Compliance and user protection notice

Effective: May 16, 2026

Divult (the "Company") complies with applicable laws in the jurisdictions it serves, including related self-regulation. This page forms part of the Terms of Service and Refund Policy, summarizing what users acknowledge at signup.

1. Nature of the service

• Divult is a second-hand / e-commerce intermediary platform for trading digital twins of physical trading cards.
• Cash issued by the Company is a prepaid electronic payment instrument used solely within the service (see Refund Policy for unused balance refunds).
• Twin trades between members are intermediated by the Company; the Company does not buy members' twins itself.
• This service is not a Virtual Asset Service Provider (VASP). The Company does not tokenize card twins on blockchain or transfer them to external virtual asset exchanges/wallets. The Company voluntarily complies with the intent of AML/CFT obligations.

2. Probabilistic content user protection

Pull is a probabilistic digital content product with disclosed per-card odds. The Company follows these principles.

1. Odds disclosure — Every Pull product discloses per-card odds on its page, enforced server-side. The Company cannot change disclosed odds arbitrarily; changes require a new product.
2. Payment limit management — Members can purchase Pull within set daily/monthly limits. Over-limit payments are auto-blocked.
3. Self-imposed limits — Members can lower their own payment limits or temporarily pause payments from My Page (anti-overuse).
4. Minor protection — Members under 19 are restricted from Pull purchases (under 14 cannot sign up).
5. Refund disclosure upfront — The Pull payment screen states clearly that refunds are impossible after results are revealed; payment proceeds only after explicit confirmation.

3. AML and suspicious transaction monitoring

1. The Company detects and blocks the following via system and operator monitoring.
   • Self-trading across the same member/IP/device/payment method
   • Price manipulation via repeated circular trades among related multi-accounts
   • Abnormal patterns of repeated top-up · instant trade · shipout
2. For suspicious transactions, the Company may request additional verification (email/phone/ID copy), hold shipouts, hold payouts, or temporarily suspend accounts.
3. When law enforcement or tax authorities lawfully request records, the Company provides them.
4. Members cannot transfer, lease, or sell their accounts to others; violations result in permanent suspension.

4. Identity verification and transaction limits

Changing limits, lowering your own limits, and pausing payments are available on My Page → Payment limit settings.

5. Cash (prepaid electronic payment) operation

1. Cash topped up by members is managed separately from the Company's own assets; the Company holds funds equal to total unused Cash.
2. Cash is valid for 5 years from top-up; unused Cash past 5 years lapses per applicable law. The Company notifies members 30 days before expiry.
3. Members can request refunds of unused Cash; if over 60% of a top-up has been used, no additional fee is charged for the remaining balance refund.
4. The Company records Cash balance changes via a double-entry ledger; members can review all changes on My Page.

6. Minor and youth protection

1. Members under 14 cannot sign up. We check via birthdate at signup; accounts found later are deleted immediately.
2. Members under 19 may be restricted from Pull products, auction bidding, and physical shipouts; payment requires guardian consent.
3. Guardians may request cancellation of a minor's payments under applicable law; the Company will refund after review (except revealed Pulls, which remain non-refundable).

7. External dispute/consultation bodies

• Korea Consumer Agency — 1372 / www.kca.go.kr
• Electronic Commerce Mediation Committee — www.ecmc.or.kr
• Financial Supervisory Service — 1332 / www.fss.or.kr
• Personal Information Infringement Report Center — 118 / privacy.kisa.or.kr

8. Policy changes

This policy may change with revisions to applicable law or operating policy. Members will be notified at least 7 days before the effective date (30 days for material changes).

9. Contact

→ Terms  ·  → Privacy  ·  → Refund policy