Privacy Policy

The latest update date: November 8, 2020

This Privacy Policy (the "Policy") explains the way of treatment of the information which is provided or collected in the websites on which this Policy is posted. In addition the Policy also explains the information which is provided or collected in the course of using the applications of Toosapp which exist in the websites or platforms of other company.

Through this Policy, Toosapp regards personal information of the users as important and inform them of the purpose and method of Toosapp's using the personal information provided by the users and the measures taken by AssembleCircle for protection of those personal information.

This Policy will be effective on the 15th day of November, 2020 and, in case of modification thereof, Toosapp will make public notice of it through posting it on the bulletin board of Toosapp’s website or individual notice through sending e-mails.

1. Information to be collected and method of collection

(1) Personal information items to be collected Personal information items to be collected by Toosapp are as follows:

[Information provided by the users]

Toosapp may collect the information directly provided by the users.

Please note that we do not require the dental record data in order to provide our Services. In such cases, we will only collect such information for your use and convenience.

[Information collected while the users use services]

Besides of information directly provided by the users, Toosapp may collect information in the course that the users use the service provided by Toosapp.

(2) Method of collection

Toosapp collects the information of users in a way of the followings:

2. Use of collected information

Toosapp uses the collected information of users for the following purposes:

Toosapp agrees that it will obtain consent from the users, if Toosapp desires to use the information other than those expressly stated in this Policy.

3. Sharing collected information

Except for the following cases, Toosapp will not share personal information with a 3rd party:

4. Cookies, Beacons and Similar Technologies

Toosapp may collect collective and impersonal information through 'cookies' or 'web beacons'. Cookies are very small text files to be sent to the browser of the users by the server used for operation of the websites of Toosapp and will be stored in hard-disks of the users' computer. Web beacon is a small quantity of code which exists on the websites and e-mails. By using web beacons, we may know whether a user has interacted with certain webs or the contents of email. These functions are used for evaluating, improving services and setting-up users' experiences so that much improved services can be provided by Toosapp to the users. The items of cookies to be collected by Toosapp and the purpose of such collection are as follows:

Category Reasons for using cookies and additional information
Strictly necessary cookies This cookie is a kind of indispensable cookie for the users to use the functions of website of Toosapp. Unless the users allow this cookie, the services such as electronic bill payment cannot be provided. This cookie does not collect any information which may be used for marketing or memorizing the sites visited by the users
  • Memorize the information entered in an order form while searching other pages during web browser session
  • For the page of products and check-out, memorize ordered services
  • Check whether login is made on website
  • Check whether the users are connected with correct services of the website of Toosapp while Toosapp changes the way of operating its website
  • Connect the users with certain application or server of the services
Performance cookies This cookie collects information how the users use the website of Toosapp such as the information of the pages which are visited by the users most. This data helps Toosapp to optimize its website so that the users can search that website more comfortably. This cookie does not collect any information of the users. Any and all the information collected by this cookie will be processed collectively and the anonymity will be guaranteed.
  • Web analysis: provide statistical data on the ways of using website
  • Advertisement response fee: check the effect of advertisement of Toosapp
  • Tracing affiliated companies; one of visitors of Toosapp provides anonymously feedback to the affiliated companies
  • Management of error: measure an error which may occur so as to give a help for improving website
  • Design testing: test other design of the website of Toosapp
Functionality cookies This cookie is used for memorizing the set-ups so that Toosapp provides services and improves visit of users. Any information collected by this cookie does not identify the users individually.
  • Memorize set-ups applied such as layout, text size, basic set-up and colors
  • Memorize when the customer respond to a survey conducted by Toosapp
Targeting cookies or advertising cookies This cookie is connected with the services provided by a 3rd party such as the buttons of 'good' and 'share'. The 3rd party provides these services by recognizing that the users visit the website of Toosapp.
  • carry out PR to the users as targets in other websites by connecting through social networks and these networks use the information of users' visit
  • provide the information of users' visit to ad agencies so that they can suggest an ad which may attract the interest of the users

The users have an option for cookie installation. So, they may either allow all cookies by setting option in web browser, make each cookie checked whenever it is saved, or refuses all cookies to be saved: Provided that, if the user rejects the installation of cookies, it may be difficult for that user to use the parts of services provided by Toosapp.

5. Users' right to access and option

The users or their legal representatives, as main agents of the information, may exercise the following options regarding the collection, use and sharing of personal information by Toosapp:

If, in order to exercise the above options, you, as an user, use the menu of 'amendment of member information of webpage or contact Toosapp by using representative telephone or sending a document or e-mails, or using telephone to the responsible department (or person in charge of management of personal information), Toosapp will take measures without delay: Provided that Toosapp may reject the request of you only to the extent that there exists either proper cause as prescribed in the laws or equivalent cause.

6. Security

Toosapp regards the security of personal information of uses as very important. Toosapp constructs the following security measures to protect the users' personal information from any unauthorized access, release, use or modification.

In order to prevent the loss, theft, leakage, alteration or damage of personal information of the users, Toosapp takes technical, managerial and physical measures for securing safety as follows:

Technical measures
  • Utilize security servers for transmitting encryption of personal information
  • Take measures of encryption for confidential information
  • Install and operate access control devices and equipments
  • Establish and execute internal management plan
Managerial measures
  • Appoint a staff responsible for protecting personal information
  • Provide education and training for staffs treating personal information
  • Establish and execute internal management plan
  • Establish rules for writing passwords which is hard to be estimated
  • Ensure safe storage of record of access to personal information processing system
  • Classify the level of authority to access to personal information processing system
Physical measures
  • Establish and operate the procedure for access control for the facilities for storing personal information
  • Store documents and backing storage containing personal information in safe places which have locking device

7. Modification of Privacy Protection Policy

Toosapp has the right to amend or modify this Policy from time to time and, in such case, Toosapp will make a public notice of it through bulletin board of its website (or through individual notice such as written document, fax or e-mail) and obtain consent from the users if required by relevant laws.

8. Others

[Data transmission]

Considering it engages in global businesses, Toosapp may provide the users' personal information to the companies located in other countries for the purpose as expressly stated in this Policy. For the places where the personal information is transmitted, retained or processed, Toosapp takes reasonable measures for protecting that personal information. (If used in the US, additional security measures may be available) In addition, when the personal information obtained from the European Union is used or disclosed, Toosapp may have to comply with safe harbor principle as required by the Commerce Department of USA, take other measures or obtain consent from users so far as those complies with the regulations of EU so as to use a standardized agreement provision approved by executing organizations of EU or securing proper safe measures.

[3rd party's sites and services]

The website, product or service of Toosapp may include the links to the ones of a 3rd party and the privacy protection policy of the site of 3rd party may be different. Thus, it is required for the users to check additionally that policy of a 3rd party site linked to the site of Toosapp.

[Guide for users residing in California]

If the user resides in California, certain rights may be given. Toosapp prepares preventive measures necessary for protecting personal information of members so that Toosapp can comply with online privacy protection laws of California. In case of leakage of personal information, a user may request Toosapp to check the leakage. In addition, all the users in the website of Toosapp, can modify their information at any time by using the menu for changing information by connecting their personal account. Moreover, Toosapp does not trace the visitors of its website nor use any signals for 'tracing prevent'. Toosapp will not collect and provide any personal identification information through ad services without consent of users.

Responsible department of AssembleCircle

Toosapp designates the following department and person in charge of personal information in order to protect personal information of customers and deal with complaints from customers:

• Department responsible for privacy protection and customer service :