Privacy Policy

This Privacy Policy (the “Policy”) explains the way of treatment of the information which is provided or collected in the website 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 website 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.

This Policy will be effective on the 27th day of November, 2019 and, in case of modification thereof, the Company will make public notice of it through posting it on the bulletin board of 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
Personal information items to be collected by the Company are as follows:
• Information provided by the users
The Company may collect the information directly provided by the users.
∘ Name, email address, ID
• Information collected while the users use services
Besides of information directly provided by the users, the Company may collect information in
the course that the users use the service provided by the Company.
∘ Log data, use time
(2) Method of collection
The Company collects the information of users in a way of the followings:
• provided by partner companies

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
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 shares the information with its affiliates, partners and service providers;
∘ 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 users consent the sharing in advance;
∘ 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, Beacons and Similar Technologies
The Company may collect collective and impersonal information through ‘cookies’ or ‘web
beacons’.
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.
Web beacon is a small quantity of code which exists on the websites and e-mails. By using web
beacons, we may know whether a user has interacted with certain webs or the contents of
email.
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:
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 of 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 Company
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.

5. Users’ right to access and option
The users or their legal representatives, as main agents of the information, may exercise the
following options 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 options, you, as an user, use the menu of ‘amendment of
member information of webpage or contact the Company by using representative telephone or
sending a document or e-mails, or using telephone to the responsible department (or person in
charge of management of personal information), 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.

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
• Encryption of personal information
– Transmit users’ personal information by using encrypted communication zone
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– 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

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.

(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:
• 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. Others
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. Responsible department of Company
The Company designates the following department and person in charge of personal
information in order to protect personal information of customers and deal with complaints
from customers:
• Department responsible for privacy protection and customer service :
Address : 37, Maebongsan-ro, Mapo-gu, Seoul, Republic of Korea
Tel.: 02-929-5095
E-mail: admin@smartdongs.com
The latest update date: 07, 05, 2021