SneakyEffective
Privacy Policy
Under Article 30 of the Korean Personal Information Protection Act, PioneerY discloses in this Privacy Policy the purposes, items, retention periods, destruction, and privacy officer for the personal information it processes.
English translation
This English version is provided for convenience. If it differs from the Korean version, the Korean version applies.
Camera video
Face and gesture recognition in the game is processed only on the buyer's device. The Seller does not collect or store webcam video, face data, or gesture data on any server.
01Purposes of processing personal information
The Seller processes personal information only for the following purposes.
- To send the license key and download instructions by email
- To confirm payments, manage orders, and handle withdrawals, cancellations, and refunds
- To answer customer inquiries
- To keep the transaction records that the E-Commerce Act requires
No member accounts are created. If the purposes change, the Seller announces it first and obtains any consent the law requires.
02Personal information processed
Only the items needed for purchases and customer support are processed.
| Category | Items |
|---|---|
| Purchase | Email address, chosen platform (Windows or Mac), payment date and time, amount paid, order number |
| Withdrawal, refunds, inquiries | Details of the request, the email address or phone number used to contact us |
| Security logs | Access time, IP address, browser type. Only when the hosting server keeps them for security. |
Payment details such as card numbers, account numbers, and passwords are processed directly by the payment service provider. The Seller does not collect or store them.
Not processed: webcam video, face recognition results, gesture recognition results, resident registration numbers, sensitive information, account passwords.
Videos that buyers share directly to TikTok or Instagram are governed by those services' policies. The Seller does not receive them.
03Processing and retention periods
Personal information is destroyed without delay once its purpose is achieved. The records below are kept for the periods set by Article 6 of the Enforcement Decree of the E-Commerce Act and then destroyed.
| Record | Retention period | Legal basis |
|---|---|---|
| Records of contracts or withdrawals | 5 years | Enforcement Decree of the E-Commerce Consumer Protection Act, Art. 6 |
| Records of payment and delivery of goods | 5 years | Enforcement Decree of the E-Commerce Consumer Protection Act, Art. 6 |
| Records of consumer complaints or dispute handling | 3 years | Enforcement Decree of the E-Commerce Consumer Protection Act, Art. 6 |
| Records of labeling and advertising | 6 months | Enforcement Decree of the E-Commerce Consumer Protection Act, Art. 6 |
Security logs, if kept, are retained only as long as needed for security checks and never longer than 3 months.
04Provision to third parties
The Seller does not sell personal information and does not provide it to third parties outside the purposes of processing.
Where an investigative agency makes a lawful request under the law, information may be provided within that scope, after the basis and scope of the request are checked.
05Destruction procedure and method
- When the retention period ends or the purpose is achieved, information to be destroyed is separated from information to be kept and deleted without delay.
- Electronic files are deleted in a way that cannot be recovered.
- Printed information is shredded or incinerated.
- Information kept under the law is stored separately from other personal information and destroyed in the same way when its retention period ends.
06Entrustment of processing
The tasks below may be entrusted to outside providers to process purchases smoothly. Until an entrustment starts, the Seller handles them directly.
| Entrusted task | What is processed |
|---|---|
| Payment processing | Payment approval, payment cancellation, refunds. Card numbers are handled by the payment service provider and not kept by the Seller. |
| Email delivery | Order confirmation emails and license key delivery |
| Website hosting | Operating the site and security logs |
Once a trustee is chosen, its name, contact details, and tasks are published in this Privacy Policy before any personal information is handed over. Entrustment contracts prohibit use outside the purpose, require protective measures, and restrict re-entrustment.
07Rights and obligations of data subjects and legal guardians, and how to exercise them
Data subjects may request access to, correction of, deletion of, or suspension of processing of their personal information. Legal guardians may make the same requests for children under 14.
Send requests to wblee@pioneery.co or 010-2601-5768. After verifying the person (or a lawful representative), the Seller acts within 10 days and reports the result.
Deletion of transaction records that the E-Commerce Act requires us to keep may be refused. In that case the Seller gives the reason and explains how to object.
08Privacy officer
The privacy officer is responsible for protecting personal information and handling complaints. Contact details are below.
- Name
- 이원빈
- Position
- Privacy officer
- Phone
- 010-2601-5768
- wblee@pioneery.co
09Measures to keep personal information secure
- Traffic to the site is encrypted with HTTPS.
- Payment method details are not stored in the Seller's systems.
- The number of people who handle personal information is kept to a minimum.
- Webcam video and recognition results are not collected.
10Automatic collection tools (cookies) and how to refuse them
The Seller does not set cookies for advertising, analytics, or third-party tracking, and does not use cookies to keep anyone logged in. The content of this site can be viewed without cookies.
You can refuse cookies in your browser settings. Refusing them does not affect reading the terms or the purchase information.
The hosting server may record access time, IP address, and browser type for security. These records are kept only for the period stated in "Processing and retention periods".
11Remedies for infringement of data subjects' rights
Reports and consultations about personal information infringement can be made to the following Korean agencies.
- Personal Information Infringement Report Center: 118 (in Korea), privacy.kisa.or.kr
- Personal Information Dispute Mediation Committee: 1833-6972, kopico.go.kr
- Supreme Prosecutors' Office, Cyber Investigation Division: 1301 (in Korea), spo.go.kr
- Korean National Police Agency, Cyber Investigation Bureau: 182 (in Korea), ecrm.police.go.kr
12Personal information of children under 14
The Seller does not collect personal information of children under 14. If it learns that information belongs to a child, it deletes it without delay. Legal guardians may exercise the rights described in "Rights and obligations of data subjects and legal guardians".
13Changes to this Privacy Policy
This policy applies from October 16, 2026. When it changes, the new policy and its effective date are posted on the site.
The personal information controller is:
- Business name
- PioneerY
- Representative
- 이원빈
- Business registration no.
- 803-27-01991
- Mail-order sales registration
- 2026-의정부흥선-0672
- Address
- 경기도 의정부시 평화로 658번길 50
- Phone
- 010-2601-5768
- wblee@pioneery.co
- Website
- trysneaky.com