Privacy Policy

[Company Name, e.g., XX Co., Ltd.] (hereinafter referred to as the "Company") recognizes the importance of protecting personal information, complies with the Act on the Protection of Personal Information (hereinafter referred to as the "APPI"), and strives for the appropriate handling and protection of personal information in accordance with the following privacy policy (hereinafter referred to as "this Policy"). Unless otherwise defined herein, the terms used in this Policy shall be as defined in the APPI.

1. Definition of Personal Information

In this Policy, "Personal Information" refers to personal information as defined in Article 2, Paragraph 1 of the APPI.

2. Purposes of Use

The Company uses personal information for the following purposes:

• To provide the Company’s services, products, etc. (hereinafter referred to as "Company Services");
• To provide information and respond to inquiries regarding Company Services;
• To promote and provide guidance regarding Company Services;
• To address acts that violate the Company’s terms, policies, etc. (hereinafter referred to as "Terms and Conditions") regarding Company Services;
• To notify users of changes to the Terms and Conditions regarding Company Services;
• To improve Company Services and assist in the development of new services and products;
• To track and analyze browsing history, behavioral history, and purchase history to improve services, add functions, and conduct development/advertising for new products and services tailored to interests and preferences;
• For employment management and internal procedures (regarding personal information of officers and employees);
• For shareholder management and procedures under the Companies Act and other laws (regarding personal information of shareholders, stock acquisition right holders, etc.);
• To create statistical data processed into a format that cannot identify individuals in connection with Company Services;
• To provide information (including advertisements) from the Company;
• For purposes incidental to the above utilization purposes.

3. Change of Purposes of Use

The Company may change the purposes of use of personal information within a range reasonably considered relevant, and in the event of a change, the Company will notify the individual who is the subject of the personal information (hereinafter referred to as the "Individual") or make a public announcement.

4. Restriction on Use

The Company will not handle personal information beyond the scope necessary to achieve the purpose of use without obtaining the prior consent of the Individual, except as permitted by the APPI and other laws and regulations. However, this shall not apply in the following cases:

1. Cases based on laws and regulations;
2. Cases in which there is a need to protect a human life, body, or fortune, and when it is difficult to obtain the consent of the Individual;
3. Cases in which there is a special need to enhance public hygiene or promote the sound growth of children, and when it is difficult to obtain the consent of the Individual;
4. Cases in which there is a need to cooperate with a state organ, a local government, or an individual or entity entrusted by them in performing the affairs prescribed by laws and regulations, and when obtaining the consent of the Individual is likely to impede the performance of those affairs;
5. Cases in which personal data is provided to an academic research institution, etc., and said institution needs to handle the personal data for academic research purposes.

5. Proper Acquisition of Personal Information

5.1 The Company will acquire personal information properly and will not acquire it by deceit or other wrongful means.

5.2 The Company will not acquire "Special Care-Required Personal Information" (as defined in Article 2, Paragraph 3 of the APPI) without the prior consent of the Individual, except in cases permitted by law or specifically outlined in Section 4.

6. Security Control Measures

The Company will exercise necessary and appropriate supervision over its employees to ensure the security control of personal information against risks such as loss, destruction, falsification, and leakage. When entrusting the handling of personal information to a third party, the Company will also exercise necessary and appropriate supervision over the trustee. Our security measures include:

• Compliance & Inquiries: Compliance with APPI and guidelines; establishing a contact point for inquiries and complaints.
• Procedural Rules: Establishing handling methods for each stage (acquisition, use, storage, etc.).
• Organizational Measures: Appointing a person responsible for handling personal data and establishing a reporting system for violations.
• Personnel Measures: Regular training for employees and confidentiality clauses in employment rules.
• Physical Measures: Restricted access to data, locking cabinets, and securing equipment with security wires.
• Technical Measures: Access control and protection against unauthorized access/malware.

7. Provision to Third Parties

7.1 The Company will not provide personal information to third parties without the prior consent of the Individual, except as provided in Section 4 or in cases of entrustment, business succession (mergers), or joint use.

7.2 For provision to third parties in foreign countries, the Company will comply with Article 28 of the APPI and obtain the necessary consent or ensure appropriate systems are in place.

7.3 & 7.4 The Company maintains records of providing/receiving personal information to/from third parties as required by Articles 29 and 30 of the APPI.

7.5 Notwithstanding Section 7.1, the Company may provide user information to partner companies based on the Terms of Use or special agreements.

8. Personally Referable Information

When acquiring "Personally Referable Information" (as defined by the APPI) from a third party and using it as personal data, the Company will obtain prior consent from the Individual and use it within the scope defined in Section 2.

9–11. Disclosure, Correction, and Suspension of Use

Individuals may request the disclosure, correction, addition, deletion, or suspension of use (opt-out) of their personal information held by the Company. Upon verifying the requester's identity, the Company will respond without delay in accordance with the APPI, unless the Company is not obligated to do so under the law.

12. Handling of Anonymously Processed Information

When creating or providing "Anonymously Processed Information" (as defined in the APPI), the Company will comply with the standards set by the Personal Information Protection Commission, implement security measures, and disclose the categories of information included.

13. Use of Cookies and Other Technologies

Our services may use cookies and similar technologies to understand usage status and improve services. Users can disable cookies through their browser settings, though this may limit some functionalities of the service.

14. Use of External Services

1) Google Analytics: We use Google Analytics to analyze site traffic. This includes remarketing, impression reporting, and demographic/interest reporting.

2) Marketing Automation: We use "Wix Forms" by Wix.com Ltd. for marketing. Cookies track access data (dates, URLs) and may be linked to your email address to analyze interests and provide tailored information.

Opt-out: Users can disable cookies via browser settings or through specific opt-out links:

• Google Privacy Policy
• Google Analytics Opt-out Add-on

15. Business Operator Information

[Company Name] Address: [Full Address]

Representative: [Name of Representative Director]

16. Contact Information

For requests regarding disclosure, opinions, questions, or complaints, please contact:

Personal Information Inquiry Desk Phone: [XX-XXXX-XXXX]

Email: [XXXX@XXXXXX]

(Hours: 10:00 AM – 6:00 PM, Weekdays)

17. Continuous Improvement

The Company will review and improve the handling of personal information as appropriate and may change this Policy as needed.

Established on [Month] [Day], 20[XX]