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.
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.
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.
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.
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.
When you subscribe to the newsletter, your email address is processed by MailerLite, which may store or process it outside the Republic of Korea:
| Item | Detail |
|---|---|
| Processor | MailerLite (EU) |
| Data transferred | Email address (provided at subscription) |
| Purpose | Newsletter delivery and subscription management |
| Method | Transmitted via API at signup |
| Retention | Until unsubscribe or withdrawal of consent |
| Country | [EU — exact country/entity TBD by counsel] |
| 항목 | 내용 |
|---|---|
| 수탁사 | MailerLite (EU) |
| 이전 항목 | 이메일 주소 (구독 시 제공) |
| 이전 목적 | 뉴스레터 발송·구독 관리 |
| 이전 방법 | 가입 시 API 전송 |
| 보유·이용 기간 | 구독 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.
Personal-data inquiries: CryptoRefract Operator — contact@cryptorefract.com.
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.
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.