个人信息处理方针
本隐私权处理方针对本方针公示的网站提供或收集的信息处理进行说明。另外，通过使用其他公司网站或平台上的公司应用程序来提供或收集的信息处理。
公司是通过本方针公示的网站和其他公司网站或平台上的公司应用程序提供或收集信息的控制器。
公司非常重视用户的个人信息，通过个人信息处理方针，将公司从使用者那里获得的个人信息以什么样的用途和方式使用，并告知您为了保护个人信息采取了什么措施。
本方针从2 0 2 0年开始实施。如以后修改本方针，将通过网站公告事项（或书面、传真、电子邮件等个别公告）进行公告。
公司是通过本方针公示的网站和其他公司网站或平台上的公司应用程序提供或收集信息的控制器。
公司非常重视用户的个人信息，通过个人信息处理方针，将公司从使用者那里获得的个人信息以什么样的用途和方式使用，并告知您为了保护个人信息采取了什么措施。
本方针从2 0 2 0年开始实施。如以后修改本方针，将通过网站公告事项（或书面、传真、电子邮件等个别公告）进行公告。
收集信息及收集方法
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(1) 收集个人信息项目
公司可以收集使用者直接提供的信息。
• 用户提供的信息
公司可以收集使用者直接提供的信息。
服务项目 收集(示例) 网络会员制 服务 ∘ 姓名，电子邮件地址，ID，电话号码，邮件地址，国家信息，统一的识别信息（CI），重复注册确认信息（DI）等 ∘ 未成年人的法定代理人信息（法定代理人的姓名、出生年月、CI、DI等） 线上结账 服务 ∘ 姓名、地址、电话号码、电子邮件地址等 ∘ 帐号、卡号等支付信息 ∘ 配送地址、收件人姓名、收件人联系方式等配送信息 ∘ 招标、采购、销售等信息 社会网络 服务 ∘ 姓名、电子邮件地址、ID、电话号码、邮件地址、国家信息、通讯录（熟人）等 ∘ 摄影场所、文件生成日期等信息 ∘ 会员看过或使用的内容类型，使用者交流或分享内容 ∘ 关于人们、会员的活动频率或期间等会员的服务使用信息
• 用户在使用服务时收集的信息
公司除了使用者直接提供的信息外，还可以在使用者使用公司服务的过程中收集信息。
目录 收集(示例) 设备情报 ∘ 设备识别器、操作系统、硬件版本、设备设置、浏览器类型及设置 网站和应用程序的使用信息、电话号码等 登录情报 ∘ IP地址、日志数据、使用时间、用户输入的搜索词、网络协议地址、cookie及网络信标等 位置情报 ∘ 通过GPS、蓝牙或WIFI信号，包含具体地理位置的仪器 位置信息等（仅限于法律允许的区域） 其他情报 ∘ 用户的服务使用偏好度、广告环境、访问页面等
(2) 收集方法
公司用以下方法收集用户的信息。
• 通过官网,书面形式,传真,电话,邮箱等情报收集等
• 从合作公司提供
收集情报的内容
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公司用以下方法收集用户的信息。
• 会员管理、本人确认等、未经许可的服务使用和不正当利用等的检测及防止
• 关于使用者要求的服务提供的合同履行、费用结算及费用结算等
• 改善现有服务，开发新服务等
• 公司网站或应用程序的功能或政策变更事项的通知
• 根据其他用户的事先同意（例如，用于营销广告等）
• 在联系方式上登记的熟人搜索、告知、自动登记、可能是熟人的其他用户的搜索和通知
• 根据会员服务使用的统计、统计、统计学特点提供服务及广告发布
• 提供宣传性活动信息及参与机会
• 遵纪守法
• 如果利用与本隐私权处理方针中明确的目的不同的用途的信息，公司将获得使用者的同意。[根据个人信息处理方针附录<1>GDPR适用的个人信息合法处理选择]
公开收集到的信息
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公司除以下情况外，不向第三方公开用户的个人信息。
• 公司的子公司、伙伴、服务提供商的公开
- 公司的子公司、伙伴、服务提供商代替公司进行结算处理、履行订单、解决产品配送、纠纷（包括结算及配送纠纷）等服务。
• 使用者事先同意的情况
- 使用者将用户的个人信息与特定企业共享，以获得相关企业的产品及服务的信息为用户选择的
- when the user selects to allow his or her personal information to be shared with the sites or platform of other companies such as social networking sites
- 用户选择用户的个人信息与社交网站等其他公司网站或平台共享。
• 其他用户事先同意的情况
- 要求在法令上公开的情况
- 根据法律规定的程序和方法有调查机关的要求
Cookies,信标及其他
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公司可以通过“cookies”或“Web beacons”等收集非个人的集合信息。
cookies 是一个用于运营公司网站的服务器给用户的浏览器发送的非常小的文本文件，它保存在用户的电脑硬盘中
网络信标是网站或电子邮件上的少量代码。您可以通过使用Web Vintent来了解用户是否与特定的网络或电子邮件内容交互。
这些功能被用来评价和改善服务，使用户体验更适合定制，为用户提供更上一层的服务。
公司收集 cookies 的项目和收集目的如下.
Category Reasons for using cookies and additional information strictly necessary cookies This cookie is a kind of indispensible cookie for the users to use the functions of website of the Company. Unless the users allow this cookie, the services such as shopping cart or electronic bill payment cannot be provided. This cookie does not collect any information which may be used for marketing or memorizing the sites visited by the users
(Examples of necessary cookies)
∘ Memorize the information entered in an order form while searching other pages during web browser session
∘ For the page of products and check-out, memorize ordered services
∘ Check whether login is made on website
∘ Check whether the users are connected with correct services of the website of the Company while the Company changes the way of operating its website
∘ Connect the users with certain application or server of the services
Performance cookies This cookie collects information how the users use the website of the Company such as the information of the pages which are visited by the users most. This data helps the Company to optimize its website so that the users can search that website more comfortably. This cookie does not collect any information who are the users. Any and all the information collected by this cookie will be processed collectively and the anonymity will be guaranteed.
(Examples of performance cookies)
∘ Web analysis: provide statistical data on the ways of using website
Advertisement response fee: check the effect of advertisement of the Company
Tracing affiliated companies; one of visitors of the Company provides anonymously feedback to the affiliated companies
Management of error: measure an error which may occur so as to give a help for improving website
Design testing: test other design of the website of CompanyFunctionality cookies This cookie is used for memorizing the set-ups so that the Company provides services and improves visit of users. Any information collected by this cookie do not identify the users individually.
(Examples of functionality cookies)
Memorize set-ups applied such as layout, text size, basic set-up and colors
Memorize when the customer respond to a survey conducted by the CompanyTargeting cookies or advertising cookies This cookie is connected with the services provided by a 3rd party such as the buttons of 'good' and 'share'. The 3rd party provides these services by recognizing that the users visits the website of the Company.
(Examples of targeting cookies or advertising cookies)
∘ carry out PR to the users as targets in other websites by connecting through social networks and these networks use the information of users' visit
∘ provide the information of users' visit to ad agencies so that they can suggest an ad which may attract the interest of the users
The users have an option for cookie installation. So, they may either allow all cookies by setting option in web browser, make each cookie checked whenever it is saved, or refuses all cookies to be saved: Provided that, if the user rejects the installation of cookies, it may be difficult for that user to use the parts of services provided by the Company.
User’s right
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The users or their legal representatives, as main agents of the information, may exercise the following rights regarding the collection, use and sharing of personal information by the Company:
• exercise right to access to personal information;
• make corrections or deletion;
• make temporary suspension of treatment of personal information; or
• request the withdrawal of their consent provided before
If, in order to exercise the above rights, you, as an user, use the menu of 'amendment of member information of webpage or contact the Company by sending a document or e-mails, or using telephone to the company(or person in charge of management of personal information or a deputy), the Company will take measures without delay: Provided that the Company may reject the request of you only to the extent that there exists either proper cause as prescribed in the laws or equivalent cause.
Option to select 'User’s right when applying GDPR' in Appendix <2>of Personal Privacy Policy]
Security
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The Company regard the security of personal information of uses as very important. The company constructs the following security measures to protect the users' personal information from any unauthorized access, release, use or modification
• Encryption of personal information
- Transmit users' personal information by using encrypted communication zone
- Store important information such as passwords after encrypting it
• Countermeasures against hacking
- Install a system in the zone the external access to which is controlled so as to prevent leakage or damage of users' personal information by hacking or computer virus
• Establish and execute internal management plan
• Install and operate access control system
• Take measures to prevent forging or alteration of access record
Protection of personal information of children
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In principle, the Company does not collect any information from the children under 13 or equivalent minimum age as prescribed in the laws in relevant jurisdiction. The website, products and services of the Company are the ones to be provided to ordinary people, in principle. The website or application of the Company has function to do age limit so that children cannot use it and the Company does not intentionally collect any personal information from children through that function.
(Additional procedure for collecting personal information from children) However, if the Company collects any personal information from children under 13 or equivalent minimum age as prescribed in the laws in relevant jurisdiction for the services for unavoidable reason, the Company will go through the additional procedure of the followings for protecting that personal information of children:• verify, to the extent that efforts are reasonably made, whether they are children of the age at which consent from their guardian is required and the consenting person is an authorized one.
• obtain consent from the parents or guardian of children so as to collect personal information of children or directly send the information of products and services of the Company • give the parents or guardian of children a notice of Company's policy of privacy protection for children including the items, purpose and sharing of personal information collected • grant to legal representatives of children a right to access to personal information of that children/correction or deletion of personal information/temporary suspension of treatment of personal information/ and request for withdrawal of their consent provided before • limit the amount of personal information exceeding those necessary for participation in online activities
Modification of Privacy Protection Policy
- The Company has the right to amend or modify this Policy from time to time and, in such case, the Company will make a public notice of it through bulletin board of its website (or through individual notice such as written document, fax or e-mail) and obtain consent from the users if required by relevant laws.
Others
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[Option to select 'data transfer to other countries ' in Appendix <3> of Personal Privacy Policy]
[Option to select 'sites and service of 3rd party' in Appendix <4> of Personal Privacy Policy]
[Option to select 'guidelines for residents in California' in Appendix <5> of Personal Privacy Policy]
[Option to select 'guidelines for residents in Korea' in Appendix <6> of Personal Privacy Policy]
Contact information of Company
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Please use one of the following methods to contact the Company should you have any queries in respect to this policy or wish to update your information:
• Company name :
Address :
Tel.:
E-mail:
(Add the following if designated of data protection officer) The Company designates the following Data Protection Officer (DPO) in order to protect personal information of customers and deal with complaints from customers.
• DPO of the Company
Adress:
Tel.:
E-mail:
(Add the following if the controller operating outside of the EU designates its deputy in the EU) The Company designates a deputy in the EU in order to protect personal information of customers and deal with complaints from customers.
• Deputy of the Company
Adress:
Tel.:
E-mail:
The latest update date: March 2020.
Appendix of Privacy Protection Policy
<1> Lawful processing of personal information under GDPR
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Processing personal information by the Company shall be lawful only if and to the extent that at least one of the following applies:
• A user has given consent to the processing of his or her personal information.
• Processing is necessary for the performance of a contract to which a user is party or in order to take steps at the request of a user prior to entering into a contract:
-Member management, identification, etc.
-Performance of a contract in relation to providing the services required by users, payment and settlement of fees, etc.
• Processing is necessary for compliance with a legal obligation to which the Company is subject
-Compliance with relevant law, regulations, legal proceedings, requests by the government
• Processing is necessary in order to protect the vital interests of users, or other natural persons
-Detection of, prevention of, and response to fraud, abuse, security risks, and technical issues that may harm users or other natural persons
• Processing is necessary for the performance of a task carried out in the public interest or in the excise of official authority vested in the Company
• Processing is necessary for the purposes of the legitimate interests pursued by the Company or by a third party (except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child).
<2> User’s right when applying GDPR
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The users or their legal representatives, as main agents of the information, may exercise the following rights regarding the collection, use and sharing of personal information by the Company:
• The right to access to personal information;
The users or their legal representatives may access the information and check the records of the collection, use and sharing of the information under the applicable law. • The right to rectification;
- The users or their legal representatives may request to correct inaccurate or incomplete information.
• The right to erasure;
- The users or their legal representatives may request the deletion of the information after the achievement of their purpose and the withdrawal of their consent.
• The right to restriction of processing;
- The users or their legal representatives may make temporary suspension of treatment of personal information in case of the disputes over the accuracy of information and the legality of information treatment, or if necessary to retain the information.
• The right to data portability
- The users or their legal representatives may request to provide or transfer the information.
• The right to object
-The users or their legal representatives may suspend the treatment of personal information if the information is used for the purpose of direct marketing, reasonable interests, the exercise of official duties and authority, and research and statistics.
• The right to automated individual decision-making, including profiling
- The users or their legal representatives may request to cease the automated treatment of personal information, including profiling, which has critical impact or cause legal effect on them.
If, in order to exercise the above rights, you, as an user, use the menu of 'amendment of member information of webpage or contact the Company by sending a document or e-mails, or using telephone to the Company (person in charge of management of personal information or a deputy), the Company will take measures without delay: Provided that the Company may reject the request of you only to the extent that there exists either proper cause as prescribed in the laws or equivalent cause.
<3> Data transfer to other countries
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Considering it engages in global businesses, the Company may provide the users' personal information to the companies located in other countries for the purpose as expressly stated in this Policy. For the places where the personal information is transmitted, retained or processed, the Company takes reasonable measures for protecting those personal information.
(If used in the US, additional security measures may be available) In addition, when the personal information obtained from the European Union or Switzerland is used or disclosed, the Company may have to comply with the US-EU Privacy Shield and Swiss-US Privacy Shield, take other measures or obtain consent from users so far as those complies with the regulations of EU so as to use a standardized agreement provision approved by executing organizations of EU or securing proper safe measures.
<4> 3rd party's sites and services
- The website, product or service of the Company may include the links to the ones of a 3rd party and the privacy protection policy of the site of 3rd party may be different. Thus, it is required for the users to check additionally that policy of a 3rd party site linked to the site of the Company.
<5> Guide for users residing in California
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If the user resides in California, certain rights may be given. The Company prepare preventive measures necessary for protecting personal information of members so that the Company can comply with online privacy protection laws of California.
In case of leakage of personal information, an user may request the Company to check the leakage. In addition, all the users in the website of the Company, can modify their information at any time by using the menu for changing information by connecting their personal account.
Moreover, the Company does not trace the visitors of its website nor use any signals for 'tracing prevent'. The Company will not collect and provide any personal identification information through ad services without consent of users.
<6> Guide for users residing in Korea
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The Company guides several additional matters to be disclosed as required by the information network laws and personal information protection laws in the Republic of Korea as follows:
(1) Information collected
The items collected by the Company are as follows:
• Examples of required information
Title of service Items to be collected(examples) Internet membership service ∘ Name, email address, ID, telephone number, address, national information, encoded identification information (CI), identification information of overlapped membership (DI)
∘ For minors, information of legal representatives (name, birth date, CI and DI of legal representatives)Online payment service ∘ Name, address, telephone number, and email address
∘ For payment with credit card : name of card company, number and expiration of card
∘ For small sum payment charged on the mobile phone: mobile phone number, payment approval number
∘ For payment by remittance: name of bank, account number and password of account
∘ For deposit without a bankbook: name of remitter, contact information
∘ Delivery information including delivery address, name and contact information of recipient
∘ Information of bid, purchase and salesSocial network service ∘ Name, email address, ID, telephone number, address, national information, address list (acquaintance)
∘ Information of place of taking pictures and date of creation of files
∘ Information of service use of members such as the type of contents watched orIn the course of using services, the information as described below may be created and collected:
∘ Information of devices (equipment/device identifier, operation system, hardware version, equipment set-up and telephone number)
∘ Log information (Log data, use time, search word input by users, internet protocol address, cookie and web beacon)
∘ Location information (Information of device location including specific geographical location detected through GPS, Bluetooth or Wifi)
∘ Other created information
• Examples of optional items
The user may reject the collection and use of optional items and, even in case of rejection, there is no limit on use of services
Purpose of collestion Items to be collected(examples) User analysis ∘ The reason for membership, occupation, marriage status, wedding anniversary, interest category and SNS account information Provision of customized ad ∘ Contents and result of marketing activities and event participation Delivery of urgent notice ∘ Information provided by the users regarding execution, maintenance, execution, management of other agreements and event participation Marketing ∘ Preference, advertisement environment, visited pages regarding service use of users
• Additional procedure for collection of sensitive information
If collection of sensitive information is indispensible, the Company may collect it by going through lawful procedure in accordance with relevant laws and regulations. The sensitive information which may be collected by the Company is as follows:
∘ Thoughts and belief
∘ Membership of and withdrawal from labor union or political party
∘ Political opinions
∘ Information of health and sexual life
∘ Genetic information obtained from the result of gene test
∘ Information of criminal record including announcement, exemption and suspension of sentences, care and custody, protective custody, treatment and custody, probation, lapse of suspension of sentence and cancellation of suspension of execution.
(2) Commission for collected personal information
For carrying out services, the Company commissions external professional companies (subcontractors) to process personal information as follows. This commissioned works for processing personal information is carried out by each subcontractor and service only if necessary for providing that service.
In commissioning process of personal information, in order to secure safety of personal information , the Company supervises and ensure to expressly state in the agreement with subcontractors so that those subcontractors will safely process personal information by strictly complying with directions regarding personal information protection, keeping personal information secret, not disclosing it to a 3rd party and being liable for accidents and returning or destructing personal information upon termination of the commission or process.
Name of subcontractors Description of commissioned works (services) AAA Customer service
(3) Details of provision of personal information to 3rd party
Except for the following cases, the Company does not disclose or provide personal information of the users to a 3rd party:
Recipients of information Purpose of use of recipient Items to be provided Period of retention and use of recipient BBB Provision of service tie-up ID, Name and age Until the date when the purpose of use is achieved or period as required by the laws
(4) Period for retention and use of personal information
In principle, the Company destructs personal information of users without delay when: the purpose of its collection and use has been achieved; the legal or management needs are satisfied; or users request: Provided that, if it is required to retain the information by relevant laws and regulations, the Company will retain member information for certain period as designated by relevant laws and regulations. The information to be retained as required by relevant laws and regulations are as follows
∘ Record regarding contract or withdrawal of subscription: 5 years (The Act on Consumer Protection in Electronic Commerce )
∘ Record on payment and supply of goods:5 years (The Act on Consumer Protection in Electronic Commerce )
∘ Record on consumer complaint or dispute treatment: 3 years (The Act on Consumer Protection in Electronic Commerce )
∘ Record on collection/process, and use of credit information: 3 years (The Act on Use and Protection of Credit Information )
∘ Record on sign/advertisement: 6 months(The Act on Consumer Protection in Electronic Commerce )
∘ Log record of users such as internet/data detecting the place of user connection: 3 months(The Protection of Communications Secrets Act )
∘ Other data for checking communication facts: 12 months (The Protection of Communications Secrets Act )
(5) Procedure and method of destruction of personal information
In principle, the Company destructs the information immediately after the purposes of its collection and use have been achieved without delay: Provided that, if any information is to be retained as required by relevant laws and regulations, the Company retain it for the period as required by those laws and regulations before destruction and, in such event, the personal information which is stored and managed separately will never be used for other purposes. The Company destructs: hard copies of personal information by shredding with a pulverizer or incinerating it; and delete personal information stored in the form of electric file by using technological method making that information not restored.
(6) Technical, managerial and physical measures for protection of personal information
In order to prevent the loss, theft, leakage, alteration or damage of personal information of the users, the Company takes technical, managerial and physical measures for securing safety as follows:
Recipients of information Purpose of use of recipient Items Examples Technical measures ∘ Utilize security servers for transmitting encryption of personal information
∘ Take measures of encryption for confidential information
∘ Install and operate access control devices and equipments
∘ Establish and execute internal management planManagerial measures ∘ Appoint a staff responsible for protecting personal information
∘ Provide education and training for staffs treating personal information
∘ Establish and execute internal management plan
∘ Establish rules for writing passwords which is hard to be estimated
∘ Ensure safe storage of record of access to personal information processing system
∘ Classify the level of authority to access to personal information processing systemPhysical measures ∘ Establish and operate the procedure for access control for the facilities for storing personal information ∘ Store documents and backing storage containing personal information in safe places which have locking device
(7) Staff responsible for managing personal information
The staff of the Company responsible for managing personal information is as follows:
• Name of staff responsible for managing personal information:
Dept. :
Tel. :
Contact :
The latest update date: March, 2020.