This Privacy Policy (the "Policy") explains the way of treatment of the information which is provided or collected in the websites on which this Policy is posted. In addition the Policy also explains the information which is provided or collected in the course of using the applications of the Company which exist in the websites or platforms of other company.
Through this Policy, the Company regards personal information of the users as important and inform them of the purpose and method of Company's using the personal information provided by the users and the measures taken by the Company for protection of those personal information.

1. Information to be collected and method of collection
(1) Personal information items to be collected
Personal information items to be collected by the Company are as follows:
∘ Name, email address, ID, telephone number, address, national information, address list (acquaintance)
∘ Information of service use of members such as the type of contents watched or used by members, frequencies and period of activities of members
∘ Equipment identifier, operation system, hardware version, equipment set-up and telephone number ∘ Log data, use time, search word input by users, internet protocol address, cookie and web beacon
∘ Preference, advertisement environment, visited pages regarding service use of users

2. Use of collected information
The Company uses the collected information of users for the following purposes:
• Member management and identification
• To detect and deter unauthorized or fraudulent use of or abuse of the Service
• Performance of contract and service fee settlement regarding provision of services demanded by the users
• Improvement of existing services and development of new services
• Making notice of function of company sites or applications or matters on policy change
• To help you connect with other users, and allow other users to connect with you
• To make statistics on member’s service usage, to provide services and place advertisements based on statistical characteristics
• To provide information on promotional events as well as opportunity to participate
• To comply with applicable laws or legal obligation
• Use of information with prior consent of the users (for example, utilization of marketing advertisement)

The Company agrees that it will obtain consent from the users, if the Company desires to use the information other than those expressly stated in this Policy.

3. Sharing collected information
Except for the following cases, the Company will not share personal information with a 3rd party:
∘ When the Company's affiliates, partners and service providers carry out services such as bill payment, execution of orders, products delivery and dispute resolution (including disputes on payment and delivery) for and on behalf of the Company
∘ when the user selects to be provided by the information of products and services of certain companies by sharing his or her personal information with those companies
∘ 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
∘ other cases where the user gives prior consent for sharing his or her personal information
• when the sharing is required by the laws
- if required to be disclosed by the laws and regulations; or
- if required to be disclosed by the investigative agencies for detecting crimes in accordance with the procedure and method as prescribed in the laws and regulations

4. Cookies
The Company may collect collective and impersonal information through 'cookies'.
Cookies are very small text files to be sent to the browser of the users by the server used for operation of the websites of the Company and will be stored in hard-disks of the users' computer.
These functions are used for evaluating, improving services and setting-up users' experiences so that much improved services can be provided by the Company to the users
The items of cookies to be collected by the Company and the purpose of such collection are as follows:
∘ 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
∘ 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
∘ Memorize set-ups applied such as languages and favorite fields
∘ Memorize when the customer respond to a survey conducted by the Company

6. Security
The Company regards 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

7. Protection of personal information of children
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.
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:
• 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

8. 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.

9. Data transmission
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 that personal information.
(If used in the US, additional security measures may be available) In addition, when the personal information obtained from the European Union is used or disclosed, the Company may have to comply with safe harbor principle as required by the Commerce Department of USA, 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.

10. 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.

11.Guide for users residing in California
If the user resides in California, certain rights may be given. The Company prepares 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, a 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.

12 Guide for users residing in Korea
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) Additional procedure for collection of sensitive information
If collection of sensitive information is indispensable, 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:
∘ 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 plan
∘ 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 system
∘ 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. : Chanyoung Ahn
Contact : [email protected]

The date of latest update: July 5, 2016.