Privacy Policy

POTEN410 Inc. is the controller (personal information handler) responsible for your personal information.

• Address: 5F, 909-9 Bangbae-dong, Seocho-gu, Seoul, Republic of Korea
• CEO: Yeobeom Yoon
• Business registration no.: 827-86-01806
• Privacy contact (Chief Privacy Officer): info@poten410.com

You can contact us about any question in this policy or to exercise your rights.

Account information - email address, password (stored only in hashed form by our authentication provider), display name, preferred language, country, and sign-in records.

Profile information - display name and name in your native script, date of birth, gender, country and city, height, languages, positions (vocal, dance, rap, visual, acting), biography, Instagram and TikTok handles, your Profile spotlight setting and profile completeness.

Photos and videos - profile photos and performance videos that you upload, which show your face, body and voice, together with technical data such as duration and size. Photos and videos may indirectly reveal information such as ethnic origin; we do not use them to infer such information.

AI analysis results - the visual archetype, strengths, similar visual types and other results generated from your photos, and match scores between your profile and auditions.

Guardian information - for Members under 18: the guardian's name and email address and a record of their consent.

Applications - the auditions you apply to or save, the media and answers you submit, the status history of each application, and messages from us or from Agencies. Agency reviewers may also add ratings and notes.

Inquiries - when you contact us: your name, email address, phone number (optional), country, language, organisation, subject and message, the program you are interested in, whether you are a minor and whether your guardian consents, and the page and campaign from which you sent the inquiry.

Program participation - registrations and attendance for seminars, mock auditions, camps and workshops, and videos recorded there with your consent. For paid programs, transaction records (we do not store full card numbers).

Device and usage information - to understand how the website is used, we record a random anonymous visitor ID and session ID; the pages you view and actions such as button clicks, sign-ups and applications; your language; device type, browser and operating system; an approximate country derived from your device's time-zone setting or browser language; the referring website; and campaign (UTM) parameters. If you choose "Accept all", Google Analytics 4 also collects online identifiers and usage data (see our Cookie Policy). Our hosting providers automatically process IP addresses and technical logs in order to deliver and secure the Service.

We do not collect your precise location, and we do not ask for government identification numbers unless the law requires them for a specific paid service.

• From you - when you sign up, complete your profile, upload media, run AI analysis, apply to auditions, register for programs or contact us.
• From your guardian - when a guardian gives consent or provides information for a minor.
• At our programs - at seminars, mock auditions and workshops you (together with your guardian where required) may register with our staff or partners, and videos recorded at partner studios may be added to your profile with your consent.
• Automatically - from your browser or app, through the storage and analytics described in our Cookie Policy.
• From Agencies - status updates, feedback and notes that Agencies add when they review your applications.
• From schools and academies - only where you or your guardian have asked them to share your details with us, for example to register for a seminar held at your school.

We use personal information to:

• create and manage your account and sign you in securely;
• build and display your talent profile, and show it to Agencies when you apply to their auditions or switch on Profile spotlight;
• provide the AI Features you choose to use, and recommend auditions that suit your profile;
• process applications, share status updates, and enable communication between you (or your guardian) and Agencies;
• verify age and guardian consent, and protect minors;
• run programs, events and challenges, and answer inquiries;
• send service messages, such as application updates, security notices and changes to our terms, and - only with your consent - news and marketing;
• measure and improve the website and the Service using statistics;
• keep the Service safe, including preventing fraud, abuse and fake auditions, and enforcing our Terms of Service;
• comply with legal obligations and respond to lawful requests from authorities.

We will ask for your consent before using personal information for a purpose not described here.

When you use AI face analysis, we process the face image you select in order to generate a visual archetype, strengths and similarity to visual types. This works as follows:

• Explicit consent first. We ask for your explicit consent (and your guardian's consent where required) the first time you run an analysis. The feature is optional - you can use PIVOT410 and apply to auditions without it.
• Used for the Service only. Results are shown to you and form part of your profile. Agencies can see them only when you apply to their auditions or switch on Profile spotlight, to help them find talent that matches the look they are searching for.
• Not used to identify you. We do not use face analysis to identify or verify who you are, to recognise you in other photos or services, or to build a facial-recognition database.
• No sale and no third-party training. We do not sell face images or analysis results, and we do not provide them to third parties to train their AI models.
• You stay in control. You can delete analysis results, and the photo that was analysed, at any time from your account; deleting your account deletes them as well. You can withdraw your consent at any time, which stops any further analysis.
• A human in the loop. AI results are assistive and may be inaccurate. They are not a beauty rating, and no casting decision is made solely by automated means.

Under some laws, facial data is treated as sensitive or biometric information. We apply those protections to AI face analysis wherever you live.

We process personal information on the following legal bases. The references are to the EU and UK General Data Protection Regulation (GDPR); where the law of your country (for example the Republic of Korea, Japan, the People's Republic of China or Taiwan) requires consent for a particular activity, we obtain that consent.

Purpose	Legal basis
Account, profile, applications and programs you book	Performance of our contract with you (Art. 6(1)(b))
AI face analysis	Explicit consent (Art. 6(1)(a) and Art. 9(2)(a))
Sharing with Agencies when you apply or switch on Profile spotlight	Performance of our contract, at your request (Art. 6(1)(b)); consent where required by local law
Guardian information and consent for minors	Legal obligation (Art. 6(1)(c)) and our legitimate interest in protecting minors (Art. 6(1)(f))
Anonymous first-party statistics, security and fraud prevention	Legitimate interests in running and improving a secure service (Art. 6(1)(f))
Google Analytics and marketing messages	Consent (Art. 6(1)(a))
Answering inquiries	Steps taken at your request before a contract, or legitimate interests (Art. 6(1)(b) and (f))
Keeping records required by law and responding to authorities	Legal obligation (Art. 6(1)(c))

Where we rely on consent, you can withdraw it at any time; this does not affect processing carried out before the withdrawal. Where we rely on legitimate interests, you can object (see "Your rights").

We do not sell or rent personal information. We share it only as follows:

• Agencies - when you apply to an audition, the Agency running it can see your profile, the media you submitted, your AI results and your application. If you switch on Profile spotlight, the casting staff of partner Agencies can see your profile, photos, videos and AI results. Agencies may use this information only for casting review, and must contact minors through their guardians. You can switch Profile spotlight off or withdraw an application at any time; Agencies that have already reviewed your information remain bound by their obligations to us and by law.
• Service providers (processors) - companies that process information on our behalf, under contract and on our instructions. They fall into these categories: cloud hosting, database, authentication and file storage (Supabase); website hosting and content delivery (Vercel); email delivery; web analytics (Google Analytics, only if you accept it); and, where applicable, payment processing.
• Program partners - local studios, schools and academies that co-run a program you register for receive the information needed to run it, such as your name and schedule.
• Legal and safety reasons - where required by law, court order or a competent authority, or where necessary to protect the life, safety or rights of any person, particularly minors.
• Business transfers - in a merger, acquisition or sale of all or part of our business, subject to the same protections and with notice to you.
• With your consent - in any other case, only with your consent.

• Our database and file storage are located on servers in the Republic of Korea.
• Our website is delivered through a global content delivery network, so page requests may be routed through servers near you or in other countries. If you accept Google Analytics, Google may process data in the United States and other countries.
• When you apply to an audition or switch on Profile spotlight, Agencies located in other countries (for example the Republic of Korea, Japan, the People's Republic of China or Taiwan) may access your information from those countries.
• Transfers take place by online transmission when you use the relevant feature. We protect them with contractual safeguards (such as data processing agreements and, where required, standard contractual clauses), access controls and encryption, and we obtain your consent where the law requires it (see the regional sections below).
• The European Commission and the United Kingdom have recognised the Republic of Korea as providing an adequate level of data protection.

You can refuse a transfer by not using the related feature - for example by not applying to an Agency's audition, keeping Profile spotlight off, or choosing "Essential only" for analytics. The related feature will then not be available.

• Account, profile, media and AI results - while your account is active. You can delete individual photos, videos or AI results at any time.
• After you delete your account - we delete or anonymise your personal information within 30 days, except for records we must keep by law, or information needed to resolve a dispute or investigate abuse. For example, under Korean e-commerce law, records of contracts and payments are kept for 5 years and records of consumer complaints for 3 years; website access logs are kept for 3 months under Korean telecommunications law.
• Applications - while your account is active. Copies already reviewed by an Agency are handled under that Agency's obligations.
• Inquiries - 3 years after the inquiry is closed, then deleted.
• Analytics - first-party analytics events use anonymous IDs and are kept only as long as needed for statistics; they are then deleted or aggregated so they no longer relate to any identifier. Event-level Google Analytics data is kept for no longer than 14 months.
• Backups - removed in the normal backup cycle.

When information is deleted, electronic files are erased using methods that prevent recovery, and any paper records are shredded.

• The Service is not intended for children under 13, and we do not knowingly collect their personal information. If we learn that we have, we delete it.
• Members under 18 need their guardian's consent to use the Service. We collect the guardian's name, email address and consent, and we may contact the guardian to verify it.
• Where local law sets a higher age for consent to data processing (for example under 14 in the People's Republic of China and the Republic of Korea, or up to 16 in some EU countries), we obtain verifiable consent from the guardian before processing.
• Guardians may request access to, correction or deletion of their child's information, and may withdraw consent at any time, by emailing info@poten410.com.
• Agencies must contact Members under 18 through, or together with, their guardians. We take extra care with minors' photos and videos, and never use them in public advertising without the guardian's separate consent.

We use technical and organisational measures appropriate to the sensitivity of the information, including:

• encryption in transit (HTTPS) and encryption at rest provided by our hosting providers;
• private storage for Members' photos and videos, accessed through short-lived signed links;
• database access rules (row-level security) so that each Member can access only their own data, and Agencies only the information they are permitted to see;
• role-based access for our staff and Agency reviewers, with activity logs;
• confidentiality obligations for staff, and regular review of our security measures.

No system is perfectly secure. If a personal data breach affects you, we will notify you and the relevant authorities as required by law.

Subject to the law that applies to you, you have the right to:

• Access - obtain confirmation of whether we process your personal information and a copy of it;
• Rectification - have inaccurate or incomplete information corrected;
• Deletion - have your information deleted;
• Restriction - ask us to limit how we use your information;
• Portability - receive the information you provided in a structured, commonly used format, or have it sent to another service;
• Objection - object to processing based on legitimate interests, and to direct marketing at any time;
• Withdraw consent - at any time, for example for AI face analysis, Google Analytics or marketing;
• Human review - we do not make decisions with legal or similarly significant effects about you solely by automated means.

Many of these you can do directly in your account: edit your profile, delete photos, videos or AI results, switch Profile spotlight off, withdraw applications, or delete your account.

• The legal bases we rely on are listed in "Legal bases for processing".
• You have the rights listed in "Your rights".
• You may lodge a complaint with the data protection supervisory authority in the country where you live or work, or where you believe an infringement took place. In the United Kingdom, this is the Information Commissioner's Office (ICO).
• Personal information is stored in the Republic of Korea, which the European Commission and the United Kingdom recognise as providing adequate protection. Other transfers are protected as described in "International transfers".
• Where the law requires it, we will appoint a representative in the EU or the UK and publish its contact details in this policy.

• We handle personal information of people in Japan in accordance with the Act on the Protection of Personal Information (APPI).
• You may request notification of the purposes of use, and disclosure (including records of provision to third parties), correction, addition or deletion, suspension of use, erasure, and suspension of provision to third parties of retained personal data, as provided by the APPI.
• Provision to third parties in foreign countries. Your personal information is stored in the Republic of Korea and may be provided to Agencies in other countries when you apply to their auditions or switch on Profile spotlight. We obtain your consent for such provision. The Republic of Korea has a comprehensive personal information protection law (the Personal Information Protection Act), supervised by the Personal Information Protection Commission. Information about the data protection system of the country where a particular Agency is located is available on request.
• Security control measures. We have established the measures described in "How we protect information", taking into account the legal system of the Republic of Korea, where the data is stored. Further details are available on request.
• Our name, address and representative are listed in "Who is responsible for your information".

• Separate consent. We obtain your separate consent before: (a) transferring your personal information outside the People's Republic of China to POTEN410 in the Republic of Korea and to Agencies in other countries; (b) processing sensitive personal information, including facial images, face analysis results, and any personal information of minors under 14; and (c) providing your personal information to Agencies as other personal information handlers.
• Minors under 14. We obtain the consent of the parent or other guardian, and apply special processing rules to their personal information.
• Overseas recipients. POTEN410 Inc. (Republic of Korea; contact info@poten410.com) and the Agencies whose auditions you apply to or who view your profile through Profile spotlight. The purposes, methods and categories of personal information are described in this policy. You can exercise your rights against overseas recipients by contacting us.
• Your rights. You have the right to know about and decide on the processing of your personal information, to restrict or refuse processing, to access and copy it, to request its transfer to another handler where the conditions set by the authorities are met, to correct and supplement it, to have it deleted, to withdraw consent, and to ask us to explain our processing rules. Close relatives of a deceased Member may exercise certain rights as provided by law.
• Where the law requires it, we will designate a specialised agency or representative in the People's Republic of China and provide its details to the competent authorities.
• You may lodge a complaint with the competent authority responsible for personal information protection.

In accordance with the Personal Data Protection Act, we inform you that:

• Collector: POTEN410 Inc.
• Purposes: as described in "How we use information".
• Categories of personal data: as described in "Information we collect".
• Period of use: as described in "How long we keep information".
• Area of use: the Republic of Korea, Taiwan, and the countries where the Agencies you apply to, or who view your profile through Profile spotlight, are located.
• Recipients: POTEN410, our service providers, and Agencies as described in "How we share information".
• Method of use: automated and manual processing by electronic means.
• Your rights: you may make an inquiry or request to review your personal data, request copies, request supplementation or correction, request that collection, processing or use be stopped, and request deletion. We may charge a reasonable fee for copies where the law allows.
• You may choose not to provide your personal data; however, we may then be unable to create your profile, process your applications or answer your inquiry.

In accordance with the Personal Information Protection Act (PIPA):

• Items, purposes and retention periods are described in "Information we collect", "How we use information" and "How long we keep information". We process personal information only within the scope of your consent or as permitted by law.
• Provision to third parties: to Agencies whose auditions you apply to, or who view your profile through Profile spotlight. Items: profile, photos, videos, AI results and application details. Purpose: casting review. Retention: until the casting purpose is achieved, subject to the Agency's obligations and applicable law.
• Entrustment of processing: we entrust processing to the categories of service providers listed in "How we share information", and supervise them under contract.
• Overseas transfer: the items, destination countries, timing and method, recipients, purposes, retention period and how to refuse are described in "How we share information" and "International transfers".
• Destruction: when the retention period ends or the purpose is achieved, we destroy personal information without delay using the methods described in "How long we keep information".
• We do not collect resident registration numbers. AI face analysis is performed only with your separate consent.
• For children under 14, we obtain the consent of their legal representative.
• Chief Privacy Officer: the privacy officer of POTEN410 Inc. can be reached at info@poten410.com.
• Remedies: in addition to contacting us, you may seek help from the Personal Information Dispute Mediation Committee (1833-6972, www.kopico.go.kr), the Personal Information Infringement Report Center (118, privacy.kisa.or.kr), the Supreme Prosecutors' Office (1301) or the Korean National Police Agency (182).

• Use the settings in your account where available.
• Otherwise, email info@poten410.com - ideally from the email address linked to your account - or write to us through our contact page, stating which right you wish to exercise.
• Guardians and authorised representatives may make requests on a Member's behalf with proof of their authority.
• To protect you, we verify your identity before acting on a request.
• We respond within 30 days, or within any shorter period required by the law that applies to you. If we need more time, or cannot fulfil a request, we will tell you why and explain how you can complain.
• Exercising your rights is free of charge, unless a request is manifestly unfounded or excessive, or the law allows a fee (for example for copies).

We mainly use browser storage (localStorage and sessionStorage) to run the website and to produce anonymous statistics. Google Analytics cookies are used only if you choose "Accept all". For details, including how to change your choice, please see our Cookie Policy.

We may update this policy to reflect changes to the Service or the law. We will post the updated policy on this page with a new effective date. We will notify you of changes on the Service or by email at least 7 days before they take effect, or at least 30 days before for material changes that affect your rights. Where the law requires your consent to a change, we will ask for it again.

POTEN410 Inc. - Privacy

• Address: 5F, 909-9 Bangbae-dong, Seocho-gu, Seoul, Republic of Korea
• Email: info@poten410.com
• Online: Contact page