Talkafe Personal Information Handling Policy

Article 1 (Purpose)

  • 1. Hancom Talkafe Co., Ltd. (hereinafterthe “Company”), in providing Talkafe services to Talkafe members, shall carefully handle the members’personal information and doits best to effectively manage and safely protectsuch personal information.
  • 2. The Company shall comply with personal information protection laws such as the Act on Promotion of Information & Communications Network Use and Protection of Information. In this Policy, the Company shall announcethe purpose and method of using personal informationprovided by Talkafe members and thepersonal information protection measures being taken.
  • 3. The Companyshall postthis Personal Information Handling Policyin the Talkafe service screen, so that Talkafe members can easily view the Policy at all times.

Article 2 (Itemsof collected personal information andmethod of collection)

  • 1. The Company shall placeimplement a procedure of consent to the Terms of Service and to the collection and use of personal information when a Talkafe membership applicant subscribes for membership The applicant, whenchoosing “consent” there, shall be deemed to consent to the aforesaid collection and use.
  • 2. The Company, to provideservices(e.g., consultation on membership subscription, processing of service application) andperform contracts, may collect the following personal information, but may not request personal information whose collection may violate basic human rights (e.g., race and ethnicity, ideology and creed, place of birth and permanent address, political inclination and criminal record, health condition,and sexuality).
    • - Mandatory items:Mobile phonenumber (if numberis changed, save the most up-to-date phone number in order to confirm the user), emailaddress, password, Talkafeserviceversion, dialogue name, network accesstype, OS, OS version, device model, deviceID, language used, area, country, Time Zone
    • - Optional items: Name andphone numberstored in the device’s address book, profilephoto (including meta-information), status message, purchased items,andproduct history
  • 3. The Company may collectservice usage records, access logs, cookies, IP access information, ID, payment records, etc. created in the process of using of the service.
  • 4. The Companyshall collectpersonal information with the followingmethods.
    • (1) Membership subscription, serviceinquiries, eventparticipation, delivery request, etc.
    • (2) Tools that collect information that has been created

Article 3 (Purposeof collecting andusing personal information)

  • 1. The Companyshall use collected personal information for the following purposes. The Company shall providepart of its servicethrough contracts with partner companies, service providers, orother third parties. To manage the website and deliver services, the Company and its partner companies may use Talkafe members’ personal information.
    • (1) Provideautomatic friendaddition and registration function

      ー Collect and usea Talkafe member’s phone number and third parties’ names and phone numbersstored in the address book of the member’s deviceand thereby provide automatic friend addition and registration functions.

    • (2) Perform contractsto provide service

      ー Providecontent, deliver goods

    • (3) Manage Talkafe members

      ー Prevent illegal or unauthorized useof service by Talkafe members, check multiple membership for a single member, confirm intent to become a member, recordkeeping for dispute resolution, handle customer complaints, notify members

    • (4) Utilize for marketing and advertisement purposes

      ー Develop newservicesandprovide tailored services, provideservicesandpost advertisements based on statistics, check effectiveness of services, check access frequency, prepare statistics on Talkafe members’ use of services, provideevent/advertising information and opportunities for participation

Article 4 (Sharing andproviding personal information)

  • 1. The Company shall usea user’spersonal information within the scopenotified in “2. Purpose of collecting and using personal information.” The Company may not use a user’s personal informationin excess of such scopeor disclose such information in principlewithout the user’s prior consent,,except in the following cases.
    • (1) A user gives prior consentto disclosure.
    • (2) Where required by the law, or requested by a criminal investigation agency for criminal investigation purposes and pursuant tothe procedure and method prescribed by the law
  • 2. Personalinformation may only be provided to a third party as follows, if the relevant Talkafe member provides consent.
    Receiver of information Job being contracted Information provided Period of holding andusing the Information
    Hancom, Inc.andits subsidiaries Subscribe to service, identify members, respond to customers’ inquiries Name, mobile phone number, address, email address While the relevant Talkafe member retains his/her membership
    Wincube Marketing Co., Ltd. Provide mobile coupon (gift shop) service Name, mobile phone number, email address Untilthe end of contract with contractor

Article 5 (Handling of collected personal informationby a contractor)

  • 1. To improve service, the Company shall appointspecializedcontractorsto manage personal information. For the safety of the contracted personal information management, the Company shall expressly prescribe, in the contractwith the contractor, strict compliance with the service provider’s personal information-related directions, confidentiality of personal information, prohibition on providing personal information to third parties, liabilities, etc. and shall keepsuch contractin writing.
  • 2. The following are contractors handling the Company’s personal information and the job being contracted.
    Contractors Jobbeing contracted
    SureM Co., Ltd. SMS verification
    SureM Co., Ltd. ACS verification
    Wincube Marketing Co., Ltd. Provide informationon mobile coupon purchase

Article 6 (Period of holding andusing collected personal information)

  • 1. If a Talkafe memberwithdraws his/her membership or if his/her Talkafe member ID is deleted for falsely stating personal information,then the collected personal information shall be completely deleted,and processed so that the information cannot be used for any purpose.
  • 2. A Talkafe member’spersonal information, once the purpose of collection and use thereof is achieved under Article 7 Paragraph 1 of this Personal Information Handling Policy, shall promptlybe destroyed. However, if the personal information needs to bekept under the Company’s internal policies or applicable laws, then it may bekept for such periodsas mentioned below.
    Items being kept Legal basis, etc. Keeping period
    Records of unauthorized use Internal policies 6 months
    Records of dispute (e.g., consumer complaint) resolution Act on Consumer Protection in E-Commerce 3 years
    Records of visitation Communications Secret Protection Act 3 months

Article 7 (Procedureandmethodof destroying personal information)

  • 1. After achieving the purpose of collecting and using personal information, the Company shall promptlydestroy such information, in principle.
  • 2. Destroying procedure
    • (1) Informationentered by a Talkafe member for membership subscription, in principle, shall promptlybe destroyed when the purpose of collecting and using that personal information is achieved. Unless required by the law, the information shall not be used for any purpose other than that of holding the information.
  • 3. Destroying method
    • (1) Print-outpersonal information shall be destroyed by shredding or incineration, and personal informationstored in the form of an electronic fileshall be deleted by a technical method that disallows reproduction of the records.

Article 8 (Talkafe member’srights and method of exercising them)

  • 1. The Companydoes not collect a user’s age, but if at any timeit turns out that the user is below 14 years of age, then the user will be required to obtain his/her legal representative’sconsent.
  • 2. A Talkafe member may at any timecheck, view, or correct his/her personal information and request that his/her membership be terminated or personal information processing be suspended. In that case, useof service may be restricted in whole or in part.
  • 3. A Talkafe member may directly view and correct his/her personal information through [My Profile] in the service. A Talkafe member may at any timeterminate the service contract through [Talkafe Withdrawal]in the serviceand, when terminating it, his/her personal information shall be entirely deleted. However, in the case described in Article 6 Paragraph 2 of the Personal Information Handling Policy, the personal information may be kept for certain periods under applicable laws.
  • 4. When a Talkafe member requests correctionordeletion of his/her personal information, the Company, shall promptlytake necessarymeasuresafter verifying the identity of the member. In the case described in Article 20 Paragraph 1(Restriction on use) of the Terms of Service, personal informationsuch as Talkafe member IDmay be destroyed under judgment of the chief personal information officer.
  • 5. When a request for correction of personal information error is made, such personal information shall not be usedorprovided until the correction is completed. If any false personal information has already been provided to a third party,then the resultof correction shall promptlybe notified to such third party so that the latter can make correction.
  • 6. The Company shall process the personal information, terminated or deleted upon a Talkafe member’s request, as specified in Article 6 of the Personal Information Handling Policy. The Company will see to it that the information may not be viewed orused for any other purposes.

Article 9 (Technical andadministrative measures for personal information protection)

To ensure safety so that personal information may not be lost, stolen, leaked, altered without authorization, or damagedin the handling of Talkafe members’personal information, the Company shall take the followingtechnical and, administrative measures.

  • 1. Technicalmeasures
    • (1) The Companyshall doits best to prevent hacking or computerviruses from leaking or damaging Talkafe members’personal information. It shall from time to time backup data (in preparation for personal informationcompromise), keepusers’ personal information or data from being leaked or damaged using up-to-date anti-virusprograms, and seeto it that personal information is safely transmitted over the network throughencrypted communications, etc. The Company shall controlunauthorized access from the outside with use of an intrusion detection system, and endeavorto be equipped with all available technical devices for systemic assurance of security.
  • 2. Administrativemeasures
    • (1) The Company’shandling of personal information can only be performed by its relevantpersonnel in charge, and a separatepasswordfor thatshall begranted and periodically updated. The Company shall stresscompliance with the Personal Information Handling Policy at all times, and educate the relevant personnel in charge from time to time.
    • (2) The Companyshall appointits chief personal information officer, thereby checking implementation of the Personal Information Handling Policy at all times, and shall endeavorto immediatelycorrectand rectify any problems found. However, the Company shall not be at all liable for problems occurring from personal information leakagedue toa user’s own negligence or problems in the Internet.

Article 10 (Linked sites)

The Company may provide Talkafe members with a link to another company’s website or materialsthrough Talkafe. Since the relevant site’s personal information handling policyis unrelated to that of Talkafe, Talkafe members shall check the personal information handling policy for that site.

Article 11 (Chief personal information officer)

The Company designates the chief personal information officer in charge of collecting opinions and handling complaints concerning personal information.

Chiefpersonal information officer Customer service
Company/service Hancom Talkafe Inc. Hancom Talkafe Inc.
Name Oh, Myung-jin Choi, Sang-Yun
Title Business Planning team Service Planning Team

  • (1) Working hours of personal information manager
    • - Ordinary days: 09:00~18:00
    • - Saturdays, Sundays, and holidays shall be off days.
  • (2) Other reporting or counseling agencies on personal informationviolation

Article 12 (Amendment of Personal Information Handling Policy)

  • 1. The Company, when intending to amendthis Personal Information Handling Policy, shall notify itas announcement in the Service, along with the current Personal Information Handling Policy, from 7 days before the effective date of amendment until the effective date, by specifying the reason and effective date of the amendment. If there is any material change in the users’ rightsorobligations,however, then notification shall be made at least 30 days in advance.
  • 2. If the Companynotifies under Paragraph 1 that a failure to state objection by the effective date shall be deemed to have stated his/her intent,but a usernevertheless fails to expressly state objection, then the user shall be deemed to consent to the amendment.
  • 3. Notwithstanding Paragraph 2, the Companyshall obtain a separate consent from the user,when collecting additional personal information from a user or providing it to a third party.

This Personal Information Handling Policy shall become effective on January 1, 2017.

- Announcement Date: November 13, 2016

- Effective Date: November 20, 2016