ArayoNews (the "Service"), operated by Sidewalk Entertainment (the "Company"), complies with applicable laws including the Personal Information Protection Act of Korea, the Act on Promotion of Information and Communications Network Utilization, the EU General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA/CPRA), and the Children's Online Privacy Protection Act (COPPA).

A. Categories of information collected:

• Newsletter subscription: Email address

• Contact inquiries: Email and message content

• Automatically collected: Cookies, IP address, browser type and OS, access time, pages visited, referrer, device identifiers

B. Methods: Direct input by users, automatic collection via cookies and log analysis tools, third-party authentication tools

• Service provision and operation

• Responding to user inquiries

• Newsletter delivery (only to consenting users)

• Site analytics and service improvement

• Personalized advertising (only to consenting users)

• Fraud prevention and security

• Compliance with legal obligations

• Newsletter email: Deleted immediately upon unsubscription

• Access logs: Retained for 3 months per the Protection of Communications Secrets Act, then destroyed

• Cookies: See Section 7

• Where required by law (e.g., advertising records: 6 months), we follow the statutory period

We do not share personal information with third parties without user consent, except where required by law.

We engage the following processors to operate the Service:

• Google LLC — Site analytics (GA) and ad serving (AdSense) — up to 26 months

• Google Cloud Platform — Website hosting and image storage — until contract ends

• Cloudflare Inc. — Email routing and CDN — until contract ends

We transfer personal data outside Korea in the course of some operations.

• Recipients: Google LLC, Cloudflare Inc.

• Destination: United States

• Timing and method: During service use, via secure electronic network transmission

• Categories transferred: Cookie identifiers, IP address, usage logs, device info

• Purposes: Ad serving, analytics, CDN, security

• Retention: Per Google's policy (up to 26 months)

• Legal basis: User consent

You may refuse international transfer, which may limit personalized advertising and some features.

The Service uses three categories of cookies:

(1) Essential cookies (no consent required): Language preference, security, session — expire at session end

(2) Analytics cookies (consent required): Google Analytics 4 — visitor counts, pageviews, dwell time — stored up to 2 years

(3) Advertising cookies (consent required): Google AdSense and Google's advertising technology partners — interest-based ads, frequency capping, performance measurement — stored up to 13 months under IAB TCF v2.3

Refusal: Click 'Reject' or 'Reject All' on the cookie banner, block cookies in browser settings, adjust Google Ads Settings (https://adssettings.google.com), YourAdChoices (https://youradchoices.com), Your Online Choices (https://www.youronlinechoices.com)

The Service displays ads via Google AdSense. Google and its advertising technology partners (Authorized Buyers) may use cookies and similar identifiers to serve interest-based ads.

• Technologies: DoubleClick DART cookies, device identifiers, IP address

• Partner list: https://support.google.com/admanager/answer/9012903

• Compliant with IAB Europe TCF v2.3

You can opt out of personalized ads via Google Ads Settings; non-personalized ads will continue to display.

California residents have the following rights:

• Right to know what personal information is collected

• Right to delete personal information

• Right to opt out of the "sale or sharing" of personal information ("Do Not Sell or Share My Personal Information")

• Right to limit the use of sensitive personal information

• Right to non-discrimination for exercising these rights

Opt-out requests: admin@arayonews.com

Residents of the EEA, UK, and Switzerland have the following rights:

• Legal basis of processing: (a) consent, (b) contract performance, (c) legitimate interests

• Rights to access, rectify, erase, restrict processing, and data portability

• Right to lodge a complaint with a supervisory authority (Korean PIPC or your local authority)

• Right to object to automated decision-making (GDPR Article 22)

Exercise rights: admin@arayonews.com

We do not knowingly collect personal information from children under 14 (under 13 under the US COPPA).

If we learn that a child under the applicable age has provided information, we delete it immediately, and obtain verifiable parental consent where legally required.

• Administrative: Minimizing access personnel, staff training

• Technical: Access control, encryption (HTTPS/TLS), security software

• Physical: Access control at server facilities (GCP data center standards)

• Department: ArayoNews Editorial Desk

• Role: Data Protection Officer

• Email: admin@arayonews.com

• Complaints contact: Same as above

• Korea Personal Information Protection Commission: 1833-6972, https://www.pipc.go.kr

• Personal Information Dispute Mediation Committee: 1833-6972

• Supreme Prosecutors' Office Cybercrime Division: 1301

• Korean National Police Agency Cyber Bureau: 182

This Policy may be updated due to changes in law or service. Material changes will be announced at least 7 days in advance.