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CLUSH Inc. Personal information processing policy

CLUSH Inc. processes and safely manages personal information legally in compliance with the 「Personal Information Protection Act」 and related laws to protect the freedom and rights of information subjects.
Accordingly, in accordance with Article 30 of the 「Personal Information Protection Act」, in order to guide information subjects on the procedures and standards for handling personal information, and to deal with complaints related to this promptly and smoothly
We establish and disclose the following personal information processing policy.



CONTENTS

  • Purpose of personal information processing, collection items, retention and use period
  • Request for personal information processing business
  • Personal information destruction procedure and method
  • Measures to ensure the safety of personal information
  • Processing of pseudonymous information
  • Remedy for Infringement of Rights and Interests
  • Changes in Privacy Policy
  • Provision of personal information to third parties
  • Overseas transfer of personal information
  • Rights and obligations of information subject and legal representative and exercise method
  • Matters concerning the installation, operation, and rejection of automatic personal information collection devices
  • Person in charge of personal information protection and request for access to personal information
  • Installation and operation of image information processing equipment




Article 1 (Purpose of personal information processing, collection items, retention and use period)



  1. CLUSH Inc. handles the personal information of information subjects as follows.

Service purpose of collection Collection items Retention and use period
Contact Us Provide the optimal service of the project to the information subject as a marketing material and confirmation of the user who wants to request the project [essential]
Company Name
Name
Email Address

[Select]
Other items
- In principle, when the purpose of collection and use of personal information is achieved, it is destroyed without delay.

- However, company name, name of inquirer, e-mail address, phone number, and other optional items are retained for 1 year to provide smooth service to the customer due to information retention according to the company's internal policy.

- If it is necessary to preserve it in accordance with the provisions of related laws, such as the Commercial Act and the Consumer Protection Act in Electronic Commerce, etc., it is preserved for a certain period of time.

 *Records on consumer complaints or dispute handling: 3 years (Act on Consumer Protection in Electronic Commerce, etc.)

 *Website visit history: 3 months (Communications Secrets Protection Act)


Article 2 (Provision of personal information to third parties)



  1. CLUSH Inc. processes the personal information of the information subject only within the scope specified in the purpose of processing personal information, and only when it falls under Articles 17 and 18 of the 「Personal Information Protection Act」 such as consent of the information subject and special provisions of the law Information is provided to a third party, and other than that, the personal information of the information subject is not provided to a third party.

Article 3 (Consignment of personal information processing)



  1. CLUSH Inc. does not entrust the processing of personal information.

Article 4 (Overseas Transfer of Personal Information)



  1. CLUSH Inc. does not consign personal information to overseas corporations.

Article 5 (Personal information destruction procedure and method)



  1. ① CLUSH Inc. destroys the personal information without delay when the personal information becomes unnecessary, such as the expiration of the personal information retention period and the achievement of the purpose of processing. ② If personal information must be kept in accordance with other laws and regulations even though the personal information retention period agreed to by the information subject has elapsed or the purpose of processing has been achieved, the personal information is moved to a separate database (DB) or stored in a storage location. otherwise preserved. ③ The procedure and method of destroying personal information are as follows.
  2. 1. Destruction procedure CLUSH Inc. selects the personal information for which the reason for destruction occurred and destroys the personal information with the approval of the person in charge of personal information protection of CLUSH Inc. 2. Destruction method CLUSH Inc. destroys personal information recorded and stored in electronic file form so that the record cannot be reproduced, and destroys personal information recorded and stored in paper documents by shredding or incinerating.

Article 6 (Rights and obligations of data subject and legal representative and exercise method)



  1. ① The information subject may exercise the right to view, correct, delete, or request suspension of processing of personal information at any time with respect to CLUSH Inc. ② The exercise of rights can be done in writing, e-mail, or fax (FAX) in accordance with Article 41, Paragraph 1 of the Enforcement Decree of the 「Personal Information Protection Act」 for CLUSH INC., and CLUSH Inc. will take action without delay. I'll do it. ③ Rights can be exercised through an agent, such as a legal representative of the information subject or a person who has been delegated. In this case, you must submit a power of attorney in accordance with the "Public Notice on Personal Information Processing Methods (No. 2020-7)" Attachment No. 11 form. ④ The rights of the information subject may be limited in accordance with Article 35 Paragraph 4 and Article 37 Paragraph 2 of the 「Personal Information Protection Act」 when requesting access to and suspension of processing of personal information. ⑤ Requests for correction and deletion of personal information cannot be requested if the personal information is specified as the subject of collection in other laws and regulations. ⑥ CLUSH INC. checks whether the person who made the request, such as a request for reading, a request for correction or deletion, or a request for suspension of processing according to the rights of the information subject, is the person or a legitimate agent.

Article 7 (Measures to Ensure Safety of Personal Information)



  1. CLUSH Inc. takes the following measures to ensure the safety of personal information. 1. Administrative measures: Establishment and execution of internal management plans, operation of a dedicated organization, regular employee training 2. Technical measures: Management of access rights such as personal information processing system, installation of access control system, encryption of personal information, installation and renewal of security program 3. Physical measures: Access control for computer rooms, data storage rooms, etc.
    CLUSH Inc. is carrying out the following activities in addition to the matters stipulated by the law to ensure the safety of personal information. 1. Obtained domestic and international personal information protection certification: ISO27001, ISO27017, ISO27018

Article 8 (Matters Regarding the Installation, Operation and Rejection of Automatic Personal Information Collection Devices)



  1. 1. CLUSH Inc. uses 'cookies' that store and retrieve usage information from time to time in order to provide individual customized services to information subjects. 2. Cookies are a small amount of information that the server (http) used to run the website sends to the user's computer browser, and is sometimes stored on the hard disk of the user's PC computer.  1) Purpose of use of cookies: It is used to provide optimized information to users by identifying the types of visits and use of each service and website visited by the user, popular search keywords, secure access, etc.  2) Installation/Operation and Rejection of Cookies: You can refuse to save cookies by setting options in the Tools>Internet Options>Personal Information menu at the top of the web browser.  3) If you refuse to save cookies, you may experience difficulties in using customized services.


Article 9 (Processing of pseudonymous information)



  1. CLUSH Inc. does not pseudonymize personal information.


Article 10 (Person in charge of personal information protection and personal information access request)



  1. ① CLUSH Inc. is responsible for the overall handling of personal information, and has designated the person in charge of personal information protection as follows for the handling of complaints and damage relief of information subjects related to personal information processing. ② The information subject may request the viewing of personal information in accordance with Article 35 of the 「Personal Information Protection Act」 to the following departments. CLUSH Inc. will make efforts to promptly process the personal information access request of the information subject. ③ The information subject can inquire about personal information protection related inquiries, complaint handling, damage relief, etc. that occurred while using the service (or business) of CLUSH Inc. to the person in charge of personal information protection and the department in charge. CLUSH Inc. will respond to and process inquiries from information subjects without delay.

Category Name, etc Contact
Personal Information Protection Officer Position: Senior Executive Vice President
Name: Jo SooHyun
Phone Number: 02-2039-2150

Email: shcho@clush.net

FAX: 02-2039-0101
Department in charge of personal information protection Department Name: Marketing Team
Manager Name: Shin Seokmin
Phone Number: 02-2039-1311

Email: smshin@clush.net

FAX: 02-2039-0101
Request for access to personal information Department Name: Marketing Team
Manager Name: Shin Seokmin
Phone Number: 02-2039-1311

Email: smshin@clush.net

FAX: 02-2039-0101


Article 11 (Remedy for Infringement of Rights and Interests)



  1. ① CLUSH Inc. guarantees the information subject's right to self-determination of personal information, and strives to provide consultation and damage relief due to personal information infringement. If you need to report or consult, please contact the department in charge below. ▶ Grievance Handling Department Department Name: Marketing Team Manager: Shin Seokmin Contact: 02-2039-1311 Phone number: 02-2039-0100 | Email: smshin@clush.net | Fax number: 02-2039-0101
    ② The information subject may apply for dispute resolution or consultation to the Personal Information Dispute Mediation Committee, Korea Internet & Security Agency Personal Information Infringement Reporting Center, etc. in order to receive relief from personal information infringement. In addition, please contact the following organizations for reporting or consulting of other personal information infringement. 1. Personal Information Dispute Mediation Committee: (without area code) 1833-6972 (www.kopico. go.kr) 2. Personal information infringement reporting center: (without area code) 118 (privacy.kisa.or. en) 3. Supreme Prosecutors' Office: (without area code) 1301 (www.spo.go.kr) 4. National Police Agency (without area code) 182 (ecrm.cyber.go.kr)
    ③ The head of a public institution responds to the request pursuant to the provisions of Article 35 (Access to Personal Information), Article 36 (Correction/Deletion of Personal Information), and Article 37 (Suspension of Processing of Personal Information, etc.) of the 「Personal Information Protection Act」 A person whose rights or interests have been infringed upon due to a disposition or omission may request an administrative appeal in accordance with the Administrative Appeals Act. ▶ Central Administrative Appeals Commission: (without area code) 110 (www.simpan.go.kr)

Article 12 (Installation and operation of visual information processing equipment)



  1. CLUSH Inc. does not install or operate image information processing devices.

Article 13 (Change of Privacy Policy)



  1. ① This personal information processing policy is applied from 2023.02.15. ② You can check the previous privacy policy below. - Apply from 2015. 1. 14 to 2022. 2. 14 (click)

Personal information processing policy

CLUSH Inc. hereinafter values your personal information and complies with the Act on Promotion of Information and Communication Network Use and Information Protection.
The company will inform you of the use and method of personal information provided by you through the personal information processing policy and what measures are being taken to protect your personal information.
When the company revises its personal information processing policy, it will announce it through a website notice or individual notice.

Privacy items that you collect

  1. - Name of the company and the name of the person inquiring: Used in the identification process according to the use of the service, such as the request for counseling. - E-mail address: Securing a smooth communication path for processing counseling applications, etc. - Other items: Securing basic data for web consulting

Purpose of collection and use of personal information

  1. - We collect and use your personal information for the purpose of providing the optimal service of the project you want as identification and marketing data for users who want to request for the project.

Period of retention and use of personal information

  1. - In principle, users' personal information shall be destroyed without delay when the purpose of collecting and using personal information is achieved. - However, the company name, customer name, e-mail address, phone number, and other optional items may be retained for one year to provide the customer's desired service due to the company's internal policy. - If it is necessary to preserve it according to the relevant statutes, such as the Commercial Act, the Consumer Protection Act in e-commerce, etc., it shall be preserved for a certain period of time. * Records on the handling of consumer complaints or disputes: 3 years* Act on Consumer Protection in e-commerce, etc. (Records on self-confirmation (months), records on visits (3 months)

Period of retention and use of personal information

  1. - Destruction procedure : The information you entered for the quotation inquiry will be transferred to a separate DB after the purpose has been achieved. In case of paper, it will be stored for a certain period of reference according to the internal policy of the document box and other related laws. * Personal information transferred to a separate DB will not be transferred for any other purpose other than being retained unless it is legal. - Destruction method : Personal information stored in electronic file type shall be deleted using a technical method that cannot play records.

Provide personal information

  1. In principle, the company does not provide users' personal information outside. However, exceptions are made in the following cases. Where the users have agreed in advance/according to the provisions of the Act or if there is a request from the investigative agency in accordance with the procedures and methods prescribed by the Act for the purpose of investigation.

Consignment of personal information collected

  1. The company does not entrust your information to an external company without your consent. If such a need arises in the future, we will notify you of the consignee and the details of the entrusted work and get prior consent if necessary.