'㈜루브캡이엔에스' (hereinafter the “Company”) values the importance of customers’ personal information and complies with the Act on Promotion of Information and Communication Network Use and Protection of Information of the Republic of Korea.

Through this Privacy Policy (hereinafter the “Privacy Policy”), the Company informs its customers about the Company’s purpose and method of utilizing the personal information provided by its customers and about the measures the Company is implementing to protect personal information.

In the event of revisions to this Privacy Policy, the Company will give a public notice through the “notice” section of its website (or by issuing individual notices).

This Policy shall enter into effect from the 17th day of March, 2022.

1. Items of Personal Information to be Collected

The Company collects the following items of personal information for the purpose of consultation, etc.

Online inquiries
- Items to be collected: Name, Phone number, email address and the content of the inquiry

2. Purpose of the Collection and Use of Personal Information

The Company utilizes collected personal information for the following purposes:
Performance of contracts for service provision and responding to inquiries or repliesas part of the provision of services.

3. Period of the Retention and Use of Personal Information

In principle, the Company destroys thepersonal information of users immediately after the purpose of its collection and use has been achieved, without delay. However, if necessary to preserve the information under the provisions of applicable laws and regulations, the Company shall retain members’ information for a certain specified period as provided by the provisions of the applicable laws and regulations.

Item of Information to be Preserved and Grounds for the Preservation of Settlement Records

• - Retention period for the record of withdrawal of contract or subscription: 3 years
• - Retention period for the record of withdrawal of contract or subscription: 5 years (Act on Consumer Protection in E-commerce)
• - Record of payment and supply of goods: 5 years (Act on Consumer Protection in E-commerce)
• - Record of consumer complaints or dispute processing: 3 years (Act on Consumer Protection in E-commerce

4. Procedure and Method of Destroying Personal Information

In principle, the Company destroys thepersonal information of its users immediately after the purpose of its collection and use has been achieved, without delay. The procedure and method of destruction are as follows:

The procedure of Destruction
The information entered by the members in the process of registering to become a member will be moved to a separate database (or in the case of paper documents, to a separate file box) after the purpose of collecting this information has been achieved, stored for certain period in accordance with the Company’s internal policy and reasons for information protection as provided by other applicable laws and regulations (refer to the section regarding the period of retention and use), and thereafter destroyed.
The personal information moved to a separate database will not be used for other purposes than the purpose of retention, unless otherwise stated in the laws.

The Method of Destruction
Any personal information stored in an electronic file will be deleted using a technological method that renders it impossible for the information to be regenerated.

5. Provision of Personal Information

In principle, the Company does not provide external parties with the personal information of users, except for the following cases:
Cases where the users have given prior consent, in compliance withrelevant laws, or cases where the information is requested by investigation agencies in compliance with the procedure and method as provided in the laws and regulations for the purpose of investigation.

6. Management of the website and system (hosting/maintenance)

• - Consignee: 3ANYINC &WEBSITE
• - Description of consigned duties: Management of the website and system (hosting/maintenance)

7. Rights of Users and Their Legal Representative and Method of Exercising TheseRights

Users may request to view or amend their registered personal information at any time and also may request the cancellation of their subscription Users can click “change personal information” (or “correct member information”) to request to view or amend one’s personal information and can also click “membership withdrawal” to request cancellation (or withdrawal of their consent). After clicking, the users shall complete an identification process and thereafter have direct access to view or correct their information or complete their withdrawal. Alternatively, users can contact the person responsible for managing personal information via letter, telephone call or email, and the Company will take measures to respond to their request without delay. In cases where the user requests a correction to any mistake in the user’s personal information, the Company will not use or provide such information before the requested correction has been completed. In addition, if the Company has already provided a 3rd party with incorrect personal information, the Company will inform such 3rd party of the result of correction without delay to ensure that the correction can be made. The Company shall process any personal information which has been cancelled or deleted upon the request of users as stated in the section on the “Period of the Retention and Use of Personal Information Collected by the Company” and shall ensure that such information cannot be accessed or used for any other purpose. In the case of minors under the age of 14, his or her legal representative has a right to request to view or correct to the personal information of such a minor and the right to withdraw the collection and consent.

8. Matters Pertaining to the Installation and Operation of Devices for the Automatic Collection of Personal Information and the Refusal Thereof

The Company operates “cookies” which frequently store or find users’ information. Cookies are very small text files sent to the user’s browserby the server which is utilized for the operation of a website,and are stored in the hard disk of the user’s computer.

The Company uses cookies for the following purposes

Purposes of Use
Target marketing and provision of customized services by the analysis of access frequency or visit hours of members and non-members; identification of users’ preferences and areas of interest and detection of traces; and tracking the user’s level of participation and visit count.
The user has a right to opt out of cookie installation. Accordingly, by selecting appropriate the setting option in the user’s web browser, the user may allow all cookies or require confirmation whenever cookies are stored or reject the storage of all cookies.

Method of Selecting CookieSettings
Example (for Internet Explorer): Select “tool” at the top of web browser > Internet option >Personal information. Note that if the user chooses to reject the installation ofcookies, there may be a difficulty in providing services.

9. Civil Complaint ServicesRelated to Personal Information

In order to protect the personal information of customers and handle any complaints related to such information, the Company designates the following department and person responsible for personal information:

If a user needs to report or consult about an infringement of personal information, the user can make an inquiry to the following available agencies:

• - Report Center of Personal Data Infringement (privacy.kisa.or.kr / 118 without local code)
• - Cyber Crime Investigation Team of the Supreme Prosecutor’s Office (www.spo.go.kr / 1301 without local code)
• - Cyber Terror Response Center of the National Police Agency (police.go.kr/182 without local code)