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“Avonne Co., Ltd.” (hereinafter referred to as “the Company”) implements the handling policies described below to protect the user's personal information and rights according to the privacy protection right and resolve the user's difficulties in relation to personal information. The customer information is your valuable asset as well as important data for the Company’s operation. Thus, the Company is committed to making all efforts to protect your personal information throughout its business operation. The Company will announce any revision of the Personal Information Handling Policy through the website.

Section 1. Consent procedure in collecting personal information
The Company provides a procedure for clicking the (I agree) button or (I do not agree) button with regard to the Personal Information Protection Policy or Terms and Conditions in its website. Personal information collection is deemed to be agreed to by the customer upon clicking the (I agree) button.

Section 2. Collection of personal information and purpose of use
The company utilizes the collected personal information for the following objectives (the processed personal information is not used for purposes other than the following, and prior consent will be required if the purposes of use are modified):

A. Name, ID, and password: Verification of user's intention regarding registration, prevention of unauthorized service use, identification of connection frequency, and customer's identification procedure according to the membership service use.
B. Email address and phone number (verification of reception): Ensuring and facilitating the communication route including delivery of notification, verification of customer's intention, and complaint processing.
Providing event and advertising information and participation opportunities, statistics on connection frequency identification or member's service use.
C. Mailing address and phone number: Ensuring the correct delivery place of the prize and product delivery.

Section 3. Transmission of advertising information
A. The Company will refrain from sending profit-oriented advertising information in accordance with the customer's explicit opt-out intention.
B. The Company will announce the modifications of the terms and conditions and other service-related modifications, new services or products including event information, and other product information through email, SMS, and other electronic transfer media. Likewise, the Company will comply with all the applicable legal requirements and methods.
C. When sending advertising information via email for the online marketing of the product, the Company will ensure that all users will see the title and contents in the email clearly.

Section 4. Scope of personal information collection
Most contents of the Company can be freely accessed without additional sign-up process. If the membership service needs to be accessed, however, the following information should be entered:
A. Personal information collection items: name, email, date of birth (DOB), ID, password, gender, address, mobile phone number (telephone), whether to receive email,
whether to receive SMS, service use record, connection log, recipient customer information (name, telephone number, address, email address)
B. How to collect personal information: User sign-up and notice board 

Section 5. Retention and use period of personal information
The company shall destroy information without delay once the purposes of personal information collection and use are achieved.
Note that the following information will be retained for the specified period for the following reasons: 

- Items to be retained: Name, login ID, password, email address, and DOB
- Grounds for retention: Prevention of recurrence of fraudulent use by malicious users
- Period of retention: One month

If the information needs to be retained in accordance with the applicable laws, the Company will store user information for a certain period of time set forth by the applicable law. 
Record of consumers' complaints or dispute handling: three years (Act on Consumer Protection in Electronic Commerce)

Section 6. Process and method of destroying personal information
In principle, when the purpose of personal information handling is achieved, the Company will destroy the related personal information without delay. The destruction procedure, deadline, and method are as follows: 

- Destruction procedure
The information entered for user subscription is transferred to a separate database (DB) after accomplishing the purpose of information (in the case of information written in paper sheets, it is stored in a separate filing cabinet) and stored for a specified period of time depending on the reason for information protection in accordance with the applicable law and internal policies prior to destroying it. The personal information transferred to a separate DB is not used for purposes other than retention unless specified otherwise by the law.

- Deadline for destruction
The user’s personal information is destroyed within five days of the end of the retention period when the retention period has lapsed, or within five days of the date when the processing of personal information is considered unnecessary in case the personal information is no longer needed, such as accomplishment of purpose of personal information handling, required service's abolition, or business termination.

- Destruction method
For electronic file format information, technical methods that make reproducing the record impossible are employed.

Section 7. Measures to ensure the safety of personal information
The Company will take all the necessary measures to ensure the safety of personal information as follows in accordance with Article 29 of the Personal Information Protection Act:

A. Minimization of the number of personal information handling staff and education
The staff responsible for personal information handling are designated, and the Company takes measures to manage personal information by minimizing the number of such staff.

B. Encryption of personal information
The Company employs additional security functions such as encryption of file and sending of data for important data that can be identified by the user only or use of file lock function as passwords in users' personal information are stored and managed after being encrypted.

Section 8. Designation of personal information protection staff
The Company is committed to ensuring that customers use their information securely. The following is the staff who handles customer personal information, and he will respond to any inquiry quickly and faithfully in relation to personal information:

▶ Personal information protection staff
Name: Park Seong-min
Affiliation/Position: Management Support Team/ General Manager
e-mail: smpark@avonne.co.kr
Telephone: 042-286-8602
The owner of the information may contact the personal information protection officer/staff regarding all personal information protection-related inquiries, complaint handling, and compensation for any damage occurring in the course of using our services.

Section 9. Gathering of feedback and complaint handling
The Company values the members' opinions, and the members have a right to receive sincere responses for all inquiries at all times. The Company operates the customer center for smooth communication with the members. 

Real-time and telephone consultations are only available during business hours. Inquiries via email and mail will be answered sincerely within 24 hours of receiving them. Note that inquiries received after working hours or during weekends and public holidays will be processed the next business day, in principle.
The Company will take measures against the theft of personal information as follows:
1. Once it becomes aware of member registration done by stealing another's personal information, the Company will take the necessary actions such as suspension of service use for the ID or membership cancellation. 
2. If a user becomes aware of the theft of his/her personal information and asks the suspension of service use or membership cancellation for the ID, the Company will take immediate action. 
For inquiries related to other personal information, you can contact the Personal Information Infringement Reporting Center, Supreme Prosecutor's Office Internet Crime Investigation Center, or National Police Agency Cyber Terror Response Center.

Personal Information Infringement Reporting Center (https://privacy.kisa.or.kr)
Supreme Prosecutor's Office Internet Crime Investigation Center (http://www.spo.go.kr/spo/major/disclosure2/disclosure01.jsp)
National Police Agency Cyber Terror Response Center (http://cyberbureau.police.go.kr/index.do)

Section 10. Duty of notification
This Personal Information Handling Policy shall be effective on the implementation date and, if amended, removed, or corrected in line with the relevant laws and regulations and guideline, shall be published via a notice served seven (7) days prior to the amendment implementation.
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