Privacy Policy

initialT Co., Ltd. (the “Company”) is committed to respecting your privacy and the confidentiality of your personal data and complying with the “Act on Promotion of Information and Communications Network and Protection of Information, etc.” This Privacy Policy is designed to assist you in understanding how we use and safeguard the information you provide. In case we update or make changes in this Privacy Policy, you will be informed of it through Website notice (or individual notice).

■ Personal Information we collect

1. 1. The Company collects your personal information for the purpose of user registration, Apply for ASP service, Use for service, etc. as follows.
2. User registration
   - Name, Phone number, E-mail, ID
3. Apply for service
   - Name(Company Name), Phone number, E-mail, Resident registration number, Business Registration Number, ID
4. Use for service
   - Camera, Microphone, Account, ID, Phone number
5. In addition, following information can be generated and collected in the process of using the service or handling the business.
   - IP Address, cookie, MAC address, Service log, Date and time of visits, Service abuse record, etc.

■ The purpose of gathering your personal information

The Company uses your personal information for the following purposes.

1. Fulfillment of the Contract for the provision of the Service and Settlement of the Charges entailing the use of the Service.
   Providing contents, purchasing and making payments, shipping or mailing bills, authenticating for financial transactions and financial services.
2. Customer management
   User identification and authentication, prevention of illegal or unauthorized use by rogue users, confirmation of intention to join the Service, handling of complaints, etc. entailing the use of membership based service
3. Marketing and advertising
   Development and customization of new services (products), delivering advertising information such as promotional event, etc., provision of specialized Services and advertisement based on demographic characteristics, tracking the access frequency and statistics on the use of the Service.

■ How long will your personal information keep by the Company?

The Company will retain your information for as long as you continue to use the Service so we can provide the Service to you. If you make a request to terminate the relationship with the Company or have your information removed, it will be made untraceable and unusable. The Company may, however, retain your username (ID), name, resident registration number, email address for the periods specified hereunder from the date of your termination request for the purpose of preventing rogue users from abusing the Service.

1. Records of contract or subscription withdrawal
   - Legal ground : Act on Consumer Protection in Electronic Commerce, etc
   - Retention period : 5 years
2. Records of payments and supply of goods
   - Legal ground : Act on Consumer Protection in Electronic Commerce, etc
   - Retention period : 5 years
3. Records of treatments of consumer complaints or disputes
   - Legal ground : Act on Consumer Protection in Electronic Commerce, etc.
   - Retention period : 3 years
4. Records on identification
   - Legal ground : Act on Promotion of Information and Communications Network Utilization and Information Protection, etc.
   - Retention period : 6 months
5. Site visit log
   - Legal ground: Protection of Communications Secrets Act
   - Retention period : 3 months

■ How to dispose of your information

As a principle, the Company disposes your private information without delay once the purposes of collecting and using the information are achieved.
The procedure and method of disposal are as follows.

1. Disposal procedure
   - Information you provided for user registration, etc. is disposed after certain retention period in accordance with the Company’s policy and relevant laws once its purpose has been fulfilled.
   - Your private information that is retained will not be used for any purpose other than legal requirements.
2. Disposal methods
   - Your private information printed on paper will be disposed by means of shredding or incineration.
   - Electronically stored information will be deleted by technical means.

■ How to disapprove automatically gathering your private data

The Company uses ‘cookies’ to frequently store and find the user’s personal information. “Cookies” are very small text files sent from a server and stored on your hard disc. The Company uses cookies for the following purposes.

1. When we use cookies, etc.
   To provide customized service and targeted marketing information by analyzing your visit frequencies and time of use, etc., tracking your field of interests and preferences, your participation in events, etc.
   You are given with an option whether to allow cookies to be installed, ask you every time it is stored, or disapprove the use of cookies.
2. How to disapprove cookie
   You can either allow the use of cookies, ask you every time it is stored, or disapprove the use of cookie all together by selecting appropriate options on your browser.
   - Example of set up (on Internet Explorer): From the menu bar, select Tools > Internet Options > Privacy
   If you choose not to use cookies, it may cause some difficulties in providing the Service.

■ Person who responsible for privacy

The company assigns a Privacy Manager whose primary task is to protect your privacy and handle any complaints about private data as follows;

• ▶Privacy manager
  - Name : Kyoo-dong Lee
  - Position : CEO
  - Telephone : +82-2-541-2003
  - email : app.initialt@gmail.com

You can report any complaints regarding the protection of your privacy which may arise while using the service to the Privacy Manager or a relevant team. The Company shall answer to your complaints and requests as quickly, and as sufficiently as possible.

If you need to report or seek advice on the infringement of private date, you can also contact the following institutions and organizations.

• ▶ Privacy Invasion Reporting Center
  - Telephone : (without area code) 118
  - Homepage : privacy.kisa.or.kr
• ▶ Cybercrime Investigation Department, Supreme Prosecutors’ Office
  - Telephone : 02-3480-3571
  - Homepage : www.spo.go.kr
• ▶ Cyber Terror Response Center, National Police Agency
  - Telephone : 1566-0112
  - Homepage : www.netan.go.kr

■ Appendix

Announcement and effective date are described as follows.
- Announcement date : Mar 13th 2017
- Effective date : Mar 20th 2017