⚠️ DRAFT · not legal advice · requires lawyer review and completion of [TO BE COMPLETED] blanks before publishing
This document is currently provided in English — Korean translation planned.

Privacy Policy

Draft for internal review. This is a template, not legal advice, and has not been reviewed by a lawyer. Applicable data-protection laws (e.g. GDPR, CCPA, Korea's PIPA) and the actual data flows must be confirmed before publishing. Fill the bracketed blanks with verified facts.

Who we are

This website (CryptoRefract, cryptorefract.com) is operated by The Accidental Order Inc. (주식회사 우연의질서) ("we," "us"). Contact: contact@cryptorefract.com. See the Imprint for entity details.

What we collect

We aim to collect as little personal data as possible.

We do not knowingly collect data from children, and we do not sell personal data.

Why we process it, and on what basis

We process the above to operate, secure, and improve the website and to communicate with you when you reach out. We rely on your consent for the newsletter (withdrawable at any time), and on our legitimate interest in operating and securing the site for the technical processing described above.

Sharing

We share personal data only with the service providers that help us run the site, under appropriate terms, and where required by law. Current processors: Amazon Web Services (hosting; Seoul region, ap-northeast-2) and MailerLite (newsletter delivery). When third-party advertising is enabled, Google (AdSense) will also process data as described under Cookies & advertising. We do not sell personal data.

International transfer

When you subscribe to the newsletter, your email address is processed by MailerLite, which may store or process it outside the Republic of Korea:

ItemDetail
ProcessorMailerLite (EU)
Data transferredEmail address (provided at subscription)
PurposeNewsletter delivery and subscription management
MethodTransmitted via API at signup
RetentionUntil unsubscribe or withdrawal of consent
Country[EU — exact country/entity TBD by counsel]
항목내용
수탁사MailerLite (EU)
이전 항목이메일 주소 (구독 시 제공)
이전 목적뉴스레터 발송·구독 관리
이전 방법가입 시 API 전송
보유·이용 기간구독 해지 또는 동의 철회 시까지
이전 국가[EU — 정확 국가/법인 변호사 확정]

You may decline by not subscribing; existing subscribers can unsubscribe at any time via the link in every newsletter.

Privacy officer

Personal-data inquiries: CryptoRefract Operator — contact@cryptorefract.com.

Your rights

Depending on your location, you may have rights to access, correct, delete, or restrict processing of your personal data, and to object or withdraw consent. To exercise them, contact contact@cryptorefract.com.

Retention and security

Newsletter data is kept until you unsubscribe or withdraw consent. Other personal data is kept only as long as needed for the purposes above or as required by law. We apply reasonable technical and organizational measures to protect it.

Last updated: 2026-06-24.