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Privacy Policy

Couple.net Privacy Policy

1. General Provisions

Couple.net is a global matchmaking platform owned and operated by Sunoo Inc., a corporation organized under the laws of the United States.
Korean-language services, Korean member consultation, customer support within Korea, member management, and certain operational activities may be handled by Sunoo Co., Ltd. or other Korean operating entities.
The Company transparently discloses through this Privacy Policy the ownership and operational structure of the service, the scope of Korean operational activities, overseas processing and storage structures, and the methods by which personal information is processed.

This Privacy Policy applies to Couple.net websites, mobile websites, applications, multilingual services including Korean, English, Chinese, and Japanese, member registration, profile registration, matching, AI recommendations, couple manager consultation, payment processing, customer support, events, communications, and all related ancillary services.
Depending on the country, language, operational entity, payment structure, consultation method, or local regulations, certain personal information processing structures may differ, and separate notices or consent procedures may apply where necessary.
The Company complies with applicable laws including the Personal Information Protection Act, the Act on Promotion of Information and Communications Network Utilization and Information Protection, the Communications Secrets Protection Act, the Telecommunications Business Act, and other relevant laws, and strives to protect the rights and interests of data subjects.

2. Scope of Personal Information Processing by Korean Operating Entity

The Korean operating entity processes personal information only within the scope necessary for Korean-language services, Korean member consultation, member management, matching consultation, identity verification support, payment/refund support, customer inquiries, complaint handling, and related operational activities within Korea.
The personal information processed by the Korean operating entity does not mean the entirety of Couple.net’s global member database, but is limited to the scope necessary for Korean-language services and Korean data subjects.
However, due to the nature of global matchmaking services, personal information may be processed overseas or transferred to overseas operators in connection with international matching, overseas infrastructure operation, international payment systems, messaging systems, email systems, cloud services, and related functions.

3. Basic Principles of Personal Information Processing

Due to the nature of marriage-oriented and serious relationship matchmaking services, the Company may process more detailed personal information than ordinary community, bulletin board, or simple chat services.
Such processing is necessary for member identification, identity verification, profile reliability verification, matching suitability analysis, consultation, recommendations, dispute prevention, fraud prevention, service quality improvement, and compliance with applicable laws.
The Company places importance on the principles of minimum collection and minimum retention of personal information. In particular, original or image files of verification documents such as identification documents, educational certificates, employment certificates, marital status documents, and family relationship documents are deleted immediately after verification as a principle.
However, the Company may retain minimum verification records such as verification items, verification dates, verification results, verification personnel, consistency checks, member statements, or electronic signature records where necessary for legal compliance, dispute response, fraud prevention, service reliability, or restriction of re-registration.

4. Categories of Personal Information Collected and Used

The Company may collect and use the following categories of personal information for service provision.
1) Member Registration and Account Management
Name, date of birth, gender, contact information, email address, ID, password, nationality, country of residence, region, language settings, registration route, and identity verification information.
2) Profile Registration and Matching Services
Photographs, self-introduction, height, body type, educational background, major, school, occupation, workplace, region, marital history, children, family relationships, religion, values, lifestyle, smoking/drinking habits, hobbies, spouse preferences, matching preferences, willingness to meet, and service usage history.
3) Identity Verification and Certification
Submission status of identity verification materials, educational verification materials, employment verification materials, marital status verification materials, family relationship verification materials, verification items, verification dates, verification results, verification personnel, consistency checks, member statements, and electronic signature records.
4) AI Matching and Recommendation
Profile information, spouse preferences, personality test results, matching preferences, matching history, consultation history, and service usage records.
5) Payment and Refunds
Payment amount, payment date, payment method, approval number, order number, payment processing results, refund account information, and refund processing history.
Sensitive financial information such as full credit card numbers or account passwords may not be directly stored by the Company and may instead be processed by payment service providers or related vendors.
6) Consultation and Customer Support
Consultation details, inquiry details, complaint records, processing history, phone calls, text messages, emails, messenger consultation records, customer support records, and dispute handling records.
7) Events and Promotions
Event participation records, participation status, prize information, promotional responses, and campaign activity records.
8) Security and Access Management
Access logs, IP addresses, cookies, device information, browser information, operating systems, access dates and times, service usage records, abnormal access detection logs, and security logs.

5. Processing of Sensitive and High-Risk Personal Information

Due to the nature of marriage and serious relationship matchmaking services, the Company may process highly sensitive or privacy-related information including marital history, family relationships, educational background, occupation, religion, photographs, personality test results, spouse preferences, and consultation details.
Such information shall only be used within the purposes specified in this Privacy Policy, including matching, consultation, identity verification, profile reliability verification, service provision, fraud prevention, and dispute response.
Members understand and agree that a certain level of detailed information may be necessary for the operation of matchmaking services.

6. Purposes of Collection and Use of Personal Information

The Company may use collected personal information for the following purposes:
1) Member identification and identity verification
2) Confirmation of membership registration intent and account management
3) Provision of matchmaking services for marriage or serious relationships
4) AI-based personalized recommendations
5) Couple manager consultation, introduction, scheduling coordination, and follow-up support
6) Profile viewing, recommendations, and exchange of contact information between members
7) Payment processing, settlement, and refund processing
8) Customer support, complaint handling, and dispute resolution
9) Notice delivery, policy updates, and security alerts
10) Fraud prevention, misuse prevention, and violation detection
11) Service quality improvement, statistical analysis, and new service development
12) Events, promotions, marketing, and advertising
13) Cooperation with affiliates or partner services
14) Compliance with laws and governmental or judicial requests
15) Security incident investigation, damage mitigation, and recurrence prevention

7. Profile Disclosure and Exchange of Contact Information Between Members

The Company may disclose certain portions of a member’s profile to recommended candidates or matching candidates for the purpose of providing matchmaking services.
Information that may be disclosed includes photographs, self-introduction, age or age range, region, educational background, occupation, marital history, children, religion, and spouse preferences necessary for matching decisions.
However, contact information, detailed identity information, and original verification documents shall only be disclosed in a limited manner pursuant to mutual consent, separate consent, or procedures established by the Company.
Members understand and agree that certain portions of their profile information may be disclosed to other approved members as an essential part of the matchmaking service.

8. AI Matching and Algorithmic Recommendations

The Company may analyze member profiles, spouse preferences, personality test results, consultation details, service usage history, and matching history in order to recommend matching candidates.
AI or algorithmic recommendations are only supportive tools intended to improve the likelihood of successful introductions and do not automatically determine marriage, dating, contact exchange, or final member decisions.
The final decision regarding meetings, exchange of contact information, or continued use of the service remains entirely with the member.
The Company does not guarantee the accuracy, completeness, or satisfaction of AI recommendations and may not disclose all recommendation criteria or detailed algorithm structures.

9. Verification Documents and Retention of Verification Records

Verification documents including identification documents, educational certificates, employment certificates, marital status documents, and family relationship documents are used solely for identity verification, qualification verification, profile reliability verification, fraud prevention, and dispute prevention purposes.
The Company deletes original documents, copies, or image files immediately after verification as a principle.

However, the Company may retain minimum verification records necessary for legal compliance, dispute response, fraud prevention, restriction of re-registration, and service reliability, including:
1) Verification items
2) Verification dates
3) Verification results
4) Verification personnel
5) Consistency checks
6) Member statements or declarations
7) Electronic signature records
8) Minimum logs necessary for dispute response
The Company’s policy of deleting original verification documents is intended to reduce the risk of data breaches and strengthen protection of data subjects.
Verification or retention of verification records by the Company does not constitute a guarantee of the complete truthfulness of member information.

10. Information Provided by Parents or Guardians

The Company may allow parents or guardians to participate in consultation, registration, information submission, document submission, or matching discussions on behalf of their children for certain services.
In such cases, the Company may process the parent’s or guardian’s name, contact information, relationship to the member, consultation details, profile information relating to the child, family information, preferred conditions, and parental confirmation or declaration documents.
The person providing such information and the related member are responsible for the accuracy and legality of the information provided.

11. Information Collected from Other Members or Third Parties

The Company may receive information about users from other members, parents, guardians, partners, affiliates, or third parties in addition to information directly provided by the user.

Examples include:
1) Reports, inquiries, feedback, or introductions made by other members
2) Information submitted by parents or guardians on behalf of children
3) Accounts or advertising performance data linked through partner websites
4) Results information delivered by payment or verification-related vendors
5) Information necessary for dispute resolution, complaint handling, or fraud prevention

12. Automatically Collected Information and Cookies

The Company may automatically collect information regarding service usage, devices, access environments, and system logs when users access or use the service.
Automatically collected information may include access dates and times, IP addresses, cookies, device information, browser information, operating systems, visited pages, click records, search history, service usage records, advertising responses, error logs, and security logs.
The Company may use cookies or similar technologies for personalized services, login maintenance, security management, usage analysis, and advertising effectiveness measurement.
Users may refuse cookie storage through browser settings, although certain services requiring login or personalized features may become limited.

13. Provision of Personal Information to Third Parties

As a principle, the Company processes personal information only within the scope of the stated purposes of collection and use. Personal information may only be provided to third parties where permitted by law or with the data subject’s consent.

Personal information may be provided in the following circumstances:
1) Disclosure of limited member profile information to matching candidates
2) Exchange of contact information between members upon mutual consent
3) Where the member has separately consented
4) Where disclosure is required by law or by governmental, judicial, or investigative authorities
5) For dispute resolution, legal obligations, or protection of life and bodily safety
6) Provision in a non-identifiable form for statistical analysis, research, or service improvement

14. Outsourcing of Personal Information Processing

The Company may outsource certain personal information processing activities to specialized external vendors for stable operation and service provision.

Outsourced tasks may include:
1) Cloud infrastructure operation and data storage
2) SMS messaging
3) Email delivery
4) Payment processing
5) Security monitoring
6) WAF and security solution operation
7) Customer management systems
8) Data backup and recovery support
9) Customer support tools
10) Log analysis and incident response
11) System maintenance and operational support
The Company enters into agreements with outsourced vendors in accordance with applicable laws and supervises such vendors regarding confidentiality, security measures, restrictions on re-outsourcing, return or deletion after termination, and liability for incidents.

15. Overseas Transfer and Overseas Processing

The Company may process personal information overseas or transfer personal information to overseas operators for purposes including global matchmaking services, system operation, data storage, messaging, email delivery, payment processing, security monitoring, customer support, overseas consultation, and matching support.

Where overseas transfers occur, the Company shall provide notice or obtain consent in accordance with applicable laws regarding:
1) Destination country
2) Recipient
3) Categories of transferred information
4) Purpose of transfer
5) Timing and method of transfer
6) Retention and usage period
7) Rights to refuse overseas transfer and disadvantages of refusal
8) Information regarding overseas vendors or service providers

Members may refuse overseas transfers, although services may become limited where such transfers are essential to the operation of global matchmaking services.
The Company strives to implement legally required protective measures even where personal information is processed overseas.

16. Retention and Use Period of Personal Information

The Company shall delete personal information without delay once the purposes of collection and use have been achieved.
Upon membership withdrawal, the Company shall delete personal information without delay as a principle.

However, the Company may separately retain minimum necessary information for purposes including:
1) Compliance with applicable laws
2) Payment settlement
3) Complaint handling
4) Dispute resolution
5) Prevention of fraudulent registration and re-registration
6) Verification of matching history
7) Security incident investigation
8) Judicial, investigative, or administrative proceedings
9) Payment and refund history
10) Service reliability and member protection

Separated information shall be deleted without delay once the retention purpose has expired or the legally required retention period has elapsed.
Original verification documents, copies, or image files are deleted immediately after verification as a principle, while minimum verification records may be retained where necessary.

17. Retention Required by Law

The Company may retain certain personal information or transaction records for periods required under applicable laws.
Examples include records regarding contracts or withdrawal of subscription, payment and service supply records, complaint or dispute handling records, and access logs.
Where laws relating to matchmaking services require retention of certain documents or records, the Company may prioritize minimum verification records rather than long-term retention of original documents where legally permissible.
Where retention of originals is unavoidable under law or official interpretation, the Company applies encryption, masking, access restrictions, and separate storage measures.

18. Blacklists and Restricted Members

The Company may manage internal restricted-member lists or blacklists relating to members involved in false information registration, false declarations, fraud, stalking, violence, threats, member harm, illegal activities, hacking, spam, data leaks, or policy violations.
In such cases, the Company may retain minimum identifying information and records necessary for preventing re-registration, protecting members, legal 대응, and investigative cooperation.

19. Non-Member Information Processing

The Company may process information relating to non-member consultation applicants, inquiry submitters, event participants, referral candidates, or information relating to children mentioned during parental consultation processes.
Such information shall only be used within the necessary scope for consultation, inquiry response, event operation, complaint handling, dispute response, or refusal-management purposes.

20. Protection of Children’s Personal Information

The Company does not intentionally collect personal information from individuals under the age of 18 and does not provide services to minors as a principle.
Where the Company becomes aware that personal information of a minor has been collected, the Company may delete such information or restrict its use in accordance with applicable laws and internal policies.

21. Links, Third-Party Services, and External Platforms

The Company’s services may include external links, advertisements, affiliate services, social logins, third-party payment systems, and external communication tools.
Where users access or use such external services, the privacy policies of those operators may apply, and the Company may not have direct control over such processing.

22. Security Measures

The Company implements technical, managerial, and physical safeguards including:
1) Encryption of personal information
2) Minimum access rights and access control
3) VPN-based administrator access control
4) Retention and monitoring of access logs
5) Intrusion prevention and intrusion detection
6) WAF deployment
7) Security monitoring
8) Backup and recovery systems
9) Administrator account management
10) Internal management plans
11) Employee training
12) Physical access control
13) Monitoring of abnormal access and suspicious behavior
14) Immediate deletion of verification documents and minimum-record retention policies
15) Restrictions on unauthorized downloading, copying, or external transmission
However, no security system can guarantee absolute security due to the nature of the Internet and information systems.

23. Security Incident Response and Notification

Where personal information leakage, loss, theft, alteration, damage, ransomware, or unauthorized access occurs or is reasonably suspected, the Company shall take measures required by law including investigation, damage mitigation, reporting to authorities, and notification to affected data subjects.
Where the scope or existence of leakage has not yet been confirmed, the Company may provide notice based on confirmed facts and ongoing investigation status.
Notification at the investigation stage does not necessarily constitute confirmation of a data leak.

24. Rights of Data Subjects

Members may exercise rights under applicable laws including:
1) Access to personal information
2) Correction
3) Deletion
4) Suspension of processing
5) Withdrawal of consent
6) Membership withdrawal
7) Refusal of marketing communications
8) Refusal of overseas transfers
9) Requests regarding profile disclosure scope
The Company shall process such requests within legally required periods following identity verification.

25. Marketing Communications

Where consent has been obtained, the Company may send marketing, promotional, advertising, or service information via email, SMS, push notifications, telephone, or messaging services.
Members may opt out at any time.

26. Destruction Procedures and Methods

Electronic personal information shall be deleted using methods that make recovery difficult or impossible.
Paper documents shall be shredded or incinerated.
Backup data may not be immediately deleted due to technical limitations but shall not be used for purposes other than recovery and shall be deleted according to retention schedules.

27. Multilingual Privacy Policies

Couple.net may provide services in multiple languages including Korean, English, Chinese, and Japanese, and the core contents of each language version shall be maintained consistently.

28. Privacy Officer and Contact Informatio

Privacy Officer: Woong Jin Lee
Department: General Management Team
Email: ceo@sunoo.com
Contact: +82-1588-2004
Address: 2F, 108 Pyeongchangmunhwa-ro, Jongno-gu, Seoul, Republic of Korea

US Center:
Email: usa@sunoo.com
Contact: 213-435-1113

29. Policy Changes

The Company may revise this Privacy Policy due to legal amendments, service changes, policy updates, security environment changes, internal procedural improvements, or global operational restructuring.

30. Final Notice and Limitation of Liability

The Company strives to protect personal information through reasonable safeguards and minimum-data retention policies.
However, the ultimate responsibility for the truthfulness of information submitted by members rests with the member or the parent/guardian providing such information.
The Company cannot completely prevent all damages arising from external attacks, user negligence, system failures, force majeure events, or matters beyond the Company’s reasonable control.
Supplementary Provision
This Privacy Policy shall take effect on May 1, 2026.