Privacy Policy

Kinka 金卡俱樂部 (“Kinka”) is operated by 吉光片羽股份有限公司 (Unified Business Number: 50894264; “we”), whose business address is 新北市中和區建康路130號4F-3 (Taiwan). We are the collector of personal data under this Policy. Personal data protection contact point: LINE official account @kinka (add-friend link: https://lin.ee/601On88). Requests to exercise personal data rights, complaints and contact about security incidents are all handled through this contact point.

This Policy applies to the Kinka website and to the Kinka mobile apps for iOS and Android (the “App”). Pages such as the FAQ, Terms of Service and Privacy Policy opened inside the App are website pages loaded in the in-app browser of the App, and the statements in this Policy about the website apply to them.

Depending on the features you use, we collect the following data to the extent necessary:

• Account and login data: when you log in or sign up with a Google Account, Apple ID or LINE, we obtain the identification and contact data that you have authorized, that the service actually returns and that is necessary to provide account features. If you choose Apple's “Hide My Email”, the email field is usually a relay address; the data Apple returns still includes the necessary login identifier. When you sign up or log in with an email address, we obtain your email address, the login identifier provided by Google's Firebase Authentication, the verification status of the email address and the verification records of login credentials; your password is processed and kept by Firebase Authentication, and our servers do not receive or store it. Whichever login method you use, each time you sign up or log in successfully through the website (or a version of the App that offers the consent checkboxes), we record the versions of the Terms of Service and Privacy Policy you agreed to, the language of the legal documents and the time, and the record from your most recent login is the one that applies; if you signed up with an email address, we also keep the consent record from when you signed up.
• Account and personal settings data: member identifier, displayed Member ID, login method, account status, nickname, and the data you voluntarily provide, update or set on your account or profile page.
• Age-related data: we do not proactively collect dates of birth or identity documents. If something needs to be confirmed because of a specific concern about use by a minor, impersonation or a payment dispute, we will separately explain the data needed, the purpose and the retention period, and will collect only the data necessary to resolve that concern.
• Service and transaction records: the acquisition, use, balance and expiring batches of KIN (recorded separately by purchase, item exchange and gift); the transaction identifier, mystery pack version, time, KIN deduction and result of official draws; Holding Box items and their handling status; and records of the exchanges, automatic exchanges, shipping, refund requests, ledger reconciliation and customer service handling that actually took place.
• Shipping data: when you set your recipient details, request shipping or deal with a shipping-related customer service matter, we collect the recipient name, contact phone number and shipping address needed to complete the delivery. You do not need to provide a shipping address or mobile phone number when signing up.
• Payment and invoice data: order and transaction identifiers, payment method, amount, payment result and reconciliation data, and, depending on the invoice option you choose, the email address for receiving the invoice, mobile barcode carrier, company Unified Business Number and name, or donation information. Full credit card numbers and security codes are handled by the third-party payment service provider; we do not obtain or store them. Where a refund cannot be made to the original payment method and must be made by bank transfer instead, we will inform you separately and collect the payee account details necessary to complete the refund.
• Customer service data: the explanations, screenshots, photos, unboxing videos, and account or transaction identifying information that you voluntarily provide in order to resolve an issue, together with the handling records. A video is not a requirement for exercising your rights to return or replace an item, to obtain a remedy for defects or to file a complaint.
• Social sharing campaign data: when you take part in a campaign that requires a public post on a social platform (for example, a Threads unboxing share), we collect the data you provide to claim the reward (for example the post URL, a screenshot of the post, or the email address used to confirm your membership) and the account name, text, posting time, photos and screenshots of that public post; we also read content you send to the official Kinka account by tagging it or by direct message. We read only content that is already public or that you send to us, do not log in to your social accounts and do not process non-public posts. After a reward has been granted, we periodically check, for the period set out in the campaign conditions, whether the post is still public, and we record its public status and any changes; if a post is judged to be non-public, we keep re-checking it until we confirm that it is public again, for no longer than 180 days after the reward was granted.
• Device, usage and system records: the login status, cookies or similar technologies, IP address, basic browser or device information, language and time zone settings, source parameters, use of pages or features, times of actions, and error or security records generated when you use the website or the App, as well as the records necessary to maintain accounts, transactions, the fairness of prize draws and service stability and to prevent abuse. When you use the App, a random installation identifier generated by the App and stored on your device (not an advertising identifier) is sent with each request, together with the App version, platform, language and time zone settings and a request identifier, and is used to keep the service running, for security and for analytics; we do not use Apple or Google advertising identifiers.

We collect, process and use your personal data only to the extent necessary for providing account and transaction services, fulfilling legal obligations, maintaining security, handling complaints and disputes, and the following purposes:

• Creating and managing accounts, verifying login identity, and providing features such as KIN, mystery pack draws, the Holding Box, item exchange and shipping.
• Handling payments, invoice issuance, refunds, reconciliation, transaction confirmation and customer service issues.
• Sending necessary notices relating to your account, transactions, item handling deadlines, shipping, security, refunds or service changes; necessary notices do not carry marketing content.
• Keeping the necessary draw, KIN deduction, exchange and shipping records for transaction verification, customer service, complaints and internal fairness reviews; when we provide data to a competent authority or judicial authority in accordance with the law, we provide only what it is entitled by law to obtain and only to the extent necessary.
• Maintaining website and account security, preventing improper use, and handling disputes or cooperating with requests from competent authorities in accordance with the law.
• Analyzing service usage and errors: the website uses first-party event logging, which sends page view and action events to Kinka's own endpoint; the login, sign-up, app-open, draw and top-up events of the App are recorded by our servers and include the member identifier and, for some events, the hashed installation identifier; login, sign-up and app-open events also include the country or region inferred from the IP address. We use the device, usage and system records described above to analyze how services such as login and top-up are used, troubleshoot errors and improve the service. When used for statistics or reports, the data is presented in aggregated form.
• Advertising performance measurement and remarketing: when you browse the website, we use tools from analytics and advertising service providers such as Google and Meta to record interaction events such as page views, sign-ups, logins and top-ups, as well as data such as page URLs, referrer URLs, and device and browser information, in order to analyze traffic sources, measure advertising performance and show relevant ads to you or to users similar to you. To measure advertising performance, we may also provide your contact data, such as your email address, to those service providers for matching after processing it by hashing or similar methods. The App itself does not integrate advertising or tracking SDKs and does not collect advertising identifiers; website pages opened in the in-app browser of the App are handled as described above for the website.
• Marketing notices: sending you campaign, offer or other marketing messages to the extent permitted by law or with your consent. You can ask us to stop at any time, and stopping marketing does not affect necessary notices.
• Checking campaign eligibility and granting rewards: matching social sharing campaign data against recent shipped shipping records (shipment number, shipping time, items, member ID or nickname, and the masked surname of the recipient; these may include your shipping records) to identify the shipment a post refers to. Rewards are granted only after our staff confirm the match, and a reward is not granted more than once for the same shipment. After a reward has been granted, we periodically confirm, for the period set out in the campaign conditions, whether the post is still public. A record that a post was deleted, hidden or made non-public is kept together with the reward grant records and used as a reference when reviewing your later applications for campaigns of the same kind (an application may be refused, but a reward already granted is not automatically withdrawn on that basis). If you believe a record is wrong, you can tell us through the contact point in this Policy and we will check and correct it.
• “Player Unboxings” public display: when you submit a post in the way the campaign specifies to claim the unboxing reward and have not indicated that you do not want it made public, then after our staff have reviewed and approved the post and created the reward, we will display the Threads account name, text and posting time of that post, the photos we select and the link to the original post, together with the prize name, prize tier, handling status and source mystery pack of the corresponding shipment, in “Player Unboxings”, on the home page and on the related mystery pack pages of the Kinka website and App; the displayed photos are obtained from the original post and, after being resized into thumbnails and compressed, are stored in our public image storage. Registration email addresses, member IDs and shipping data will not be made public; where a photo or text contains personal information that is not appropriate to make public, we will exclude or remove it. The post remains on display until you ask for it to be taken down, you delete your account or we stop displaying it; after it is taken down, we will delete the publicly displayed content and image files, but content that has already been downloaded or reposted by others cannot be recalled along with it. Not making a post public or taking it down does not affect the campaign review or the reward.

• Period: managed separately according to the nature of the data. Account data is kept until the account is permanently deleted under this Policy or the membership relationship ends, and the data necessary for shipments, payments, refunds and disputes already established is kept until each of those matters has been fully handled. Records of transactions, KIN movements, exchanges, shipping and refunds are kept for 5 years after the related rights and accounts have been settled. Accounting documents and account books are kept for the periods prescribed by Taiwan's Business Entity Accounting Act and tax laws and regulations. Service usage analytics events are kept for 14 months; data obtained by analytics and advertising service providers is kept according to their service settings and privacy policies; service logs are managed separately according to their purpose and system settings; and security or dispute evidence that must be kept by law is kept separately. If we cease operations, we will still keep and use the necessary data for the period needed to handle refunds and item shipping and to meet statutory retention requirements.
• Territory: within the Republic of China (Taiwan), and overseas regions that assist in providing the service. Computing and service logs for the Kinka website and App use Google Cloud service regions located in the United States; the database and file storage are also located in Google Cloud's United States regions. For third-party login services (Google, Apple, LINE, and Google Firebase Authentication used for email login), payment and e-invoice service providers, logistics carriers, analytics and advertising service providers such as Google and Meta, and the AI service provider that helps match social sharing campaign posts (OpenAI), the territory may include overseas regions, depending on where each provider actually processes the data.
• Recipients: us; the service providers that actually process the necessary data in order to complete the services you choose, namely Google Cloud (cloud hosting and storage), Google, Apple and LINE (login), Google Firebase Authentication (email login), 綠界科技 (ECPay; payment services and e-invoices), LINE Pay (payment services), analytics and advertising service providers such as Google and Meta, OpenAI (matching social sharing campaign posts with shipping records), and logistics carriers; and the competent authorities and judicial authorities that are entitled by law to require data. Login, analytics and advertising service providers process data under their own privacy policies and are not treated across the board as processors commissioned by us. Where a partner actually takes on shipping or fulfillment work, it obtains only the data necessary to perform that transaction. Unboxing share posts for which you have not indicated that you do not want them made public can be viewed by anyone browsing the Kinka website and App, within the scope of the “Player Unboxings” public display described above.
• Methods: collection, processing or use by electronic and automated means and, where necessary, manually by customer service. Statistics are presented in aggregated or appropriately de-identified form, but data that can be re-linked to an account, device or transaction is still protected as personal data.

We use cookies, sessions, on-device storage or similar technologies to maintain your login status on the website and in the App, save necessary settings, make sure features work properly and keep accounts and transactions secure. You can manage some of this data through your browser or device settings. If you disable cookies or related technologies that are necessary for the service, some login, transaction or other features may not work properly.

We use a first-party analytics cookie (for example, kinka_vid) that uses a random visitor identifier to link use of the service before and after login; it is kept for a maximum of 13 months. We also use cookies and similar technologies from analytics and advertising service providers such as Google and Meta (for example, _ga from Google Analytics and _fbp from the Meta Pixel) for the traffic analysis, advertising performance measurement and remarketing described in “Purposes for using personal data”. These cookies are set by the respective service providers and are kept according to their service settings and privacy policies. You can block or delete cookies through your browser settings, or use the opt-out methods offered by each service provider (for example, the Google Analytics opt-out browser add-on or Meta ad preferences). If you refuse them, the main features of the website are not affected.

When you choose to log in with Google, Apple or LINE, the relevant service processes data according to your authorization and its own privacy policy, and we obtain only the data that is actually returned and is necessary to provide account features.

When you choose email login, your email address and password are processed and kept by Google's Firebase Authentication and used to create the login account, send verification and password reset emails, verify the email address and log you in. We obtain the identifier needed for login, the verified email address and its verification status, together with verification records such as the login time and the validity period of login credentials. Our servers do not receive or store your password. Firebase Authentication processes data under Google's privacy policy.

The third-party payment service provider handles the payment process you choose; the e-invoice service provider obtains the email address, invoice carrier, Unified Business Number and name, or donation data needed to issue the invoice; and the logistics carrier obtains the recipient details needed to complete the delivery when you request shipping. Analytics and advertising service providers may obtain your browsing and interaction data on this website, cookie identifiers, IP address, and device and browser information, and process them under their respective privacy policies. Cloud providers and other commissioned processors process data only to the extent necessary for the commissioned purpose. Providing data to a competent authority or judicial authority requires a lawful basis.

Deleting your Kinka account is not the same as deleting your Apple, Google or LINE account. When you request deletion, we will, depending on the login method actually used, revoke the Sign in with Apple authorization and remove the LINE authorization; for accounts that use LINE login, the withdrawal process notifies LY Corporation and removes the link with Kinka. For Google login authorization, we provide instructions for removing access. For accounts that use email login, we also delete the corresponding login account in Firebase Authentication, and if that deletion does not succeed we keep retrying it. If a usable authorization credential cannot be obtained at that time, or the login service cannot complete the process, we will not postpone the deletion of data on this site for that reason; we will tell you truthfully which part has not been completed and provide the way to remove the authorization for that login service.

To identify which shipment a social sharing campaign post refers to, we provide the application data you send to the official account by direct message (including the email address used to confirm your membership and the screenshot of the post), the post content and masked shipping records (the shipping records do not include addresses, phone numbers or email addresses) to the AI service of OpenAI for matching; that service processes the data under its own terms of service and privacy policy, and whether a reward is granted is decided by our staff. Photos and screenshots used to review the campaign are deleted after they have been submitted for matching, and other records of the matching process are kept briefly and then deleted; the post URL, text, photo URLs and the result of the check are kept for the retention period of reward grant records.

We do not sell or rent your personal data.

Personal data is retained in accordance with the periods for each category of data listed in “Period, territory, recipients and methods of use” and the necessary purposes. When the purpose no longer exists or the law no longer requires the data to be kept, we will delete it, stop the corresponding use or de-identify it irreversibly. The parts needed by law or for specific unresolved matters are retained as an exception; we do not continue marketing or expand the purposes of use on that basis.

How data is handled after account deletion:

• General member data: once an account deletion request that has not been cancelled reaches its deadline, general member personal data goes into permanent deletion and is no longer kept for account recovery or marketing.
• Recipient details for established shipments: the name, phone number, shipping address and necessary logistics data are used only to complete that shipment and to handle any specific problem with it. Recipient details on the item record are deleted once 30 days have passed since delivery; the same applies where 180 days have passed since dispatch and there is still no delivery record. Shipping request records that have been handed over for fulfillment (including the recipient name, phone number and address) are kept for the retention period for transaction records and are not deleted early because of account deletion. Unresolved payment, refund, invoice and reconciliation matters continue to be handled on the basis of the original transaction records.
• Transaction records: necessary transaction records such as payments, KIN movements, exchanges, draws, shipping and refunds are still kept for the periods listed in “Period, territory, recipients and methods of use”; identity and contact fields in them that are no longer necessary are cleared. These records can still be matched to one another through internal transaction identifiers; we continue to manage them under personal data protection measures and do not claim that they are fully anonymous.
• Analytics, logs and backups: service usage analytics events are kept for the period listed in “Period, territory, recipients and methods of use”, and system logs and backups are kept for retention periods set according to their purpose and system settings. They are not rewritten record by record because of account deletion and are deleted when their retention period ends. This data is no longer used for day-to-day member services or marketing.
• Preventing new-member offers from being claimed more than once: to prevent new-member offers from being obtained again by deleting an account and signing up again with the same login identity, we retain, when an account is permanently deleted, a purpose-limited keyed hash generated from the identification data verified by the login service. This data is not used for login, advertising or restoring the original account. It is retained for 180 days and deleted when that period ends. It can still be used to check for the same login identity, so we do not describe it as fully anonymous data. For accounts signed up with an email address, this hash is generated from the normalized form of the email address (ignoring letter case, dropping any tag after “+”, and ignoring periods in Gmail addresses), is kept for as long as the account exists, is used to check whether an account with the same email address already exists and whether new-member offers apply, and is likewise retained for 180 days after the account is permanently deleted.
• Deletion request records and progress checks: the progress link you receive after submitting a deletion request carries no login authorization. It is used only to check whether that request has been accepted, cancelled or completed, and it does not display member data. The record of the deletion request (the times of acceptance, cancellation and completion, the KIN balance and item counts shown at the time of the request, any reason you chose to give, and the result of removing login authorizations) is kept for the retention period for transaction records, as a record that you were informed and confirmed.

We adopt appropriate access controls, transmission protection, logging and other security measures according to the nature of the data and the risks. If a personal data security incident occurs, we will take measures to contain the damage, investigate and remedy the incident, and, in accordance with Taiwan's Personal Data Protection Act as in force at the time of the incident and the applicable sector-specific rules, notify the data subjects, make the necessary reports and keep records of how the incident was handled.

Under the Personal Data Protection Act, you can use the contact details listed in this Policy to ask us to let you inquire about or review your personal data, to provide a copy of it, to supplement or correct it, to stop collecting, processing or using it, and to delete it. We may verify your identity, or that of your lawful agent, to the extent necessary. We will decide on requests to inquire about, review or receive a copy of personal data within 15 days; where necessary, we may extend this period by no more than 15 days and will notify you of the reason in writing. We will decide on other requests within 30 days; where necessary, we may extend this period by no more than 30 days and will notify you of the reason in writing. Where we refuse or restrict a request in accordance with the law, we will explain the specific reasons and scope, and we will not refuse all requests across the board on the ground that the account is still in dispute.

You can choose whether to provide personal data. However, if you do not provide the data required for a particular feature, we may be unable to complete account sign-up or login, payment, draws, customer service, item shipping or other related services.

Ways to delete your account and confirmation: you can submit a request from “Account → Delete account” on the Kinka website or on the public account deletion page, and the website routes do not require you to install the App, and you can also submit a request from the account page of the Kinka App. Before you submit the request, we show your currently available KIN, the number of items in your Holding Box and the number of items in shipping, and we confirm your intention by having you type “DELETE”. Giving a reason for deletion is optional. Personal data rights requests can also be made through the contact point in this Policy.

Once the request is accepted, login authorization on all devices becomes invalid. If you log in again within 7 days of acceptance, the request is automatically cancelled; after the period ends, the original account cannot be restored. We will delete general member data such as linked login methods, email address, nickname, address book and invoice preferences, as well as remaining KIN and your rights in Holding Box items for which shipping has not been requested. After submitting, you receive a progress link that lets you check, without logging in, whether the request has been accepted, cancelled or completed; you do not need to provide an additional email address for this.

Deleting an account is different from deleting all transaction records. Necessary records such as payments, invoices, the KIN ledger, draws and shipments are handled as described in “Data retention and security”. For specific payments, refunds and shipments that are not yet complete, we keep only the data necessary to complete that matter, and it is no longer used for member login, marketing or general personalization.

Sign-up, KIN purchases and official draws on Kinka are intended for people aged 18 or over, and we do not actively solicit minors by allowing them to make new transactions. If we find that someone appears to be under 18, we will restrict new transactions as necessary and carry out proportionate verification or contact the person's legal representative. The validity of existing transactions, the return of the price paid and the delivery of items are handled case by case in accordance with the law. Data that is necessary to handle existing transactions by minors, requests from legal representatives or security incidents is still processed for a clear purpose and for the necessary period; where there is no need to keep it any longer, it is deleted or its use is restricted in accordance with the law. Legal representatives who have questions can contact us using the methods listed in this Policy.

When this Policy is updated, the version, last updated date and effective date are indicated and the Policy is published on this page. For material changes affecting your rights and interests in your personal data, we will notify you by an announcement on the website or by other appropriate means.