POLICY VIRAADS

This Policy (the “Policy”) explains the way of treatment of the information which is provided or collected on the websites 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 services of the Company which exists on the websites or platforms of other companies.

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

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

This Policy will be effective on the 1st day of April 2022, the Company will make public notice of it by posting it on the bulletin board of the Company’s website (or individual notice through sending mails, fax, or e-mails).

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.

Classification	Items to be collected
Sign up for Business	ID, password, email, phone number, company name, name of the representative, business type, business item, business address, business registration number, name of contact person, etc. Representative site name, representative site URL
Sign up for Individual	Name, ID, password, email, phone number, company name, business address, etc. Representative site name, representative site URL
Commissions and Refunds Payment	Bank account information (bank name, account number, name on account) For individuals, name and resident registration numbers (related to withholding), etc.
Inquiries	Name, email, phone number, company name, etc. Representative site name, representative site URL

Information collected while the users use services: Besides information directly provided by the users, the Company may collect information in the course that the users use the service or watch content/ads provided by the Company or partner companies. All of the information below is collected only as non-personally aggregated information that can not identify the subject of the information.

Lists	Items to be collected
Equipment information	Equipment identifier, operation system, hardware version, equipment set-up, type and set-up of the browser, use information of website or application, etc.
Log information	IP address, log data, use time, search word input by users, user activity, abusing history, internet address (URL), cookie and web beacon, etc.
Location information	Information of device location including specific geographical location detected through GPS, Bluetooth, or Wifi (limited to the region permissible under the laws), etc.
Other information	Advertisement environment, etc.

(2) Method of collection

The Company collects the information of users in a way of the followings:

Web page, written form, fax, telephone calling, e-mailing, tools for collection of created information
Provided by partner companies

2. Purpose of collecting and using personal 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 regarding provision of services demanded by the users, commission and refund transaction and payment, etc.

Improvement of existing services and development of new services
Making notice of function of company sites or services or matters on policy change
Use of information with the prior consent of the users (for example, utilization of marketing advertisement)

To make statistics on member’s service usage, to provide personalized services and advertisements based on statistical characteristics

To provide information on promotional events as well as opportunity to participate
To comply with applicable laws or legal obligations

The Company agrees that it will obtain consent from the users if the Company desires to use the information other than those expressly stated in this Policy.

3. Disclosure of collected information

Except for the following cases, the Company will not disclose personal information to a 3rd party:

when the Company discloses 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, dispute resolution (including disputes on payment, etc) 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
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 following the procedure and method as prescribed in the laws and regulations

4. Cookie, 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 the operation of the websites of the Company and will be stored on hard disks of the users’ computer. A web beacon is a small quantity of code that exists on websites and e-mails. By using web beacons, we may know whether a user has interacted with certain webs or the contents of the 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

Category	Reasons for using cookies and additional information
Strictly Necessary Cookies	This cookie is a kind of indispensable cookie for the users to use the functions of service of the Company. This cookie does not collect any information which may be used for marketing or memorizing the sites visited by the users Purpose of identifying users who see Dable recommendation Check whether login is made on the dashboard
Performance Cookies	This cookie collects information on how the users use the website such as the information on the pages which are visited by the users most. This data helps the Company to optimize its service so that the users can find interesting information on the website more comfortably. This cookie does not collect any information about who are the users. Any and all the information collected by this cookie will be processed collectively and anonymity will be guaranteed. Web analysis: provide statistical data on the ways of using the website Advertisement response: check the effect of the advertisement of the Company Management of error: measure an error that may occur to give help for improving the website Design testing: test other designs of the website of partners
Functionality Cookies	This cookie is used for memorizing the set-ups so that the Company provides services and improves the visit of users. Any information collected by this cookie does not identify the users individually. Memorize set-ups applied such as layout, text size, basic set-up, and colors Memorize when the customer responds to a survey conducted by the Company

The users have an option for cookie installation. So, they may either allow all cookies by setting an option in the web browser, make each cookie checked whenever it is saved, or refuses all cookies to be saved: Provided that, if the user rejects the installation of cookies, it may be difficult for that user to use the parts of services provided by the Company.

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 deletions;
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 a user, use the menu of ‘amendment of member information of web page or contact the Company by sending a document or e-mails, or using the telephone to the company(or person in charge of the 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.

6. Security

Items	Examples
Technical measures	Utilize security servers for transmitting encryption of personal information Take measures of encryption for confidential information Install and operate access control devices and types of equipment Establish and execute an internal management plan
Managerial measures	Appoint a staff responsible for protecting personal information Provide education and training for staff treating personal information Establish and execute an internal management plan Establish rules for writing passwords which are hard to be estimated Ensure safe storage of records of access to the personal information processing system Classify the level of authority to access to the personal information processing system
Physical measures	Establish and operate the procedure for access control for the facilities for storing personal information Store documents and backing storage containing personal information in safe places which have a locking device Control data in a cloud virtualization environment and avoid physical archiving

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 the relevant jurisdiction. The website, products and services of the Company are the ones to be provided to ordinary people, in principle. There are age restrictions for joining a company’s services. Children cannot use it and the Company does not intentionally collect any personal information from children.

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.

9. Procedure and method of destruction of personal information

In principle, the Company destructs the information immediately after the purposes of its collection and use have been achieved without delay: Provided that, if any information is to be retained as required by relevant laws and regulations, the Company retains it for the period as required by those laws and regulations before destruction and, in such event, the personal information which is stored and managed separately will never be used for other purposes. Such storage and management of the retained information may vary depending on the governing law and jurisdiction where the service is provided.

The Company destructs: hard copies of personal information by shredding with a pulverizer or incinerating it and deletes personal information stored in the form of electric files by using technological methods making that information not restored.

10. Contact information of Company

Please use one of the following methods to contact the Company should you have any queries with respect to this policy or wish to update your information:

Company name: Viraads Ltd., co
E-mail: [email protected]