This Policy (the "Policy") explains the way of treatment of the information which is provided or
collected in the web sites on which this Policy is posted. In addition the Policy also explains the
information which is provided or collected in the course of using the applications of the Company
which exist in the websites or platforms of other company.

The Company is the controller of the information provided or collected in the websites on which
this Policy is posted and in the course of using the applications of the Company which exist in the
websites or platforms of other company.

Through this Policy, the Company regards personal information of the users as important and
inform them of the purpose and method of Company's using the personal information provided
by the users and the measures taken by the Company for protection of those personal
information. 

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This Policy will be effective on the 1 day of January, 2020 and, in case of modification thereof,
the Company will make public notice of it through posting it on the bulletin board of Company's
website or individual notice through sending mails, fax or e-mails). 

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1. Information to be collected and method of collection
(1) Personal information items to be collected
Personal information items to be collected by the Company are as follows:
• Information provided by the users
The Company may collect the information directly provided by the users.

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• Information collected while the users use services
Besides of information directly provided by the users, the Company may collect information in
the course that the users use the service provided by the Company.

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(2) Method of collection
The Company collects the information of users in a way of the followings:
• webpage, written form, fax, telephone calling, e-mailing, tools for collection of created
information
• provided by partner companies

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2. Use of collected information
The Company uses the collected information of users for the following purposes:
• Member management and identification
• To detect and deter unauthorized or fraudulent use of or abuse of the Service
• Performance of contract, service fee payment and service fee settlement regarding provision
of services demanded by the users
• Improvement of existing services and development of new services
• Making notice of function of company sites or applications or matters on policy change
• To help you connect with other users you already know and, with your permission, allow other
users to connect with you
• To make statistics on member’s service usage, to provide services and place advertisements
based on statistical characteristics
• To provide information on promotional events as well as opportunity to participate
• To comply with applicable laws or legal obligation

• Use of information with prior consent of the users (for example, utilization of marketing
advertisement)
The Company agrees that it will obtain a consent from the users, if the Company desires to use
the information other than those expressly stated in this Policy. 

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3. Disclosure of collected information
Except for the following cases, the Company will not disclose personal information with a 3rd
party:
• when the Company disclosing the information with its affiliates, partners and service providers;
- When the Company's affiliates, partners and service providers carry out services such as
bill payment, execution of orders, products delivery and dispute resolution (including
disputes on payment and delivery) for and on behalf of the Company
• when the users consent to disclose in advance;
- when the user selects to be provided by the information of products and services of certain
companies by sharing his or her personal information with those companies
- when the user selects to allow his or her personal information to be shared with the sites
or platform of other companies such as social networking sites
- other cases where the user gives prior consent for sharing his or her personal information
• when disclosure is required by the laws:
- if required to be disclosed by the laws and regulations; or
- if required to be disclosed by the investigative agencies for detecting crimes in accordance
with the procedure and method as prescribed in the laws and regulations

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4. Cookies, Beacons and Similar Technologies
The Company may collect collective and impersonal information through 'cookies' or 'web
beacons'.
Cookies are very small text files to be sent to the browser of the users by the server used for
operation of the websites of the Company and will be stored in hard-disks of the users' computer.
Web beacon is a small quantity of code which exists on the websites and e-mails. By using web
beacons, we may know whether an user has interacted with certain webs or the contents of
email.
These functions are used for evaluating, improving services and setting-up users' experiences so
that much improved services can be provided by the Company to the users
The items of cookies to be collected by the Company and the purpose of such collection are as
follows:
 

5. User’s right
The users or their legal representatives, as main agents of the information, may exercise the
following rights regarding the collection, use and sharing of personal information by the
Company:
• exercise right to access to personal information;
• make corrections or deletion;
• make temporary suspension of treatment of personal information; or
• request the withdrawal of their consent provided before
If, in order to exercise the above rights, you, as an user, use the menu of 'amendment of member
information of webpage or contact the Company by sending a document or e-mails, or using
telephone to the company(or person in charge of management of personal information or a
deputy), the Company will take measures without delay: Provided that the Company may reject 

the request of you only to the extent that there exists either proper cause as prescribed in the
laws or equivalent cause. 

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6. Security
The Company regard the security of personal information of uses as very important. The company
constructs the following security measures to protect the users' personal information from any
unauthorized access, release, use or modification
• Encryption of personal information
- Transmit users' personal information by using encrypted communication zone
- Store important information such as passwords after encrypting it
• Countermeasures against hacking
- Install a system in the zone the external access to which is controlled so as to prevent
leakage or damage of users' personal information by hacking or computer virus
• Establish and execute internal management plan
• Install and operate access control system
• Take measures to prevent forging or alteration of access record

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7. Protection of personal information of children
In principle, the Company does not collect any information from the children under 13 or
equivalent minimum age as prescribed in the laws in relevant jurisdiction. The website, products
and services of the Company are the ones to be provided to ordinary people, in principle. The
website or application of the Company has function to do age limit so that children cannot use it
and the Company does not intentionally collect any personal information from children through
that function. 

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(Additional procedure for collecting personal information from children) However, if the
Company collects any personal information from children under 13 or equivalent minimum age
as prescribed in the laws in relevant jurisdiction for the services for unavoidable reason, the
Company will go through the additional procedure of the followings for protecting that personal
information of children:• verify, to the extent that efforts are reasonably made, whether they
are children of the age at which consent from their guardian is required and the consenting
person is an authorized one.
• obtain consent from the parents or guardian of children so as to collect personal information
of children or directly send the information of products and services of the Company
• give the parents or guardian of children a notice of Company's policy of privacy protection for
children including the items, purpose and sharing of personal information collected
• grant to legal representatives of children a right to access to personal information of that
children/correction or deletion of personal information/temporary suspension of treatment of
personal information/ and request for withdrawal of their consent provided before
• limit the amount of personal information exceeding those necessary for participation in online
activities 

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8. Modification of Privacy Protection Policy
The Company has the right to amend or modify this Policy from time to time and, in such case,
the Company will make a public notice of it through bulletin board of its website (or through
individual notice such as written document, fax or e-mail) and obtain consent from the users if
required by relevant laws. 

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9. Others
[Option to select 'data transfer to other countries ' in Appendix <3> of Personal Privacy Policy]
[Option to select 'sites and service of 3rd party' in Appendix <4> of Personal Privacy Policy]
[Option to select 'guidelines for residents in California' in Appendix <5> of Personal Privacy Policy]

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10. Contact information of Company
Please use one of the following methods to contact the Company should you have any queries in
respect to this policy or wish to update your information:
•Company name : Cubroid, Inc.
Address : #1919, C-dong, IncheonTechnoValleyU1Center, 236, Jubuto-ro, Bupyeong-gu, Incheon, Republic of Korea
Tel.: +82-70-70059296
E-mail: info@cubroid.com

(Add the following if designated of data protection officer) The Company designates the
following Data Protection Officer (DPO) in order to protect personal information of customers
and deal with complaints from customers.
DPO of the Company
Adress: #1919, C-dong, IncheonTechnoValleyU1Center, 236, Jubuto-ro, Bupyeong-gu, Incheon, Republic of Korea
Tel.: +82-70-70059296
E-mail: info@cubroid.com

(Add the following if the controller operating outside of the EU designates its deputy in the EU)
The Company designates a deputy in the EU in order to protect personal information of customers
and deal with complaints from customers.
Deputy of the Company
Adress: #1919, C-dong, IncheonTechnoValleyU1Center, 236, Jubuto-ro, Bupyeong-gu, Incheon, Republic of Korea
Tel.: +82-70-70059296
E-mail: info@cubroid.com
The latest update date: January 1, 2020

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Appendix of Privacy Protection Policy

<1> Lawful processing of personal information under GDPR
Processing personal information by the Company shall be lawful only if and to the extent that at
least one of the following applies:
• A user has given consent to the processing of his or her personal information.
• Processing is necessary for the performance of a contract to which a user is party or in order
to take steps at the request of a user prior to entering into a contract:
- Member management, identification, etc.
- Performance of a contract in relation to providing the services required by users, payment
and settlement of fees, etc.
• Processing is necessary for compliance with a legal obligation to which the Company is subject
- Compliance with relevant law, regulations, legal proceedings, requests by the
government
• Processing is necessary in order to protect the vital interests of users, or other natural persons
- Detection of, prevention of, and response to fraud, abuse, security risks, and technical
issues that may harm users or other natural persons
• Processing is necessary for the performance of a task carried out in the public interest or in the
excise of official authority vested in the Company
• Processing is necessary for the purposes of the legitimate interests pursued by the Company
or by a third party (except where such interests are overridden by the interests or fundamental
rights and freedoms of the data subject which require protection of personal data, in particular
where the data subject is a child).

<2> User’s right when applying GDPR

The users or their legal representatives, as main agents of the information, may exercise the
following rights regarding the collection, use and sharing of personal information by the
Company:
• The right to access to personal information;
The users or their legal representatives may access the information and check the records of the
collection, use and sharing of the information under the applicable law. • The right to
rectification;
- The users or their legal representatives may request to correct inaccurate or incomplete
information.
• The right to erasure;
- The users or their legal representatives may request the deletion of the information after
the achievement of their purpose and the withdrawal of their consent.
• The right to restriction of processing;
- The users or their legal representatives may make temporary suspension of treatment of
personal information in case of the disputes over the accuracy of information and the
legality of information treatment, or if necessary to retain the information.
• The right to data portability
- The users or their legal representatives may request to provide or transfer the information.
• The right to object
- The users or their legal representatives may suspend the treatment of personal
information if the information is used for the purpose of direct marketing, reasonable
interests, the exercise of official duties and authority, and research and statistics.
• The right to automated individual decision-making, including profiling

- The users or their legal representatives may request to cease the automated treatment of
personal information, including profiling, which has critical impact or cause legal effect
on them.
If, in order to exercise the above rightss, you, as an user, use the menu of 'amendment of member
information of webpage or contact the Company by sending a document or e-mails, or using
telephone to the Company ( person in charge of management of personal information or a
deputy), the Company will take measures without delay: Provided that the Company may reject
the request of you only to the extent that there exists either proper cause as prescribed in the
laws or equivalent cause. 

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<3> Data transfer to other countries
Considering it engages in global businesses, the Company may provide the users' personal
information to the companies located in other countries for the purpose as expressly stated in
this Policy. For the places where the personal information is transmitted, retained or processed,
the Company takes reasonable measures for protecting those personal information.
(If used in the US, additional security measures may be available) In addition, when the personal
information obtained from the European Union or Switzerland is used or disclosed, the Company
may have to comply with the US-EU Privacy Shield and Swiss-US Privacy Shield, take other
measures or obtain consent from users so far as those complies with the regulations of EU so as
to use a standardized agreement provision approved by executing organizations of EU or securing
proper safe measures.

<4> 3rd party's sites and services
The website, product or service of the Company may include the links to the ones of a 3rd party
and the privacy protection policy of the site of 3rd party may be different. Thus, it is required for
the users to check additionally that policy of a 3rd party site linked to the site of the Company. 

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<5> Guide for users residing in California
If the user resides in California, certain rights may be given. The Company prepare preventive
measures necessary for protecting personal information of members so that the Company can
comply with online privacy protection laws of California.
In case of leakage of personal information, an user may request the Company to check the
leakage. In addition, all the users in the website of the Company, can modify their information at
any time by using the menu for changing information by connecting their personal account.
Moreover, the Company does not trace the visitors of its website nor use any signals for 'tracing
prevent'. The Company will not collect and provide any personal identification information
through ad services without consent of users.
 

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