Amid a surge in 'refund agency' services claiming to process mobile game refunds on behalf of users, consumer harm concerns are growing due to the virtual absence of legal regulations. Some agencies are using methods that exploit app market policies and game company terms of service, resulting in user account suspensions and even personal information leaks.
Searching for terms like 'game refund site' or 'Google refund agency' on Google and Naver reveals dozens of refund agency services. Promotional text from a refund agency. / Screenshot from website
When searching for terms like "game refund site" or "Google refund agency" on Google and Naver, dozens of refund agency services appear. These agencies attract users with promotional phrases such as "100% refund possible even after using items," "expert consultation," and "direct inquiry with headquarters."
Refund agencies have grown by exploiting mobile game users' perception that app market refund procedures are difficult. In the case of Google Play Store, Google directly handles refunds within 48 hours of purchase, but after this period, users must contact the game company or app developer directly. In such cases, refund approval varies according to each game company's terms of service.
Refund agencies charge fees of approximately 10-30% of the refund amount under the pretext of handling these procedures. The Korean Bar Association has interpreted that under the Attorney-at-Law Act, non-lawyers engaging in 'legal affairs' such as representing others' rights relief or dispute mediation for financial purposes is illegal. Google and Apple's app market terms of service also strictly prohibit sharing account and payment information with third parties or requesting refunds based on false pretenses.
"Got the Money, But Account Permanently Suspended"... The Trap of Refund Agencies That Victimizes Gamers
The problem is that the refund agency business causes significant side effects, including deceiving users through false advertising. Some agencies advertise that refunds are possible even for games from major game companies. However, Google Play Store does not accept any refund inquiries for games from major Korean game companies (Nexon, Netmarble, NCSOFT, etc.).
Other agencies promote that refunds are possible solely based on reasons like continuous paid item releases, which are not the game company's fault such as item non-delivery. However, industry experts evaluate that such subjective reasons make refunds difficult in principle. This is because, under the Electronic Commerce Act, proof of objective defects in products or services must be established for refunds to be approved.
The biggest problem occurs when some agencies attempt refunds by exploiting app market policies. While the actual refund reason is 'simple change of mind,' they apply for withdrawal to Google by changing it to reasons with higher success rates (minor's payment, system error).
In such cases, game companies may recognize these as abnormal refund cases and impose account suspension or service usage restriction measures on users. In particular, receiving money by deceiving the platform after already using the goods can be subject to criminal prosecution for fraud (fraud using computers, etc.) and obstruction of business against game companies under criminal law.
Cases of game accounts being suspended after using refund agencies are increasing in actual game communities. Some users have confirmed numerous opinions such as "I received the refund but game access was blocked" and "my account was permanently suspended for allegedly abusing refunds."
Actual refund agency transactions are mostly conducted through KakaoTalk open chats. / Screenshot from website
Growing Risks of Personal Information Leaks and Upfront Payment Scams
Personal information leak risks are also pointed out. While some refund agencies operate websites, actual transactions often occur through KakaoTalk open chats. In this process, it's common to require users to provide Google/Apple account email addresses and passwords, names, addresses, and mobile phone numbers.
Experts warn that the act of users handing over account information to third parties is extremely dangerous in itself, as it can lead to account takeover or personal information leaks. Places that require upfront fee payments should also be avoided. The possibility of so-called 'exit scam' damage, where they cut off contact after receiving upfront payments, cannot be ruled out.
Attorney Kim Tae-rim of Axis Law Office stated, "There is currently no law requiring registration or permission for the refund agency business itself, so it's difficult to definitively call the business itself illegal," while pointing out that "however, the method of collecting users' account emails and passwords as is through open chat has potential violations of security obligations under the Personal Information Protection Act."
He added, "Open chat is a channel accessible to many, and if collected authentication information is stored and managed on agency servers or devices without encryption, it directly leads to secondary damage in case of loss or leak," and "cases of damage from collecting upfront fees and disappearing or misusing collected account information are being repeatedly reported."
The need for institutional improvements is also raised, given that the refund agency business is essentially operating outside the regulatory system. This is because even under the Electronic Commerce Act, there are no means of remedy if an account is suspended after using an agency service, and refund provisions for paid transactions are also missing from Game Industry Act amendments.
Lee Chul-woo, Chairman of the Korea Game Users Association, said, "The refund agency business lacks clear regulations in information and communications network infringement, Fair Labeling and Advertising Act, or Electronic Commerce Act violations, making consumer damage relief difficult," and "the fact that there's no way for users to receive compensation when accounts are suspended for terms of service violations is a major problem.“
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