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Privacy Policy

CLASSUM Co., Ltd. (“CLASSUM”) operates a privacy policy (“Privacy Policy”) as shown below to protect the personal information of its data subjects (“Users”) and to process any related complaints in a prompt manner in accordance with Article 30 of the Personal Information Protection Act. This Privacy Policy of CLASSUM may be amended from time to time subject to the changes in the applicable law, policy, or CLASSUM's internal policy, etc., and any such changes to the Privacy Policy will be announced on the website so that Users may easily be informed of the changes.
This Privacy Policy will take effective from February 11th, 2022 (“Effective Date”).

1. Purpose of Processing Personal Information

CLASSUM collects the minimum amount of personal information that is necessary to provide services to Users and obtains consent from Users for the collection of such information. The items of personal information that are collected are shown below, which are used only for the notified purposes. CLASSUM processes personal information for the following purposes and does not use it for any other purposes.
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To perform obligations under the service agreement, settle charges for services rendered, purchase and pay for service, manage membership, and verify identification;
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To authenticate members prior to allowing the use of membership-based services for the management of members, conduct personal identification, prevent illegal or unauthorized use by delinquent members, confirm members' intention to execute service agreements, verify age, handle complaints and other grievances, and provide notices to members;
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To develop and specialize new services (products) for marketing and advertisements, deliver advertising information, such as event information, etc., understand access frequency or compile statistics on members' use of the services; and
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To restrict the number of subscriptions, preserve records for dispute resolution, build a service environment to strengthen privacy protection, monitor members' satisfaction with the service and goal satisfaction status, calculate statistics on lectures, classes, and interests, etc.

2. Items of Personal Information to be Processed

1.
CLASSUM processes the following items of Personal Information
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Required items: name, mobile phone number, e-mail address, affiliated organization, major, legal representative’s information for members under the age of 14 (name, date of birth, gender, e-mail address, mobile phone number of the legal representative)
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Optional items: occupation, consent to receive marketing information
2.
Information, such as mobile device IDs, access IP address, advertising ID (AAID, IDFA, etc.), cookies, and access date/time, etc. may be automatically generated and collected to check whether any content has been used in the process of using the service or operating the business.
3.
CLASSUM collects the following personal information from a third party when Users subscribe for membership (or subscribe for service) through external platforms or by synchronizing accounts.
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Google: Google ID, e-mail address
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Apple: Apple ID, e-mail address (if selected, collected only once initially)
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Facebook, Inc.: Facebook ID, e-mail address (optional), profile photo (optional)
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Membership through an institution affiliated with CLASSUM: The member’s name and e-mail registered with the affiliated institution

3. Processing of Personal Information and Retention Period

1.
CLASSUM processes and holds personal information for the period of retention and use to which Users consented when the personal information was collected or within the period of retention and use permitted under law.
2.
The specific periods for processing and retaining personal information are as follows:
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Prevention of fraudulent subscription and inappropriate use: If there is a record of inappropriate use of the service, such as fraudulent subscription, unauthorized disclosure of posts, or sharing of ID, etc., the authentication information for subscription (e-mail address or Facebook serial number, legal representative’s e-mail address and mobile phone number in the case of a member under the age of 14), among other personal information, will be retained for one year from the date of cancellation of User’s membership.
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User subscription and management: Until the service agreement or membership is terminated. However, if there remain any receivables or debtor-creditor relationship, personal information of the member will be retained until such receivables are collected or the debtor-creditor relationship is settled.
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Records of e-commerce contracts and withdrawal of e-commerce subscription, payment records and records of supply of goods, etc.: 5 years
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Records of consumer complaints or dispute settlements: 3 years
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Records of User access logs (communication confirmation data): 3 months

4. Providing Personal Information to a Third Party

CLASSUM does not provide the personal information of its members to a third party unless it is specifically permitted by law, such as when it obtains consent from Users in accordance with Article 17 of the Personal Information Protection Act or when the personal information is used for statistical, academic, research, or market survey purposes, etc. pursuant to Article 28-2 of the Personal Information Protection Act after being anonymized with the removal of all personally identifiable information.

5. Entrustment of Personal Information Processing

CLASSUM entrusts the processing of the following personal information in order to facilitate the processing of personal information.
1.
Entrusted entity: humusOn Inc.
Entrusted Operation: Sending service-related e-mails
2.
Entrusted entity: Channel Corp.
Entrusted Operation : Customer Consultation

6. Rights and Obligations of Users and Their Legal Representatives, and Methods of Exercising their Rights

Users may exercise each of the following privacy rights against CLASSUM at any time. If User is a child under the age of 14, a legal representative of the child may exercise the privacy rights against CLASSUM.
1.
Right to request access to their personal information
2.
Right to request the correction if there is any error, etc. to their personal information
3.
Right to request the deletion of their personal information
4.
Right to request the suspension of processing

7. Destruction of Personal Information

If personal information becomes unnecessary because the retention period of the personal information has passed or the purpose of processing the personal information has been accomplished, etc., CLASSUM will destroy the personal information without delay in the manner set forth below.
1.
Process of destruction: The information entered by Users is transferred to a separate DB (in the case of paper documents, to a separate file) after the purpose of the information has been served and is destroyed immediately or after being stored for a certain period in accordance with internal policy and other applicable laws. The personal information that is transferred to a separate DB will not be used for any purposes except as required by law.
2.
Destruction period: The personal information of Users must be destroyed within five days from the last date of the retention period if the retention period for the personal information has passed; and within five days from the date the processing of the personal information is determined to be unnecessary, if the processing of personal information is so determined to be unnecessary due to the purpose being served, such as the discontinuance of the relevant service or the termination of the business, etc.
3.
Destruction method: Information in electronic files must be destroyed using technical methods that prevent the reproduction of the record. Personal information printed out on paper must be destroyed by shredding it in a shredder or incinerating it.

8. Measures to Ensure the Safe Protection of Personal Information

CLASSUM takes the following measures to ensure that the User’s personal information is safely protected.
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Management measures: CLASSUM establishes and implements internal management plans and provides regular training for its employees and staff.
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Technical measures: CLASSUM manages access privileges by setting passwords on computers where personal information is stored, installs security programs such as vaccine software, etc., and encrypts files containing personal information.

9. Matters Concerning the Installation, Operation, and Refusal of Automatic Personal Information Collection Devices

1.
CLASSUM uses cookies to store and retrieve User data in order to provide customized services for each User.
2.
A cookie is a small piece of data sent by the server used to operate the website to the User's computer browser, which may be stored in the hard disk of the User's PC.
a.
Purpose of cookies: Cookies are used to identify the various services and websites visited by the Users, the type of use, frequently used search terms, use of a secure connection, etc., in order to provide the Users with optimized information.
b.
Refusal of installation and operation of cookies: Users may disable cookies at Tool at the top of the web browser → Internet Option → Option in the Personal Information menu.
c.
Refusing to store cookies may cause some interference in using CLASSUM’s customized services.

10. Using and Providing Personal Information Within the Scope Reasonably Related to the Purpose of Collection

CLASSUM may use or provide personal information to a third party without consent from the Users, in consideration of the following criteria and within the scope reasonably pertinent to the original purpose of collecting the personal information.
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Whether it is related to the original purpose of collection: This is determined by considering whether the original purpose is related to the purpose of additionally providing or using personal information in terms of nature or tendency.
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Whether the additional use or provision of personal information to a third party is predictable in light of the circumstances of collection or processing practices: This is determined by considering the relationship between the personal information controller and the User, the level of technology and speed of technological advancement, general circumstances (practice) established over a considerable period of time.
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Whether the interest of the User is unfairly infringed upon: This is determined by considering whether the interest of the User is substantively infringed upon in relation to the purpose of the additional use of personal information and whether the infringement of interest is justifiable.
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Whether necessary measures have been taken to ensure safe protection of personal information, including the pseudonymization or encryption of information, etc.: This is determined by considering whether safety measures have been taken in proportion to the possibility of infringement.

11. Chief Privacy Officer

CLASSUM appoints the Chief Privacy Officer and Privacy Officer, as shown below, to oversee the processing of personal information and to respond to the User complaints and remedies in connection with the processing of personal information.
Chief Privacy Officer
Name: Youjin Choi Title: Director (CEO) Contact: privacy@classum.com / youjin@classum.com
Privacy Officer
Name: Jihye Kang Title: Product Manager Contact: privacy@classum.com / jenny@classum.com
Users may contact the Chief Privacy Officer and the department in charge for all inquiries about the protection of personal information, processing of complaints, and remedies for any damage, etc. that Users may have while using the service provided by CLASSUM. CLASSUM will promptly respond and process User inquiries.

12. Amendment of Privacy Policy

This Privacy Policy takes effect from the Effective Date. CLASSUM will notify, through its notifications, Users of any addition, deletion, or modification to the Privacy Policy made in accordance with law and policies seven days prior to the date when the change is to take effect.