ALPHACIRCLE Inc. (‘www.alphacircle.co.kr, hereinafter, the “ALPHACIRCLE”) has established the personal information management policy as follows (the “Policy”) in accordance with the Personal Information Protection Act and Act on Promotion of Information and Communication Network Utilization and Information Protection to protect the rights and interests of the users of the ALPHACIRCLE’s services and to handle any problems that the users may face in respect of their personal information. Any amendment of this Policy will be publicly announced by a posting on the website of the ALPHACIRCLE at www.alphacircle.co.kr

This Policy will come into effect on 1^st of June, 2021 (the “Effective Date”)

1. 1. Purpose of Personal Information Management

The ‘ALPHACIRCLE’ processes user’s personal information for the following purposes. Processed information will not be used for any purposes other than for the following purposes. The ‘ALPHACIRCLE’ will seek prior consent of the persons who are the subject of the personal information (the “Users”) before any change to the intended use is implemented.

< Complaint Handling >

The ‘ALPHACIRCLE’ processes personal information for the following purposes:

• · To verify the complaining person’s identification;
• · To review complaints;
• · To contact or notify the complaining persons to investigate the cause of the complaints; and
• · To notify complaint review results.

• 2. Personal Information Processing and Retention Period

2. A. The ‘ALPHACIRCLE’ processes and retains personal information during the period permitted by law or agreed by the subject of the information upon collection of his/her personal information.
3. B. Personal information processing and retention periods are as follows:

< Handling Complaints >

The ‘ALPHACIRCLE’ processes and retains personal information for the purpose of “Complaint Handling” for 36 months from the date on which User gives consent to collect or use of his/her personal information for the said purpose. However, if the User withdraws his/her consent before the expiration of the 36 month period, the User’s personal information will be promptly destroyed. Also, if the official site must be closed due to the ALPHACIRCLE’s business shut down, then all User’s personal information will also be entirely destroyed.

However, if retention of any of the above information is required by law, the ALPHACIRCLE shall process and retain such information during the required period in accordance with the law.

3. 3. Rights of the Users and Method to Exercising such Rights

As the subject of the personal information, User may exercise the following rights:

1. A. User may at any time exercise the following rights against the ‘ALPHACIRCLE’ in order to protect his/her personal information:

1. B. The rights referred to in Paragraph A above may be exercised by completing Form of the Enforcement Regulation of the Personal Information Protection Act ( Acts 41 – 1 ) and submitting to the ‘ALPHACIRCLE’ as hard copy, or by email or facsimile. The ‘ALPHACIRCLE’ will immediately take action upon receipt of such request.

1. C. The rights referred to in Paragraph A above may be exercised by a legal agent or an authorized representative of the User. In such a case, power of attorney as provided in Form 11 of the Enforcement Regulation of the Personal Information Protection Act (2020-7) must be submitted to the ‘ALPHACIRCLE’

1. D. The right of the information subject may be restricted pursuant to Articles 35 (4) and 37 (2) of the Personal Information Protection Act.

1. E. A request for correction and deletion of personal information shall not be requested if the personal information is specified as a target for collection in other Acts and subordinate statutes.

1. F. ALPHCIRCLE Inc. verifies whether it is the person who made the request for perusal, correction or deletion, and suspension of processing, etc. based on the right of the information subject.

4. 4. Types of Personal Information Collected and Method of Collecting Personal Information

Types of Personal Information Collected

The ‘ALPHACIRCLE’ processes the following types of personal information, which are essential for the provision of its services.

< Complaint Handling >

– Required Items: email address, name, company name, smartphone device name

– Optional Items: any messages that users write in the content section, downloadable link to download the video file which is necessary step to provide ALPHACIRCLE’s service to requested users.

5. 5. Disposal of Personal Information
6. A. When any of the personal information becomes no longer necessary, including by expiration of the retention period or fulfilment of its purposes, the ALPHACIRCLE disposes of such personal information without delay.
8. B. If the personal information agreed by the information subject expires or the personal information is to be preserved under other Acts and subordinate statutes, the personal information shall be moved to a separate database (DB) or stored in a different place.

– According to Information and policies of the ‘Communication Network Act’

– Personal information items preserved: e-mail, name, company name, what the customer writes, video link, mobile phone model

The process, timing and method of disposal of personal information are as follows:

1. 1. Disposal Process

ALPHACIRCLE identifies personal information that needs to be destroyed, and after obtaining approval of the ALPHACIRCLE’s personal information manager, destroys such information.

In case the personal information should be preserved according to applicable laws, the ALPHACIRCLE will store such information in a separate database (in case of personal information in paper form, the ALPHACIRCLE will record such information in a separate document) and preserve it for the required period of time in accordance with applicable law and the ALPHACIRCLE’s internal policies, and will dispose of it after the required period elapses. In such a case, the personal information preserved will not be used except in strict adherence to the relevant law.

2. 2. Disposal Method

(1) Information in electronic form will be destroyed using technical tools so as to make sure that such information will not be reproduced. (2) Information in paper form will be destroyed by shredding it with a paper shredder or incinerated. (3) In any other cases which require to destroy the information, then ALPHACIRCLE will contact the website design agency (TJ WEB) to delete everything that are related to User’s personal information.

6. 6. Measures to Secure Safety of Personal Information

ALPHACIRCLE takes the following technical, administrative and physical measures necessary to protect personal information in accordance with the Personal Information Protection Act:

1. A. Minimize Number of Staff Processing Personal Information; Training

ALPHACIRCLE appoints a minimum number of staff for processing personal information and gives permission to handle personal information only to such staff.

1. B. Technological Measures to Prevent Hacking

ALPHACIRCLE installs security programs in order to prevent leakage or damage of personal information caused by computer hacking or virus, and renews and checks the system regularly. In addition, the information system is located where access from outside is controlled and monitored through technical and physical means.

1. C. Limited Access to Personal Information

ALPHACIRCLE takes measures to control access to personal information by controlling authorization to access personal information database systems, and prevents unauthorized access from outside using intrusion prevention system.

7. 7. Installation, operation, and rejection of personal information auto collection devices

ALPHACIRCLE does not collect the ‘cookie’ to store or use the information

8. 8. Personal Information Protection Manager
9. A. ALPHACIRCLE appoints a personal information protection manager who is responsible for all affairs relating to personal information processing, and handling complaints raised by the Users and remedy of damages incurred in relation to personal information processing.

Personal Information Protection Manager

Name: HYEONWOO, KIM

Position: Representative of ALPHACIRCLE in Korea

Title: Associate Director

Contact Personal Information Management Division:

Tel: +82-10-8649-8956, kevin@alphacircle.co.kr, Fax: –

Personal Information Management Division

Name of Division: Business Development

Person in Charge: HYEONWOO, KIM

Contact Personal Information Management Division:

Tel: +82-10-8649-8956, kevin@alphacircle.co.kr, Fax: –

1. User may direct all personal information related questions or complaints to the Personal Information Manager and the Management Division. ALPHACIRCLE will promptly respond to such enquiries.

9. 9. Request to Review Personal Information
10. B. User may request the following division to allow review of his/her personal information in accordance with Article 35 of the Personal Information Protection Act. ALPHACIRCLE will do its best to handle such requests as promptly as possible.

Division in Charge

Name of Division: Business Development

Person in Charge: HYEONWOO, KIM

Tel: +82-10-8649-8956, kevin@alphacircle.co.kr, Fax: –

10. 10. Remedy for Infringement on Rights and Interests of Users
11. User may inquire at the following institutions regarding remedy of damages arising from infringement of personal information, if not fully satisfied with the service of the ALPHACIRCLE in handling complaints related to personal information.

Personal Information Protection Centre (operated by Korea Internet & Security Agency)

What they do: Take reports on infringement of personal information and provide counselling services in relation thereto

Website: privacy.kisa.or.kr

Phone: 118 (without area code)

Address: Personal Information Protection Centre, Korea Internet & Security Agency, 135 Joongdae-ro, Songpa-gu, Seoul 138-950, Korea

Personal Information Dispute Mediation Committee (operated by Korea Internet & Security Agency)

What they do: Receive applications for mediation of personal information-related disputes and to mediate such disputes (civil resolution)

Website: privacy.kisa.or.kr

Phone: 118 (without area code)

Address: Personal Information Protection Centre, Korea Internet & Security Agency, 135 Joongdae-ro, Songpa-gu, Seoul 138-950, Korea

Cybercrime Investigation Department of the Supreme Prosecutors’ Office:

02-3480-3582(www.spo.go.kr)

Korean National Police Agency Cyber Bureau:

182 (cyberbureau.police.go.kr)

A person who has been infringed on his/her rights or interests due to the disposition or act by the head of a public institution under Articles 35 (Reading Personal Information), 36 (Correction and Deletion of Personal Information), 37 (Suspension of Processing, etc.) of the Personal Information Act may request an administrative appeal.

※ For more information on administrative appeals, please refer to the website of the Central Administrative Appeals Commission (www.simpan.go.kr).

11. 11. Changes in the Personal Information Management Policy and Notification
12. This Policy will take effect from the 1^st of June, 2021.
13. You may view or download previous versions of this Policy below:

>> Will be added after May 31^st, 2024.