The following Privacy Policy has been established by JIPYONG LLC (the “Firm”) to protect personal information belonging to individuals or entities (the “Subjects”) and to address their privacy concerns effectively and expeditiously in accordance with the Personal Information Protection Act.

Article 1 (Purpose of Collecting Personal Information)

The Firm collects and uses personal information for the following purposes only. In case of any changes to the purposes, the Firm will take such measures as necessary under Article 18 of the Personal Information Protection Act, including seeking additional consent from the Subjects.

• A. Personal Information of Clients: to engage in communications necessary to perform services for which the Firm has been retained or services related to the Client; to distribute newsletters and other publications issued by the Firm; and to advertise events sponsored by the Firm or provide other information
• B. Personal Information of Officers and Employees of the Firm: for human resources management purposes such as executing and maintaining employment contracts, paying wages, and managing the employment insurance and national pension programs
• C. Personal Information of Applicants to Professional and Administrative Positions and Internships: for hiring purposes such as identification, verification of educational and professional background, management of application history, notice of hiring decisions, and communications regarding future hiring opportunities.

Article 2 (Retention of Personal Information)

• (1) The Firm uses and retains personal information only for a period permitted by law or for the period consented to by the Subjects at the time personal information was collected (the “Retention Period”).
• (2) The Retention Period for each type of personal information is as follows:
  • A. Personal Information of Clients: until completion of services or the client’s withdrawal of consent
  • B. Personal Information of Officers and Employees: until 3 years after retirement/resignation or the Subject’s request for disposal
  • C. Personal Information of Applicants to Professional and Administrative Positions and Internships: until 3 years after application or the Subject’s request for disposal

Article 3 (Provision of Personal Information to Third Parties)

The Firm will use personal information of the Subjects strictly within the scope set forth in Article 1 (Purpose of Collecting Personal Information), and provide personal information to a third party only in accordance with Article 17 of the Personal Information Protection Act, such as where the Subject has given consent or it is specifically permitted by a statute. The Firm currently does not provide personal information to any third party.

Article 4 (Consignment of Personal Information Management)

• (1) For effective management of personal information, the Firm has consigned certain necessary tasks to an independent contractor. The Firm regulates, manages and supervises the independent contractor to safely process the personal information in accordance with the Personal Information Protection Act and the Act on Promotion of Information and Communication Network Utilization and Information Protection.
  • - Independent Contractor: SummercePlatform
  •   Consigned Task: Kakao Notification Messaging
  • - Independent Contractor: Hanbom Studio
  •   Consigned Task: Development and maintenance of Sotong Hotline reporting feature on the Firm’s website
  • - Independent Contractor : Doodlin Corp.
  •   Consigned Task: Job application feature via Greeting ATS, a recruitment management solution
• (2) If there are any changes to the independent contractor or the consigned task, the Firm will promptly announce such changes through the Firm’s Privacy Policy.

Article 5 (Rights and Obligations of the Subjects and the Method of Exercising the Same)

• (1) A Subject may exercise his/her rights related to protection of personal information including requesting the Firm, at any time, to make his/her personal information available for inspection, to correct any errors, to delete, or to suspend use.
• (2) A Subject may exercise the rights under Paragraph (1) by written notice, telephone, email or facsimile to the Firm. The Firm will take necessary measures without delay.
• (3) If a Subjects requests to correct or delete errors in the personal information, the Firm will not use or provide such personal information until correction or deletion has been completed.
• (4) A Subject may exercise the rights under Paragraph (1) through agents such as legal counsel or authorized representatives. In such case, the Subject must submit a power of attorney in line with Form No. 11 of the Enforcement Rules to the Personal Information Protection Act.
• (5) A Subject may not infringe upon personal information or privacy of his/her own or of other others in violation of the Personal Information Protection Act.

Article 6 (Types of Personal Information)

The Firm collects and uses the following types of personal information:

• A. Personal Information of Clients:
  Required: name, address, contact information, email, company name, position and title
• B. Personal Information of Officers and Employees:
  Required: name, resident registration number, address, contact information, gender, email
  Optional: fingerprint, licenses and qualifications, language skills, awards, etc.
• C. Personal Information of Applicants to Professional and Administrative Positions and Internships:
  Required: name, date of birth, address, contact information, gender, email, resume, cover letter, and transcript and other personal information stated in such documents
  Optional: licenses and qualification, language skills, awards, etc.

Article 7 (Disposal of Personal Information)

• (1) The Firm will discard without delay any personal information which is no longer necessary, such as when the Retention Period has expired or the purpose of such personal information has been achieved.
• (2) If the Firm is required to retain personal information pursuant to other laws even though the Retention Period has expired or its purpose has been achieved, the Firm will transfer the personal information to a different database or preserve such at a separate storage facility.
• (3) The Firm will identify personal information subject to disposal and dispose of them upon approval of the Personal Information Privacy Manager. Personal information recorded and stored in electronic format will be permanently disposed of through low level formatting, and personal information recorded and stored in paper will be shredded or incinerated.

Article 8 (Security Measures for Personal Information)

The Firm employs the following security measures to protect personal information:

• A. Administrative measures: establishment and implementation of internal management plans, staff training on a regular basis, etc.;
• B. Technological measures: limiting access to personal information management system, installation of access control system, encryption of personally identifiable information, installation of security programs, etc.; and
• C. Physical measures: controlled access to IT and record storage facilities, etc.

Article 9 (Personal Information Privacy Manager)

• (1) The Firm has designated the following individuals to take charge of all tasks relating to the management of personal information, respond to Subjects’ complaint, and provide relief:
  • ▶ Personal Information Privacy Manager
    Name: So Young LEE
    Position: Attorney
    Tel: +82-2-6200-1721
  • ▶ Personal Information Privacy Team
    Name: Information Technology Team
    Manager: General Manager Jin-Goo KIM
    Tel: +82-2-6200-0715
• (2) A Subject may contact the Personal Information Privacy Manager or the Privacy Team for any inquiry regarding protection of personal information, complaints, request for relief, etc. arising during the course of the Firm’s services (or business). The Firm will respond to and address any such inquiry without delay.

Article 10 (Relief for Infringement of Rights and Interests)

A Subject may seek relief, advice, etc. regarding any infringement of personal information from the following institutions.
The following institutions are independent of the Firm. Please contact them if you are not satisfied with the Firm’s response to or relief for complaints relating to personal information, or if you require assistance.

• ▶ Center for Personal Information Infringement Reporting (operated by the Korea Internet & Security Agency)
  • - Function: report of personal information infringement, consultation
  • - Website: www.privacy.kisa.or.kr
  • - Tel: 118 (No Area Code)
• ▶ Personal Information Dispute Mediation Committee (operated by the Korea Internet & Security Agency)
  • - Function: Mediation of dispute concerning personal information, mediation of group dispute (civil resolution)
  • - Website: www.kopico.go.kr
  • Tel: 1833-6972 (No Area Code)
• ▶ Cybercrime Investigation Division of the Supreme Prosecutors’ Office: 02-3480-3573 (www.spo.go.kr)
• ▶ Korean National Police Agency’s Cyber Bureau: 182 (No Area Code) (cyberbureau.police.go.kr)

Article 11 (Amendment to Privacy Policy)

The Firm’s Privacy Policy may be amended in accordance with relevant laws, guidelines and internal regulations of the Firm. Any amendment to the Privacy Policy will be published in a manner required by applicable laws.