Privacy Policy
This
Policy (the "Policy") explains the way of treatment of the
information which is provided or collected
in the web sites 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.
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 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.
This
Policy will be effective on the 31th day of December, 2021 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.
|
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 ◦
Payment information including account number
and card number ◦ Delivery information including delivery address,
name and contact
information of recipient ◦
Information of bid, purchase and sales |
|
Social 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 or used by members, the persons interacting
or sharing contents with members, frequencies and period
of activities of members |
•
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.
|
Lists |
Items to be collected(examples) |
|
Equipment information |
◦ Equipment identifier, operation system, hardware version,
equipment set-up, type and set-up of browser, use information of website or application and telephone number |
|
Log information |
◦ IP address, 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 (limited to the region
permissible under the laws) |
|
Other information |
◦ Preference, advertisement environment, visited pages regarding service use of users |
(2) Method of collection
The Company collects
the information of users
in a way of the
followings:
• webpage, written form, fax, telephone calling, e-mailing, tools for collection of created information
•
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
• 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 you already know and, with your permission, 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 a consent from the users, if the Company
desires to use the information other than those
expressly stated in this Policy.
[Option to select ‘Lawful Processing of Personal Information under GDPR’ in Appendix <1> of Personal Privacy
Policy]
3. Disclosure of collected information
Except for the following cases, the Company will not disclose personal
information with a 3rd party:
•
when the Company
disclosing 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
to disclose 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 disclosure 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 an 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:
|
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 Company |
|
functionality 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 Company |
|
targeting 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.
5. User’s right
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]
6. Security
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
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:• 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
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
[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]
10. Contact information of Company
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 : Sirius Investment
Address : 46, Bangbae-ro, Seocho-gu, Seoul, Korea
Tel.: +82 2-522-9335
E-mail: sirius@siriusinv.com
(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: 18th March, 2018.
Appendix of Privacy Protection Policy
<1> 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:
•
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
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
rightss, 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
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
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
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 sales |
|
Social 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 or used by members,
frequencies and period
of activities of members |
|
In
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) |
|
|
|
(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 |
|
|
|
|
|
(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:
(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:
|
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 plan |
|
Managerial 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 system |
|
Physical 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: DongHyun Kim
Dept. : Head of Investment Operations
Tel. : +82 2-522-9335
Contact : sirius@siriusinv.com
The latest update date:18th march, 2022.