Figgle Privacy Policy

1. Purposes, information collected, and retention

Registration and account management: We collect names, email addresses, and passwords for registration, account management, and service provision, and retain them until account withdrawal. Organization and phone number are optional and are used to identify research teams and communicate with members. They are retained until consent is withdrawn or the account is closed, whichever occurs first.

Inquiries: We collect names, email addresses, inquiry contents, and optionally organization names. This information is retained until the inquiry is resolved and then destroyed without delay. Records subject to statutory retention for consumer complaints, disputes, or transactions are separately retained under Section 2.

Paid services, payments, and refunds: We process member identifiers, order numbers, purchased products, payment amounts, payment dates and times, payment method types, transaction identifiers, and cancellation and refund records. This information is used to verify payments, provide services, and process refunds. Contract, payment, and service supply records are retained for 5 years.

Service security and incident response: We process IP addresses, access dates and times, member identifiers, and service usage and error logs, retaining them for 3 months from creation. Statutory access records relating to personal information operations such as viewing or modification are retained for the periods in Section 2.

The legal basis for registration, optional information, and general inquiries is the user’s consent. Information necessary for payments and service provision is processed to perform the contract. Statutory retention and legally required security records are processed to comply with legal obligations.

2. Statutory retention and destruction

Under the Enforcement Decree of the Act on the Consumer Protection in Electronic Commerce, etc., the Company retains records of contracts, withdrawal of offers, payments, and service supply for 5 years; consumer complaints and dispute resolution for 3 years; and labeling and advertising for 6 months. Where records contain personal information, only the items necessary for their retention are kept.

Under the Standards for Ensuring the Safety of Personal Information, operational access logs for personal information processing systems are retained for 1 year, or 2 years where a retention requirement of at least 2 years applies, including systems processing sensitive information or unique identification information. Any other applicable statutory retention period takes precedence.

The Company identifies and destroys personal information without delay when it is no longer necessary because its purpose has been fulfilled or its retention period has ended. Information that must be retained by law is managed separately from other personal information. Electronic files are deleted in a manner that prevents recovery or reproduction, and paper records are shredded or incinerated.

3. Third-party disclosure, entrusted processing, and overseas transfers

The Company does not disclose personal information to third parties without the user’s consent or another legal basis.

Third-party disclosures: We are confirming whether disclosures occur and, if applicable, the recipients, purposes, information disclosed, retention periods, and legal bases.

Entrusted processing: We are confirming the exact legal names of service providers and the processing tasks entrusted to them.

When entrusting personal information processing, the Company contractually prohibits processing for other purposes, specifies protective measures, and manages and supervises the provider’s processing activities.

Overseas transfers: We are confirming whether overseas transfers occur and, if applicable, the countries, recipients and contact details, information transferred, purposes, timing and methods, retention periods, legal bases, and methods and consequences of refusing a transfer.

Where overseas transfers occur, the Company establishes a lawful basis and follows the notice, consent, and other procedures required by applicable law.

4. Personal information uploaded by research institutions

Personal information in research materials uploaded to Figgle by research institutions or similar organizations is processed based on the institution’s lawful grounds and its personal information processing agreement with the Company.

The Company does not use entrusted research materials for its own purposes beyond the entrusted scope. Information categories and retention periods are determined by the legal basis for each study and the processing agreement. On termination, information is returned or destroyed according to lawful instructions. Retention of research materials is handled separately from member account withdrawal.

5. Individual rights and safeguards

Individuals or their authorized representatives may use the contact details below to request access, correction, deletion, suspension of processing, or withdrawal of consent. The Company verifies identity or representative authority and handles requests under applicable law.

The Company implements technical and organizational measures necessary to protect personal information, including access control, encryption, and access log management.

Cookies and similar technologies: We use a session cookie (__session) to maintain login status and a language cookie (NEXT_LOCALE) to remember the selected language. The session cookie lasts for the browser session and is deleted on logout. The language cookie is retained for up to 1 year from when it is set.

Browser storage holds language and display preferences and current project information. Language and display preferences remain until changed or deleted; project information in session storage remains for the tab’s session. You can block or delete cookies and site data in your browser settings. Doing so may prevent you from staying signed in or reset language and display preferences.

6. Privacy contact

Department responsible for privacy inquiries: Customer Support Team

Phone: A company phone number for privacy inquiries is being arranged. Please use the email below for now.

Email: goldenegg@figgle.it

Changes to this Policy and their effective date will be published on the website. Separate consent will be obtained where required by law.

Effective date: September 14, 2026