This Policy (the "Policy") explains the way of treatment of the information which is provided or collected on the websites on which this Policy is posted. In addition, the Policy also explains the information provided or collected in the course of using the applications of the Company which exists on the websites or platforms of other companies.

The Company is the controller of the information provided or collected in the websites on which this Policy is posted and in the course of using the applications of the Company which exists in the websites or platforms of other companies.

Through this Policy, the Company regards the personal information of the users as important. It informs them of the purpose and method of the Company's using the personal information provided by the users and the measures taken by the Company to protect that personal information.

This Policy will be effective on the 10th day of December 2024. In case of modification thereof, the Company will make public notice of it by posting it on the bulletin board of the Company's website or individual notice through sending mails, fax, or e-mails).

1. Information to be collected and method of collection

1. Personal Information Items to be Collected

   1. Information provided by the users

      The Company may collect the information directly provided by the users.

      1. Internet membership service: Email, Password, Gender, Birth date, Name, Nationality, and third-party single sign-on information (if you opt for such a sign-on method)
      2. Online payment service: Payment information including account number and card number

   2. Information collected while the users use services

      Besides information directly provided by the users, the Company may collect information in the course that the users use the service provided by the Company.

      1. (Equipment information) Equipment identifier, operation system, hardware version, equipment set-up, type and set-up of the browser, use information of website or application, and telephone number
      2. (Log information) IP address, log data, use time, internet protocol address, cookie, and web beacon, language, reference webpages, pages visited, location, telecommunications service provider, search terms and search ID (including those whose access is not requested), advertisements posted to you by the Company, identifiers generated by the Company, and identifiers connected to cookies. Also, the Company receives log data when you click, access, or interact with a link on the Company’s services, including when you install another app through the service.
      3. (Usage Information) Chatting (transmitted within the Company is encrypted both in transit and at rest)
      4. (Other information) Preference, advertisement environment, visited pages regarding service use of users

2. Method of Collection

   The Company collects the information of users in the way of the followings:

   1. Webpage, written form, fax, telephone calling, e-mailing, tools for collection of created information
   2. provided by partner companies
      1. If you use online products or services from a third party, the concerned party may share data on your usage with the Company (including advertising partners, developers and publishers, and solution services). The Company’s advertising and business partners share the data on browser cookie ID, Webudding-generated identifiers, mobile device ID, hashed user information, and service usage information with the Company.

2. Use and Processing of Collected Information

1. Use and Purpose of Collected Information

   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.

   1. Member management and identification
   2. To detect and deter unauthorized or fraudulent use of or abuse of the Service
   3. Performance of the contract, service fee payment, and service fee settlement regarding provision of services demanded by the users
   4. Improvement of existing services and development of new services
   5. Making notice of the function of company sites or applications or matters on policy change
   6. To help you connect with other users you already know and, with your permission, allow other users to connect with you
   7. To make statistics on members’ service usage, to provide services, and to place advertisements based on statistical characteristics
   8. To provide information on promotional events as well as opportunity to participate
   9. To determine the situation in the event of a problem.
   10. To comply with applicable laws or legal obligations
   11. The Company shall consider the following in cases where users’ data are used or provided without consent.
       1. Whether the purpose of additionally using or providing personal data is relevant to the initial purpose of collection.
       2. Whether the additional provision of use is predictable in light of the reasons for collecting personal data or processing practices.
       3. Whether the data subject’s interest is disadvantageously infringed due to additional use or provision of personal data.
       4. If any measures needed to secure safety such as pseudonymization or encryption have been taken.

2. Lawful Processing of Personal Information under GDPR

   Processing personal information by the Company shall be lawful only if and to the extent that at least one of the following applies:

   1. A user has given consent to the processing of his or her personal information.
   2. Processing is necessary for the performance of a contract to which a user is a party or to take steps at the request of a user prior to entering into a contract:
      1. Member management, identification, etc.
      2. Performance of a contract in relation to providing the services required by users, payment and settlement of fees, etc.
   3. Processing is necessary for compliance with a legal obligation to which the Company is subject
      1. Compliance with relevant laws, regulations, legal proceedings, and requests by the government
   4. Processing is necessary to protect the vital interests of users or other natural persons
      1. Detection of, prevention of, and response to fraud, abuse, security risks, and technical issues that may harm users or other natural person
   5. Processing is necessary for the performance of a task carried out in the public interest or the excise of official authority vested in the Company
   6. Processing is necessary for 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).

3. Disclosure of Collected Information

Except for the following cases, the Company will not disclose personal information with a 3rd party:

1. when the Company discloses the information with its affiliates, partners, and service providers;
   1. 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
2. when the users consent to disclose in advance;
   1. 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
   2. 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
   3. other cases where the user gives prior consent for sharing his or her personal information
3. when disclosure is required by the laws:
   1. if required to be disclosed by the laws and regulations; or
   2. 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