Credit Information)
  5. Record on sign/advertisement: 6 months (The Act on Consumer Protection in Electronic Commerce)
  6. Log record of users such as internet/data detecting the place of user connection: 3 months (The Protection of Communications Secrets Act)
  7. Other data for checking communication facts: 12 months (The Protection of Communications Secrets Act)

9.3. Procedure and Method of Destruction of Personal Information

In principle, the Company destructs information immediately after achieving its collection and use purposes. If retention is required by relevant laws:

  1. Hard copies of personal information are destroyed by shredding or incineration.
  2. Electronic files are deleted using technological methods to prevent restoration.

9.4. Technical, Managerial, and Physical Measures for Protection

a. Technical Measures

  1. Utilize security servers for transmitting encryption of personal information.
  2. Implement encryption for confidential information.
  3. Install and operate access control devices and equipment.
  4. Establish and execute an internal management plan.

b. Managerial Measures

  1. Appoint a member of staff responsible for protecting personal information.
  2. Provide education and training for staff treating personal information.
  3. Establish and execute an internal management plan.
  4. Establish rules for creating passwords that are hard to estimate.
  5. Ensure safe storage of records of access to the personal information processing system.
  6. Classify the level of authority to access the personal information processing system.

c. Physical Measures

  1. Establish and operate the procedure for access control for facilities storing personal information.
  2. Store documents and backing storage containing personal information in safe places with a locking device.

10. Protecting Your Information

  1. We take the security of your personal information very seriously and have implemented policies and procedures, including technical measures, that are designed to help safeguard it. While we strive to use best practices to protect your personal information, the Internet and computer technology are not 100% secure and we cannot absolutely ensure the security of any personal information that you provide to us.
  2. The Company designates the following Data Protection Officer (DPO) in order to protect the personal information of customers and deal with complaints from customers.
  3. If you do not want us to keep you up to date with our news, you are free to contact us at any time and have your email address removed from our mailing list. If you wish to update your information or have any comments or concerns about our Privacy Policy, please contact us at:

Company: e-glue Cloud

DPO of the Company: Sungha Kim (CMO)

Address: 9F, 38, Mapo-daero, Mapo-gu, Seoul, Republic of Korea

Tel: +82-70-4192-7522