1. Basic Policy

The Company complies with the Act on the Protection of Personal Information (hereinafter referred to as the "APPI") and other relevant laws, regulations, and guidelines concerning the appropriate protection and use of personal information. The Company strives to protect and use personal information appropriately and to continuously improve its management structures and initiatives for personal information protection to respond appropriately to advances in information technology.

2. Definitions and Special Care-Required Personal Information

1. "Personal Information" means "Personal Information" as defined in the APPI, referring to information about a living individual that can identify a specific individual by name, date of birth, address, telephone number, contact details, or other descriptions contained in such information, or information that can be easily collated with other information and thereby identify a specific individual.
2. As a general rule, the Company will obtain Special Care-Required Personal Information as defined by laws and regulations (such as race, creed, social status, medical history, physical or mental disabilities, information regarding health, medical care, and welfare, or other similar matters) only after obtaining the prior consent of the individual concerned, and will handle such information appropriately within the scope of the purpose of use. Except as provided by laws and regulations, the Company will not obtain Special Care-Required Personal Information without the prior consent of the individual concerned.

3. Method of Obtaining Personal Information

The Company obtains personal information through fair and lawful means. In addition to information registered or entered into the Services by Users, the Company may obtain transaction records and payment information from its business partners (including information providers, advertisers, ad distribution partners, etc.; hereinafter referred to as "Business Partners").

4. Purposes of Use

The Company uses obtained personal information within the scope necessary to achieve the following purposes of use. The Company may continue to retain and use such personal information after the cancellation of the Services or the termination of contracts for post-termination management purposes.

Common Purposes of Use

1. Receipt of applications, provision, management, and continuous operation of the Services
2. Identity verification and verification of eligibility, conditions, etc., for using the Services
3. Responding to inquiries and consultations, supporting service use (including maintenance and operations), and sending important notices
4. Public relations and advertising for the Company's services (photos, testimonials, etc., will be posted only with the consent of the individual or their legal representative)
5. Notification of new features, updates, campaigns, etc., and guidance on other services provided by the Company or products of partner companies (including notices via email, direct mail, SNS, telephone, etc.)
6. Identification of Users who violate the Terms of Service and prevention of unauthorized or improper use
7. Research, development, improvement, and enhancement of products and services through market research, data analysis, surveys, etc.
8. Measurement of advertising effectiveness based on matching customer browsing history, location information, preferences, etc., obtained from third parties with information obtained at the start of Service use
9. Billing and payment processing for various fees and usage charges
10. Cancellation of transactions and post-termination management after transaction cancellation
11. Creation of anonymously processed information, statistical information, or other information processed into a format that cannot identify individuals in accordance with laws and regulations, and using such information for validation, quality improvement, research and development, effectiveness measurement, statistical analysis, and other incidental purposes related to the Services (including but not limited to developmental/educational effects), and providing such information to universities, other research institutions, or joint research partners as necessary
12. Purposes incidental to the above purposes of use

Specific Purposes of Use by Business Unit

In addition to the common purposes above, the Company uses personal information for the following purposes in each business unit:

5. Special Provisions on Registration and Joint Use of Customer Information

1. When registering personal information (including Special Care-Required Personal Information) obtained from their customers into the systems or platforms provided by the Company in connection with using the Services, Users shall register only information for which lawful consent has been obtained from the individual (or a person with legal authority, such as a parent/guardian) or other personal information that complies with laws and regulations.
2. The Company may jointly use personal information provided by Users and other personal information regarding the Services with the Company's Business Partners. However, such Business Partners shall handle such personal information appropriately in accordance with the handling of personal information by the Company under this Policy, and Users shall obtain the individual's consent regarding the provision of personal information to such Business Partners and take other necessary measures.

6. Security Control Measures and Supervision of Contractors

1. The Company implements organizational, human, physical, and technical security control measures to prevent the loss, alteration, leakage, or other security incidents involving personal information, and manages personal information appropriately.
2. When entrusting all or part of the handling of personal information to third parties, the Company exercises necessary and appropriate supervision over the contractors to ensure the security management of personal information.

7. Provision of Personal Information to Third Parties

The Company will not provide personal data to third parties without obtaining prior consent from the individual concerned (including cases where Users of the Services obtain consent on behalf of the Company), except in the following cases:

1. Cases based on laws and regulations (including laws and regulations of countries outside the residence of the individual)
2. Cases where the Company entrusts business operations to a third party (including non-life insurance companies) within the scope necessary to achieve the purposes of use
3. Cases where provision is necessary for the protection of human life, body, or property, and it is difficult to obtain the consent of the individual
4. Cases where provision is particularly necessary for improving public health or promoting the sound growth and support of children/users, and it is difficult to obtain the consent of the individual
5. Cases where cooperation is required for a national agency, local government, or an entity entrusted by them to execute affairs prescribed by laws and regulations, and obtaining the consent of the individual is likely to impede the execution of such affairs
6. Cases where all or part of the handling of personal information is entrusted within the scope necessary to achieve the purposes of use specified in Section 4
7. Cases where personal information is provided in connection with a merger, company split, business transfer, or other disposition of all or part of the Company's business, assets, or stock (including transfers made in connection with bankruptcy or similar procedures)
8. Cases where anonymously processed information or statistical information described in Item 11 of Section 4 is provided to universities, other research institutions, or joint research partners and used for joint research

8. Provision to Third Parties in Foreign Countries

1. The Company may use cloud services, AI services, or other services provided by operators located in foreign countries, or entrust the handling of personal information to such operators within the scope necessary to achieve the purposes of use. In such cases, the Company exercises necessary and appropriate supervision to ensure that personal information is handled appropriately by the operator concerned.
2. When providing personal information to an operator in a foreign country, the Company shall, upon request from the individual concerned, disclose information regarding the name of the recipient operator, the country in which it is located, the personal information protection system in that country, and the measures taken by the recipient for the protection of personal information.
3. When handling Special Care-Required Personal Information using foreign AI services or other tools, the Company configures appropriate settings to ensure that such information is not used for training the service model and is not provided beyond the necessary scope.

9. Procedures for Requests for Disclosure, etc.

The Company accepts requests for notification of the purpose of use, disclosure, correction/addition/deletion, suspension of use/erasure, or suspension of third-party provision of retained personal data under the APPI (hereinafter collectively referred to as "Requests for Disclosure, etc.") at the contact point below.

10. Changes to the Privacy Policy

1. The contents of this Policy may be changed without individual notification to Users, except as otherwise provided by laws and regulations or in this Policy.
2. The revised Privacy Policy shall take effect from the time it is posted on the Company's website or other designated locations.

11. Contact Information

For opinions, questions, complaints, or other inquiries regarding the Company's handling of personal information, please contact the following: