Effective date: October 27, 2026 · Last updated: October 26, 2026
This Privacy Policy explains how glnoon Co., Ltd. (“glnoon,” “we,” “us”) handles personal information when you use the English-language Focus Reading website at glnoon.com/en/. We are the controller of your personal information.
glnoon Co., Ltd. · A428, Room 402, 4F, 20 Hakdong-ro 24-gil, Gangnam-gu, Seoul, Republic of Korea · Privacy contact: Sunghoo Park (CEO), focusforum1@gmail.com
1. What we collect and why
We collect only what we need for the purposes below.
| Category | Information | Purpose | Legal basis (GDPR) |
|---|---|---|---|
| Account | Name, email, password (stored encrypted) | Identify you, log you in, manage your account, prevent misuse | Contract |
| Orders and refunds | Course, amount, date, order ID received from Paddle | Grant course access, process refunds, keep records | Contract, legal obligation |
| Learning and diagnostics | Diagnostic answers, scores, F-Level, video progress, Opened Days, study time, workbook entries, download history | Run the Classroom, create reports and training plans, calculate refunds, confirm completion | Contract |
| Boards | Posts, ratings, dates, reports of abuse | Answer questions, show reviews, block abuse | Contract, legitimate interests |
| Support | Name, email, message content | Answer questions and handle refunds | Contract |
| Certificates | Name, course, completion date, certificate number | Issue and verify certificates you request | Contract |
| Group enrollment | Organization name, Group Access Code | Enroll members under an organization’s contract | Contract |
| Promotional email (optional) | New courses, discounts, events | Consent | |
| Technical data | IP address, access time, browser and device information, cookies | Keep you logged in, secure the Site | Legitimate interests, legal obligation |
We do not collect sensitive information such as health data or religious or political beliefs. We do not sell your personal information or use it for targeted advertising.
2. Payments and Paddle
Payments are handled by Paddle.com, our online reseller and Merchant of Record. Paddle collects your payment details, billing address, and tax information directly and processes them as an independent controller under the Paddle Privacy Notice. We never see or store your card number. Paddle sends us the order information listed above so that we can give you access.
3. Who we share it with
We share personal information only as needed to run the Services.
| Recipient | Role | What they do |
|---|---|---|
| Paddle.com Market Ltd | Independent controller (Merchant of Record) | Checkout, payment, tax, invoices, refunds |
| Kinsta Inc. | Processor | Hosts the Site; data is stored in a data center in Seoul, Republic of Korea |
| Google LLC (Google Workspace) | Processor | Company email and service emails |
| Vimeo, Inc. | Processor | Plays lecture videos (processes access data during playback) |
| Our website development and maintenance provider | Processor | Builds and maintains the Site under a data processing agreement |
| The organization that issued your Group Access Code (only if you used one) | Controller for its own purposes | Receives your name, enrollment, progress, and completion status to manage group training |
We may also disclose information when the law requires it.
4. International transfers
We are based in the Republic of Korea, and the Site’s data is stored in Seoul. The European Commission and the United Kingdom have recognized the Republic of Korea as providing an adequate level of data protection. Some of our service providers (Google, Vimeo, Kinsta support staff) may access data from the United States or other countries. Where this happens, we rely on safeguards such as the EU Standard Contractual Clauses or the EU-U.S. Data Privacy Framework, as provided in each provider’s data processing terms.
5. How long we keep it
| Information | Kept for |
|---|---|
| Account, learning and diagnostic records, posts | Until you delete your account, then deleted without delay |
| Order, refund, and contract records | 5 years (Korean e-commerce law) |
| Records of complaints and disputes | 3 years (Korean e-commerce law) |
| Login records (time, IP) | 3 months (Korean communications law) |
| Certificate register (name, course, number) | 5 years from issue, to verify certificates |
| Promotional email consent | Until you withdraw it |
We may keep anonymous statistics made from learning records after you delete your account, because they no longer identify you.
6. Your rights
You can ask us to:
- give you a copy of your personal information (access) or send it to you in a common format (portability);
- correct it (rectification) or delete it (erasure);
- limit how we use it (restriction) or stop using it based on legitimate interests (objection);
- withdraw your consent at any time, for example to promotional email, without affecting earlier processing.
You can do much of this in My Account, or email focusforum1@gmail.com. We respond within 10 days and in any case within one month. If the law requires us to keep certain records, we will tell you why we cannot delete them yet.
If you are in the EU, the EEA, or the UK, you also have the right to complain to your local data protection authority.
Automated results: F-Levels and training plans are generated automatically from your diagnostic answers using fixed criteria. They are learning aids and have no legal or similarly significant effect on you. You can ask us how the criteria work.
7. Children
The Site is not intended for children under 16. We do not knowingly collect personal information from anyone under 16. If you believe a child has given us information, contact us and we will delete it.
8. Security
We protect personal information with measures that include encrypted connections (HTTPS) across the Site, one-way encryption of passwords, two-step verification and minimum access for administrator accounts, login attempt limits, access logs reviewed monthly, firewalls, and regular backups. Only a small number of trained staff can access personal information.
9. Cookies
We use only essential cookies that keep you logged in and keep the Site secure. We do not use advertising or tracking cookies. You can block cookies in your browser, but you will not be able to log in. If we add analytics in the future, we will ask for your consent first and update this policy.
10. Changes
We will post changes to this policy at least 7 days before they take effect, or 30 days before for important changes such as new categories of data or new recipients. Earlier versions remain available on the Site.
11. Contact
Privacy contact: Sunghoo Park (CEO) · focusforum1@gmail.com · glnoon Co., Ltd., A428, Room 402, 4F, 20 Hakdong-ro 24-gil, Gangnam-gu, Seoul, Republic of Korea
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