Privacy Protection Policy

YUJIN ROBOT Co., Ltd. (hereinafter, the “Company”) regards its customers’ personal information as important and complies with the Act on Promotion of Information and Communication Network Use. Company informs the Users of what are the use and collection method of privacy information provided by them and which measures the Company takes for privacy protection through Company’s privacy protection.

1. Definitions
As used herein, the following terms shall have the following meanings:
“User” means the customer using any service (the “Service”) provided by Company.
“Service” means any and all the services provided by Company.
“Terminal” means smart phone, tablet PC devices in which the Service may be downloaded, installed and used
“Application” means any and all the programs which are downloaded, installed and used through the Terminal for using the Service provided by Company.
“App Store (open market) Service Provider” (the “ASSP”) means the service provider providing open market provided for installation of the application of Company.
“Platform Service Provider” (the “PSP”) means the service provider providing the Service by making partnership relations with CY and all the services related thereto in promoting or using the application of Company.
“User Account” means the information, as information for identification of User, for identification of User provided by PSP, is provided and used by receiving unique identification number (consisting of specific number or characters) other than direct indication or exposure to PSP .
2. Any other terms used herein than those defined herein shall mean as prescribed in applicable laws and regulations and, otherwise, mean as customary practices.

1. Items and collection method of personal information
1) Items of personal information to be collected
The following information may be generated and collected in the course of using Service or handling the business of Company:

① Information of mobile phone Terminal of User (including model name, OS version, mobile firmware version, and unique device number), IP Address, cookies, the place of latest access.
② Access date, service use record and record of bad use
2) Collection method of personal information: Company collects personal information in the following way
① Collect through consent process while joining membership of Service of Company
② Collect through a separate consent process while carrying out a promotion and event
③ Collect automatically through platforms which are in partnership relations with Company in terms of provision of Service
④ Collect on voluntary provision or need of User while responding to the customers during membership to, payment for and use of the Service

2. Purpose of collection and use of personal information
Company uses the collected information of User for the following purposes:
1. Secure smooth communication route for delivery of notice and treatment of complaints
2. Handle inquiries on use of paid information and provide customer services including resolution of contract performance dispute and refund of payment
3. Guide information of new services and new products event
4. Provide other contents and certification service

3. Sharing and provision of personal information
Company will use the personal information of User within the scope of notice as set forth in the foregoing “2. Purpose of collection and use of personal information” and shall not disclose such personal information without prior consent of User, in principle, except for the following cases:
1. when User gives prior consent on disclosure, or
2. when the disclosure of such personal information is required by the provisions of laws and regulations or law enforcement agencies in accordance with the procedure and method as prescribed therein for investigation

4. Consignment of processing and handling of personal information
Company will not consign outside subcontractors to handle the personal information without consent of User and, if necessary in the future, will inform the consignee and customers of details of such consignment duties and obtain prior consent from User if necessary.

5. Period of retention and use of personal information collected by Company
(1) Company continues to retain personal information of User until and before User’s withdrawal of membership, in principle and destroy such personal information without delay upon achievement of the purpose of collection and use of personal information.
(2) However, even after achievement of the purpose of collection and provision of personal information and when necessary to be retained as required by provisions of relevant laws and regulations including the Commercial Act, under internal policies and other applicable laws and regulations, Company may retain the Users’ personal information for certain periods as follows and, in such event, such personal information will be used only for the purpose of such retention:
in order to prevent the recurrence of misuse of faulty members, Company may retain the record of that misuse of those members and information of overlapping membership for 1 year after the date of termination of user agreement. For the parts of contents such as golf swing analysis data generated while a member uses the service, upon separate request of that member after termination of user agreement, those parts will be promptly deleted.
1. Record of conclusion and termination of contract or subscriptions: 5 years (Ground for retention: Act on Consumer Protection in E-commerce)
2. Record of payment and supply of goods: 5 years (Ground for retention: Act on Consumer Protection in E-commerce)
3. Record of payment and consumer complaint and dispute resolution: 3 years (Ground for retention: Act on Consumer Protection in E-commerce)
4. Record of self-authentication: 6 months (Ground for retention: Act on Promotion of Information and Communication Network Use)
5. Record of visitation (including access log, and service use record): 3 months (Ground for retention: Communications Privacy Act)

6. Procedure and method of destruction of personal information
Company destructs any information immediately after the purpose of its collection and use have been achieved without delay, in principle and the process and method thereof are as follows:
(1) Process of destruction
1. After achieving the purpose, the information entered by the users will be maintained for certain period of time for the reason of causes in accordance with internal policy and other applicable regulations (please refer to the retention and use period) and discarded thereafter.
2. Unless required by the law, personal information will not be used for the other purposes than the one for retention as described above.
(2) Method of destruction
1. Company deletes personal information stored in the form of electric file by using technological method that makes that information not to be regenerated.
2. Company destructs hard copies of personal information by shredding with a pulverizer or incinerating it.

7. Rights and its exercise of User and legal representative
(1) The rights of User and its legal representative may be exercised by making a request through the platform having partnership relations with Company in terms of provision of Service or directly request in the homepage of Company.
(2) User and its legal representative may check and amend any registered personal information of itself or relevant child under 14 at any time and may request for withdrawal of membership.
(3) Company will take immediate measures when User contact the person responsible for managing personal information by written document, telephone call or e-mail
(4) If the User requests Company to make correction in error of personal information, Company will not use or provide until such correction is completed. In addition, if any personal information having error has been already provided to a 3rd party, Company will inform the result of such correction to the 3rd party to ensure that such personal information having error will be corrected.
(5) For any personal information terminated or deleted upon request of User or its legal representative, Company handles as set forth in “Retention and use period of personal information” above and treats to ensure that such personal information will not be accessed or used for other use.

8. Matters on installation/operation or rejection of cookie
In order to provide special customized services to its users, Company uses cookie which saves and retrieve your information frequently. Cookie is a tiny text file which the server used for operation of website of the Company sends and that file may be stored in your computer hard disk. Company finds information of ID by using cookie for providing more suitable and useful services to its users. Cookie identifies the user’s computer but does not identify the user personally. By identifying each service of Company the users have visited through using cookie, Company can make and provide customized services including information interlocking and most optimal information for the users. The users may have option for allowing the use of cookie: by setting up options in mobile devices/PC or delete the cookies but, in such event of rejection, the users may have difficulties in using while using Service requiring login.

9. Technical/managerial protective measures related to personal information
In handling its users’ personal information, Company takes the following technical/managerial protection of personal information to secure safety so that such personal information will not be lost, stolen, leaked, altered or damaged.
(1) Countermeasures against hacking
The Company makes its best effort in preventing leakage and damage of personal information of members by hacking and computer virus. In order to prevent any damage on personal information, the Company makes back-up data from time to time and prevents leakage and damage of personal information of users by using the latest vaccine program and, through module of password decode, the Company safely transmits personal information in the network. In addition, in order to secure stability of system, the Company makes its best efforts in being equipped with all available technical devices.
(2) Minimization the number of employees handling personal information and education for them
The Company designates specific employee to deal with personal information of users and gives special password and renew it in regular basis and, through making him or her take responsibility and education, the Company always emphasizes compliance with privacy protection policy of the Company. (3) Operation of organization dedicated to privacy protection
Company take corrective measures immediately upon occurrence of problem by checking whether this privacy protection policy is performed through internal organization dedicated to privacy protection or not or the person in charge thereof complies of such policy or not: Provided that Company will never responsible for any problem arising out of leakage of personal information including account ( ID), password, nickname and e-mail of the platform which are in partnership relations with Company in terms of provision of Service

10. Contact Us
10. Contact numbers of the person in charge of personal information management and person in charge
1) The company has appointed a person in charge of personal information management and person in charge of collecting opinions and complaints about personal; the contact information is as follows.
① A person in charge of personal information management: Ko, Sang-Yoon, syko@yujinrobot.com
② A person in charge of personal information management: Ko, Sang-Yoon, syko@yujinrobot.com
2) If you want to consult a public organization other than our company, you can consult the following organizations.
– Infringement of the personal information center in Korea Information Security Agency(KISA) (http://www.118.or.kr, phone 118)
– Information protection mark authentication committee (http://www.privacy.or.kr, phone 02-580-0533~4.
– High-Tech Crimes Department in Supreme Prosecutors’ Office (http://www.spo.go.kr, phone 02-3480-2000)
– Cyber Terror Response Center in the National Police Agency (http://www.ctrc.go.kr, phone 02-392-0330)

11. Miscellaneous
(1) Company may provide the links for websites or data of other companies to the User and, in such event, Company has no control thereon and will not responsible or warrant the usefulness of the service or data provided thereby.
(2) If the User clicks such links provided by Company and moves to the page of other sites, the privacy protection policy and user terms and conditions of such sites are not related to Company and please check the policy of such sites newly visited.
(3) User has the right to protection of his or her personal information and also has obligation to ensure that the personal information of him/herself will be protected by him/herself and will not be infringed on the information of others. User shall be cautious not to leak his or her own personal information including password and be careful not to damage personal information of others including materials posted. Otherwise, if the User damages the information and dignity of others, the User may be punished under applicable laws and regulations.
(4) User shall be fully responsible for any disadvantages or property damage in using the Service arising out of entering incorrect or fraudulent information in filing out its personal information.

12. Notice obligation
If any addition, deletion and amendment (the “Revision”) are made for current privacy protection policy of the Company, the Company will inform it through its homepage at least 10 days before such Revision.

– Public notice date: Sep 1, 2018
– Enforcement date: Sep 1, 2018