- The operator is a Singapore company. Data is processed and stored outside your country. (see section 7)
- You sign up and log in with an email address or a Google, Apple, Kakao or Naver account. We receive your email address, name and profile photo. We do not collect your date of birth or any national identification number.
- To calculate rewards and prevent abuse we process device identifiers, wallet addresses and activity records.
- Location and camera are accessed only when you use the relevant feature and only with your permission.
- For step rewards (pedometer) we read your step count and physical activity recognition data (health and fitness data) only with your permission. We never use this data for advertising or sell it. (see section 1)
- You can ask to access or delete your data at any time. Transactions recorded on a blockchain cannot be deleted.
11. Personal data we collect
We collect only what the Service needs. We do not collect your date of birth or any national identification number.
| Basis | Data | When collected |
|---|---|---|
| Required | Account information: email address, name (nickname), profile photo, social account identifier | On sign-up and login (email sign-up or Google, Apple, Kakao or Naver login) |
| Required | Password (stored with irreversible one-way encryption) | On email sign-up |
| Required | Device identifier (including advertising ID), OS and device model, app version | Automatically on first launch |
| Required | Blockchain wallet address, transaction hashes | On wallet connection and reward payout |
| Required | Activity records (accruals, timestamps, booster multiplier), invitation code and acquisition source | Automatically during use |
| Optional | Location data (GPS coordinates, distance travelled) | When you use the walking reward (after consent) |
| Optional | Health and fitness data: step count and physical activity recognition (walking, running, stationary, in vehicle, cycling) | When you use the pedometer / step reward (after granting permission) |
| Optional | Photographs and capture metadata | When you use the photo feature (after consent) |
| Optional | Push notification token | When you opt in to notifications |
| Optional | Email address | When you enter it to contact or report to us |
| Automatic | IP address, access timestamps, cookies, usage records, error logs | Automatically during use |
How we handle health and fitness data (step count and physical activity)
- How we access it — Only when you use the pedometer (step reward) feature and grant the device permission. On Android we use the device step sensor and activity recognition through the "Physical activity" permission and, where applicable, step counts from Health Connect (read-only). On iOS we use step counts and activity state through the "Motion & Fitness" permission and, where applicable, step counts from Apple Health (HealthKit, read-only).
- What we collect — Your cumulative step count for the day, and your activity state (walking, running, stationary, in vehicle, cycling) with its confidence level. We do not collect heart rate, weight, sleep, medical conditions or any other health information, and we never write data to Health Connect or Apple Health.
- How we use it — Solely to calculate MOL accrual and pay step rewards, to display your step count in the app, and to prevent abuse by excluding abnormal steps such as those recorded while in a vehicle or by shaking the device.
- Processing and storage — Activity state is used only on your device to verify steps and is never sent to our servers. Only your daily step count is linked to your account and transmitted, encrypted, to our servers for reward calculation.
- Sharing and restrictions — We do not sell health and fitness data, use it for advertising, marketing or personalised ads, or share it with advertising networks, data brokers or other third parties, and we do not use it to determine eligibility for credit or insurance. Apart from our cloud infrastructure provider (section 5) acting on our behalf, we do not share it except where required by law.
- What we receive — When you log in with a Google, Apple, Kakao or Naver account, we receive only your account identifier, email address, name and profile photo from that service. For Google accounts we request no permissions beyond basic profile information (openid, email, profile), and we do not access your contacts, Gmail, Drive or any other Google data.
- How we use it — Solely to identify you, log you in and verify your identity, prevent duplicate accounts and abuse, and display your profile in the app.
- Storage — This information is linked to your account and transmitted over an encrypted connection to, and stored on, the Company's servers. We never receive your social account password, and access tokens from the social service are used only to verify the login and are not stored.
- Sharing and limits — Information received through social login is never sold, never used for advertising, marketing or personalised ads, and never provided to third parties such as ad networks or data brokers. It is not shared with anyone other than our cloud infrastructure provider (section 5), except where required by law.
- Deletion — When you delete your account, your email address, name, profile photo and password are destroyed immediately. You can remove DigMol's access at any time in your Google Account settings (myaccount.google.com/permissions).
22. Why we use it
- Account management — identifying users, logging in and verifying identity, resetting passwords, preventing duplicate accounts, processing account deletion
- Providing the Service — recognising activity, counting steps, calculating MOL accrual, paying rewards, showing history
- Preventing abuse — detecting duplicate accounts, automation and location spoofing, and excluding abnormal steps such as those taken in a vehicle
- Managing invitations — attributing installs to invitation links and paying both sides
- Improving the Service — usage analytics, error diagnosis, feature development
- Support — receiving and answering enquiries and reports
- Notices — essential announcements about terms, reward policy and maintenance (marketing messages only where you have opted in)
- Legal compliance — obligations under Singapore and Korean law, sanctions screening, and responding to lawful requests from authorities
33. Retention
We destroy personal data without delay once the purpose of collection has been achieved, except as set out below.
| Data | Retention | Basis |
|---|---|---|
| Account information (email address, name, profile photo, password) | Destroyed immediately on account deletion | - |
| Social account identifier (email address for email sign-up) | 7 days after account deletion (destroyed afterwards) | Preventing abuse through immediate re-registration |
| Device identifiers and activity records | 30 days after termination | Preventing repeat abuse and handling enquiries |
| Abuse records | 3 years | Preventing recurrence and handling disputes |
| Location data | Destroyed immediately after each use (only aggregate distance is kept) | Location data legislation |
| Step data | Daily step counts: 30 days after termination (activity state is processed only on your device and is not stored on our servers) | Reward settlement and handling enquiries |
| Support and enquiry records | 3 years | Consumer complaint and dispute records |
| Access logs and IP addresses | 3 months | Communications privacy legislation |
| Anti-money-laundering records | 5 years | Applicable Singapore and Korean law |
44. Disclosure to third parties
We do not disclose personal data to third parties, except in the following cases.
- Where you have given prior, express consent
- Where a law so provides, or where a Korean or Singapore investigative authority makes a request following the procedure prescribed by law
- Where data is provided in a form from which no individual can be identified, for statistical or academic purposes
55. Processors
We engage the following processors so that the Service can run. Each contract sets out data protection obligations clearly, and we supervise performance against them.
| Processor | Purpose | Retention |
|---|---|---|
| Cloud infrastructure provider | Server operation and data storage | Until the contract ends |
| Push notification provider | Sending app push messages | Until the contract ends |
| Advertising network | Serving rewarded ads and verifying views | Until the contract ends |
| Analytics provider | Usage analytics and error collection | Until the contract ends |
66. Your rights
You may exercise the following rights at any time.
- Access your personal data
- Have inaccurate data corrected
- Have data deleted (except where retention is required by law)
- Ask us to stop processing
- Withdraw consent (for optional items)
- Refuse cross-border transfer (which may make the Service unavailable to you)
You can exercise these rights through the in-app settings or by writing to privacy@digmol.com. We respond within 10 days of receiving a request. Where you ask for deletion, we destroy the data so that it cannot be restored or reconstructed.
77. Cross-border transfer
The following disclosure is made in accordance with Article 28-8 of the Personal Information Protection Act of the Republic of Korea and the transfer limitation obligation under the Singapore PDPA.
| Item | Detail |
|---|---|
| Recipient | BUKCS PTE. LTD. (service operator) and the processors listed in section 5 |
| Destination | Singapore and the countries in which each processor's servers are located |
| Data transferred | All items listed in section 1 |
| Timing and method | Transmitted on an ongoing basis over encrypted network connections as you use the Service |
| Purpose | All purposes listed in section 2 |
| Retention | As set out in section 3 |
| How to refuse | Write to privacy@digmol.com. Because the transfer is essential to providing the Service, refusing it may restrict or prevent your use of it. |
We apply protection to transferred data comparable to the standard required by the law of your country, including encryption in transit and access controls.
88. Children
We do not collect personal data from children under 14 and the Service is not directed at them. If we find that we hold such data, we destroy it immediately and suspend the account. Where the law of your country sets a higher age of consent, that threshold applies.
99. Cookies and similar technologies
On the website we use cookies and local storage to keep track of invitation attribution and to understand how the Service is used.
- Essential cookies — preserving invitation codes and language preference, maintaining a session. Required for the Service.
- Analytics storage — page visit statistics and error diagnosis.
You can refuse cookies in your browser settings. Blocking essential cookies may prevent invitation rewards from being attributed correctly.
1010. Security measures
- Technical — encryption in transit (HTTPS/TLS), encryption of sensitive data at rest, least-privilege access, intrusion prevention
- Organisational — minimising the number of staff who handle personal data, regular training, an internal management plan, retention and review of access logs
- Physical — access control at the facilities where data is stored
1111. Contact
We have appointed the following person to oversee personal data processing and handle complaints.
- Data protection officer: (to be appointed)
- Contact: privacy@digmol.com
Complaints about personal data handling may also be raised with a supervisory authority.
- Singapore — Personal Data Protection Commission (PDPC), pdpc.gov.sg
- Republic of Korea — Personal Information Dispute Mediation Committee, kopico.go.kr / 1833-6972
- Republic of Korea — Privacy Infringement Report Centre, privacy.kisa.or.kr / 118
1212. Changes to this policy
This policy may be revised to reflect changes in law, policy or the Service. Changes and their effective date are announced in the app or on the website at least 7 days in advance. Where a change materially affects your rights, notice is given 30 days in advance and, where necessary, separate consent is obtained.