Privacy Policy

Initial Effective Date: [01/01], 2026

Last Amendment Date: [01/01], 2026

GOLFZON Co.,Ltd. and its subsidiaries and affiliates (“GOLFZON,” “we,” “us,” or “our”) consider the protection of your personal information very important. This Privacy Policy provides information on the personal information we collect and how we process and use the information.

By signing this privacy policy, you as the data subject (i) understand and agree to the terms and conditions of this Privacy Policy and (ii) understand and agree to grant your free, voluntary and unconditional consent for Golfzon and their third parties (as defined below) to process your personal data to the extent permitted by laws and under this privacy policy.

We have implemented all protective measures required by law to ensure that your personal information is handled safely.

1. Scope of Application of This Privacy Policy

This Privacy Policy applies only to websites operated and provided by GOLFZON where this Privacy Policy is posted and services provided through the GOLFZON mobile application (our “Services”).

2. Collected Information (Categories and Sources of Personal Information)

We collect several types of personal information from you.

At GOLFZON, personal information is deemed to include not only email addresses and other information on the individual, but also personal or important matters that identify or can identify the individual (e.g., IDs and passwords related to our Services, nicknames, gender, age, cell phone numbers, and other information that can identify specific individuals). We may collect the following information:

If you contact us, your ID and password, nickname, email address, date of birth, and mobile phone number related to our Services;

Your internet protocol (IP) address, which is the number that allows devices connected to the internet to know where to send data, such as the web page you see;

If you participate in an event described in Article 1, your name, date of birth, email address, and/or telephone number.

In addition, GOLFZON can collect information on circumstances related to access to our Services and how they are used. This includes the following information:

Device information;

Location information;

Log information;

Cookies and anonymous IDs.

3. Cookies

We use cookies in our Services. Cookies are small text files that are used to collect information about your activities within our Services and to help you use our Services as conveniently as possible. For example, when a user visits a web page within our Services, cookies are stored on the user’s device (if the user accepts the cookies), or if the user has previously accessed our Services, the cookies are read. These cookies allow us to collect information, including user IDs, app versions, operating systems, device names, and error codes.

If you want to opt out (reject receipt) from a specific device that accesses this Privacy Policy, please go to (need to add the relevant website). On most browsers, you may choose to display notifications when cookies are received or block cookies. However, if cookies are blocked, the personalized functions enjoyed by other service users may not be used. Some of the cookies we use may be Adobe or “flash” cookies and may not be deleted when deleting other cookies. To delete these types of cookies, please check your system requirements.

The following applies to residents of the European Economic Area and the United Kingdom:

We process cookies (except for absolutely necessary cookies) as well as your personal information obtained through cookies for the purposes set forth in Article 5 based on your consent. You may withdraw your consent to this processing at any time. A withdrawal does not affect the legality of any processing performed before you withdrew your consent.

4. Cookies and Other Tracking Tools from Third-Party Providers

We use the following cookies:

Google Analytics

Google Analytics, a web analytics service provided by Google LLC (“Google”), collects anonymous statistical and analytic information about how our users use our Services. For example, Google collects and aggregates page views and click count data for our Services. This analysis will not be used to track your other website movements or to identify you. Information created by Google Analytics’ cookies about your use of the Services (including your IP address) is sent by Google to a server in the U.S. for storage.

You can find more information about Google’s Privacy Policy below.

https://policies.google.com/privacy

5. Use of Personal Information

We may process your personal information for the purposes detailed below:

policies

If we are required to process your personal information for any purpose not specified in this Privacy Policy, we will inform you accordingly and seek your consent if necessary.If we are required to process your personal information for any purpose not specified in this Privacy Policy, we will inform you accordingly and seek your consent if necessary.

The following applies to residents of the European Economic Area and the United Kingdom:

We always process your personal information based on one of the legal grounds set out in the GDPR (Articles 6 and 7). We process your personal information for the purposes set forth in the preceding paragraph on the basis of the following legal grounds:

(1) Performance of Contracts (GDPR Article 6(1)(b))

We process your personal information for the following purposes as necessary to take action at the request of the data subject before performing or executing a contract:

Provision of Services related to content transmission such as games, videos, music, etc.;

Contact and communication with you to respond to your inquiries and complaints;

Completion of transactions or Services requested by you;

Notice of changes to this Privacy Policy or the terms and conditions of use, if necessary;

Authorization of access to access-restricted areas of our Services;

Settlement of disputes with you;

(2) Legitimate Interests (GDPR Article 6(1)(f))

We process your personal information for the following purposes as necessary to pursue legitimate interests (GDPR Article 6(1)(f)):

Service development, statistics, analysis, surveys, and other marketing activities to improve our Services;

Achievement of marketing or promotional objectives;

Verification of whether our Services meet your needs;

Help to create and release content that is best suited for you;

Sharing of personal information with promoters holding e-sports events related to the Services detailed in Article 6. Disclosure to Third Parties;

Processing of cookies that are absolutely necessary;

(3) Consent (GDPR Article 6(1)(a))

We process your personal information based on your consent (GDPR Article 6(1)(a)) for the following purposes:

Processing of cookies (except for absolutely necessary cookies) and personal information obtained through such cookies;

Upon your request or your consent to our information transmission, provision of special information, up-to-date information, and other new Services or delivery of promotional materials from GOLFZON or other third parties;

Provision of newsletters or other information you request.

The provision of personal information described in Paragraph 2 above (other than cookies that are not absolutely necessary) is an essential condition for providing our Services and we may not provide our Services to you if you do not provide such personal information.

For California residents, the following information is also provided:

We may have collected the following categories of information from or about you during the previous 12 months:

Identifiers (which may include names, aliases, mailing addresses, unique personal identifiers, online identifiers, internet protocol addresses, email addresses, account names, or other similar identifiers):

Sources: (1) Information directly obtained from you, (2) information indirectly obtained from you (e.g., observation of the user’s activities on our Services), and (3) third-party service providers such as data analytics providers;

Purpose: To fulfill or satisfy the reasons why you provided the information (e.g., responding to inquiries, promoting contests or new products, processing orders, fulfilling promotional conditions, and evaluating the effectiveness of advertisements);

Disclosure to third parties: Subjects of disclosure for business purposes (internet service providers, payment processing companies, cloud service providers, and promoters holding e-sports events related to the Services detailed in Article 6. Disclosure to Third Parties below);

The categories of personal information included in customer records (which may include names, signatures, addresses, telephone numbers, and bank account numbers):

Source: Information directly obtained from you;

Purpose: To fulfill or satisfy the reasons why you provided the information (e.g., responding to inquiries related to the Services, fulfilling promotional conditions, and evaluating the effectiveness of advertisements);

Disclosure to third parties: Subjects of disclosure for business purposes (internet service providers, payment processing companies, promotion co-sponsors, cloud service providers, and delivery companies);

Commercial information (which may include records of personal property, products or Services purchased, acquired, or reviewed, or other purchase or consumption history or trends);

Source: Information directly obtained from you;

Purpose: To fulfill or satisfy the reasons why you provided the information (e.g., responding to inquiries, processing orders, and evaluating the effectiveness of advertisements);

Disclosure to third parties: Subjects of disclosure for business purposes (internet service providers, payment processing companies, promotion co-sponsors, and promoters holding e-sports events related to the Services detailed in Article 6. Disclosure to Third Parties below);

Internet or other similar network activities (which may include inquiry records, search records, and information on interactions between consumers and websites, applications, or advertisements):

Sources: (1) Information indirectly obtained from you (e.g., observation of the user’s activities on our Services) and (2) third-party service providers such as data analysis providers;

Purpose: To fulfill or satisfy the reasons why you provided the information (e.g., providing targeted advertising and evaluating the effectiveness of advertising);

Disclosure to third parties: Subjects of disclosure for business purposes (internet service providers, cloud service providers, etc., and promoters holding e-sports events related to the Services detailed in Article 6. Disclosure to Third Parties below);

Geographic location data (which may include physical location):

Sources: (1) Information directly obtained from you and (2) information indirectly obtained from you (e.g., observation of the user’s activities on our Services);

Purpose: To fulfill or satisfy the reasons why you provided the information (e.g., responding to inquiries, processing orders, providing targeted advertisements, and evaluating the effectiveness of advertisements);

Disclosure to third parties: Subjects of disclosure for business purposes (internet service providers);

Other inferences drawn from personal information (which may include profiles reflecting individual preferences, characteristics, psychological trends, tendencies, behaviors, attitudes, intelligence, abilities, and aptitudes):

Sources: (1) Information indirectly obtained from you (e.g., observation of the user’s activities on our Services) and (2) third-party service providers such as data analysis providers;

Purpose: To fulfill or satisfy the reasons why you provided the information (e.g., providing targeted advertising, managing services, maintaining and analyzing data, and evaluating the effectiveness of advertising);

Disclosure to third parties: (1) Subjects of disclosure for marketing purposes (independent contractors) and (2) subjects of disclosure for business purposes (promoters holding e-sports events related to the Services detailed in Article 6. Disclosure to Third Parties below).

6. Disclosure to Third Parties

We may share or disclose your personal information set forth in Article 2 with third parties to the extent permitted herein and by laws. To clarify, third parties include Google Google LLC as a web analytics service provider, Amazon Web Services as data storage and management service provider, internet service providers, payment processing companies, cloud service providers, and promoters holding e-sports events, similar to those mentioned in clause on California market. Personal information disclosed to a third party may be used by the third party only for the purposes set forth below, and such third party may use the personal information only for the period necessary to accomplish such purposes:

Performance of Services. For example, if you choose to participate in a game or Service on the Services, we may share your personal information to provide the Services. In addition, if you participate in a prize event or contest, we may use your personal information to fulfill the terms of the promotion. This means, for example, that information can be shared for the purpose of shipping products, including sharing your mailing address with a post office or delivery company. We may also share your information with the co-sponsor of the promotion;

Storage and Management of Data on Servers. We may transfer your personal information to Amazon Web Services, Inc. and other cloud service providers;

Evaluation of Advertising Effects. We may transfer your personal information to companies as set forth in Article 4 (Cookies and Other Tracking Tools of Third-Party Providers);

Processing and Fulfillment of Orders, Provision of Customer Services, Maintenance and Analysis of Data, Transmission of Customer Communications, Recruitment of Participants in Contests, Prize Events, and Other Promotions, Selection of Winners, and Provision of Products. Delegated third parties, including unaffiliated third-party service providers such as shipping companies, agencies, and independent contractors, will support the maintenance of our Services and handle such information in the form of providing other administrative services to us. When delegating a third party to process some or all of the personal information, GOLFZON shall enter into a non-disclosure agreement and other agreements for the protection of personal information with the delegated third party, and request consent to the terms and conditions and agreements to safely manage the personal information. Third-party service providers that assist us in managing our Services may access users’ personal information. If you do not want unaffiliated third-party service providers to access your information, please do not register or submit your personal information to us;

Compliance with Laws and Regulations. We may share personal information if necessary or in the good faith belief that such action is required pursuant to a requirement of law, a legally binding court order, or a governmental order of an investigative agency or competent regulatory body issued through due process of law. Golfzon could keep wordings as it is for now and if the competent authority challenges it later, we may revise to make it compliance with the applicable laws at that time (LOPDP 2025 or Decree 13).

Disclosure to Third Parties as Part of Corporate Reorganization Proceedings, Including (But Not Limited to) Mergers, Acquisitions, and the Sale of All or Substantially All of Our Assets.

7. Security

While we implement reasonable and appropriate technical and organizational measures to safeguard your personal data, you acknowledge that data transmission over the internet inherently carries risks and cannot be guaranteed to be 100% secure due to unexpectedly objective events.

Accordingly, both parties share responsibility for protecting data: we commit to maintaining security standards in accordance with applicable laws and industry practices, and you agree to exercise caution when transmitting personal information.

In the unlikely event of data being compromised due to factors beyond our control, we will take prompt remedial actions and notify affected individuals as required by law. However, we cannot be held liable for damages arising from transmission vulnerabilities unless caused by our proven negligence or breach of duty. GOLFZON designates rules for the protection of personal information and adopts appropriate management, technical, organizational, and physical security measures as required by applicable regulations. We use firewalls to protect your information from unauthorized access, disclosure, alteration, or destruction. However, no assurance can be given that the aforementioned firewall or security server software will completely prevent the access, disclosure, alteration, or destruction of the information.

We may attempt to notify you electronically to take appropriate protective measures if we become aware of the destruction of the security system. You agree that by using our Services or providing personal information to us, we may communicate with you electronically regarding security, privacy, and management issues related to the use of our Services. We may post notices within our Services in the event of a security breach. We may also email you at the email address you provided in these circumstances.

8. Access, Transfer, and Correction of Personal Information

You may use the contact details in Article 21 to view and request the correction or transmission of information about you in our possession or object to the processing of data related to you. If we receive a request from you to inspect, transmit, correct, add, or delete personal information or if you object to the processing of your personal information due to incorrect personal information (“Correction”), GOLFZON shall conduct all necessary investigations without undue delay and provide your personal information to you or a designated third party and make the Correction as soon as possible.

The following applies to residents of the European Economic Area and the United Kingdom:

If certain conditions are met, you may be provided with personal information about you in structured, commonly used, machine-readable format, and may transfer the data to another data controller without hindrance from us (GDPR Article 20).

The following applies to California residents:

In accordance with California Civil Code Section 1798.83, California residents may request certain information regarding the disclosure of personal information to third parties for direct marketing purposes. We do not share personal information for the direct marketing purposes of third parties.

You have the right to know and read the categories of personal information we collect about you and the specific information, as well as the categories of sources from which we collect such information, the purpose for which we collect the information, and the categories of third parties to which we share such information. You also have the right to know if we have sold or disclosed your personal information. You may request a copy of the personal information we collect and we will provide you with this information in electronic form upon request.

You may request information about whether we have sold or disclosed your personal information to third parties for business.

California residents have the right not to be discriminated against for exercising these rights. To exercise one or more of these California residents’ rights, please contact us using the contact information described in Article 21. You may also designate an authorized representative registered with the California Secretary of State to make a request on your behalf. The authorized representative must have written authorization to submit the request on your behalf. At any time that we are able to verify, we will compare the identifying information you provide with the personal information we already have. However, if we cannot verify your identity with the information we already have, we may request additional information.

9. Discontinuance of Processing of Personal Information and Deletion

You may use the contact details in Article 21 to request the discontinuance of processing and/or deletion of personal information about you in our possession. In the event that a request is made for the deletion or destruction of personal information (“Discontinuance of Processing”) on the grounds that the personal information is processed in a manner beyond the purpose of collection or is acquired by deceit or other unlawful means, GOLFZON shall, upon confirmation that the requested user is an identified individual, conduct all necessary investigations without undue delay and, in accordance with the result, discontinue the processing of the personal information free of charge to the extent possible by GOLFZON and notify you thereof. However, we may retain copies of your personal information if required or permitted by law and we may, therefore, inform the data subjects accordingly.

We will destroy your personal information without delay as soon as the purpose of collection/use of the personal information is achieved. However, certain information that must be retained for a legally prescribed period of time will be destroyed after the expiration of that period. In such cases, personal information stored separately will not be used for any other purpose unless provided by law.

For electronic data files, we destroy them using technical methods so that they cannot be restored or reconstructed. Printed copies and paper documents are destroyed through incineration or shredding.

The following applies to European Economic Areas and UK residents:

Rectification or Erasure of Personal Information: You may require us to rectify inaccurate personal information about you without undue delay and complete incomplete personal information (GDPR Article 16). You may also require us to erase personal information about you without undue delay if certain conditions are met (GDPR Article 17);

Restriction of Processing of Personal Information: You may require us to restrict the processing of personal information about you if certain conditions are met (GDPR Article 18);

Objection to Processing of Personal Information: You may object to the processing of your personal information if certain conditions are met (GDPR Article 21);

No Subjection to Automated Decision-Making: You have the right not to be subject to automated decision-making (including profiling) based solely on data that would have a legal or similar material impact on you if certain conditions are met (GDPR Article 22).

The following applies to California residents:

You may refuse the sale of your personal information to third parties. We do not currently sell your personal information.

You may also request the deletion of your personal information, subject to certain legal exceptions.

10. Account Information

Access to your account information and our Services can only be done through individual user IDs and passwords. To protect the confidentiality of your personal information, please keep your password confidential and do not disclose it to anyone else. We do not ask you to disclose your password by telephone or email. GOLFZON is not responsible for any actions taken in connection with your account while your account is logged in with your user ID and password.

11. Delivery of Information Related to the Services

We may also transmit information or data related to our Services, including (but not limited to) (i) notices of use of our Services, including notices of violations of use, (ii) updates, and (iii) information or data regarding the transactions, products, and/or Services that you may have purchased or elected.

12. Retention Period

We do not hold your personal information for more than the time required to achieve the purpose of collection unless there are other legal grounds (e.g., performance of legal obligations). After that period, we will delete your personal information. Each retention period depends on the type of personal information and the purpose for which it is processed.

13. Transfer of Information Overseas

If you provide us with your personal information, the information will be stored in Japan. GOLFZON may, in accordance with applicable laws and regulations relating to the transfer of personal information abroad, transmit such information to our subsidiaries, affiliates, and other third parties described in Article 6 located elsewhere than in the territory in which you reside (by any means, including by transmitting or allowing access to the information). Such personal information may be processed by the relevant party for the period of time necessary to fulfill the purposes set forth in Article 6.

The following applies to residents of the European Economic Area and the United Kingdom:

We share or disclose your personal information with a third country based on the adequacy decision (GDPR Article 45) once adequacy is decided for the third country. If no adequacy decision has been made for the third country, we will share or disclose your personal information to the third country by signing a standard personal information protection clause (GDPR Article 46(2)(c) and (5)) approved by the European Commission with the transferee.

14. Public Posting Areas

Any internet user can use the information contained in the message you post in public posting areas. For example, if you do not want your email address to be known, please do not include that address in your publicly posted messages. Please pay special attention when disclosing information in public posting areas. We are not responsible for the use by others of the information you disclose in chat rooms, forums, and other public posting areas.

15. Push Notifications

From time to time, we may send push notifications to you through mobile applications to send game updates and other notifications related to the Services that may be important to you. You may refuse to receive this type of notification by removing push notifications from the device settings at any time.

16. Third-Party Services

This Privacy Policy applies only to information collected from our Services. Our Services may include links to other web services. We are not responsible for the privacy practices or content of these other web services.

17. Changes to This Privacy Policy

We may change this Privacy Policy from time to time. In the event of a change, we will also change the date of the “Last Amendment Date” set forth at the top of this Privacy Policy. For some changes to this Privacy Policy, we may seek your consent by giving notice within our Services prior to implementing the changes. Continued use of our Services after such notice shall be deemed to agree with such change unless otherwise specified. We do not substitute your consent to the processing of personal information with your consent to this Privacy Policy. However, to the extent that such processing is permitted under applicable law, your personal information may be processed without your consent.

18. Online Tracking

Certain web browsers and other programs may be used to indicate to us whether information related to your online activities is collectible by us or third parties, or your intent with respect to how information is collected. GOLFZON does not support Do Not Track (DNT) browser settings because there is still no generally accepted standard for how to respond to the expression of DNT and GOLFZON is not currently participating in the DNT framework that allows you to respond to any expression of intent or other mechanism received from you regarding the collection of personal or non-personal information.

19. Our Child-Related Policy

We will not knowingly collect or request personal information from children under the age of 13 and will not knowingly allow such users to use our Services. If you are under the age of 13, please do not send us any information about yourself, including your name, address, telephone number, or email address. No one under the age of 13 can provide personal information. If we learn that we have collected personal information from children under the age of 13, we will delete the information as soon as possible. If you believe that we have collected information from, or may have information related to, children under the age of 13, please contact us using an online form

20. Right to Complaint

You may file a complaint with the local data protection authorities if you do not like how we process your personal information.

21. Inquiries

If you have any questions about this Privacy Policy, our privacy practices, or the information, correction, blocking, or deletion of data, please contact us using an online form