KyungDong Navien Co., Ltd. (hereinafter called ‘KD Navien’) would like to set and disclose the following privacy policies for the protection of personal information of its users and quick handling of relevant issues.

1. Clause 1 Objective of Collecting Personal Information

   KD Navien shall use information of is users for the following purposes only.

   1. Responding to the inquiry of the user and provision of service.
   2. Development of new service, responding to inquiry of the user, and improvement of service.
2. Clause 2 Items for Collection of Personal Information

   1. Items for Collection for Receiving Service
      1. Compulsory : name, location, address, city, post code, country, e-mail address and inquiry
      2. Optional : contact information (phone number, fax number, business area and inquiry)
   2. The company shall be able to collect additional personal information for other marketing-related activities. In this case, however, the company shall separately notify the purpose, item, and retention period, only when the user has given his/her consent.
3. Clause 3 Period of Retention and Usage of Personal Information

   KD Navien shall be allowed to possess and use information collected according to Clause 2 for 3 years after the collection.

4. Clause 4 Provision of Personal Information to Third Party

   1. KD Navien shall not provide the personal information of its users to a third party, as a rule.
   2. Despite article 1, Navien shall be able to provide the personal information of its users to a third party if the user agrees and if it is in accordance with the relevant regulations.
5. Clause 5 Rights, obligations, and exercise of the user

   1. The user shall be able to exercise rights for personal information for the followings anytime.
      1. Request for reading his/her personal information
      2. Request for modification of error in personal information
      3. Request for deletion of personal information
      4. Request for personal information processing down
   2. To exercise the rights defined in article 1, the company shall take relevant action once the user makes contact to the management/protection administrator or manager through e-mail and other relevant methods.
   3. The user shall be able to exercise the rights of article 1 through proxies which include legal agents and representatives. A ‘Power of Attorney’ shall be submitted in this case.
   4. The user shall be able to reject agreement with privacy policies of KD Navien. If so, however, the service of KD Navien shall be provided limitedly.
6. Clause 6 Procedure of Termination of Personal Information

   1. Termination Procedure
      • The information by which the user entered is transferred to a separate database (or, separate document in paper) and shall be terminated after a certain period of storage. For this, the personal information in database shall not be used for other purposes apart from regulation.
   2. Deadline of Termination
      • The personal information of users shall be terminated within 5 days of retention period in case of conclusion of retention period for personal information. In addition, if the personal information is not needed due to closure of the service or business, such information shall be terminated within 5 days from acknowledgement on the fact that the information is not needed anymore.
   3. Method of Termination
      • The personal information printed on paper shall be terminated through paper shredder or incineration, and information in the form of electric file shall be terminated through a technical method which can prevent regeneration of the information.
7. Clause 7 Installation/ Operation of Auto-Collection of Personal Information and Its Rejection

   1. Cookie
      • Cookie refers to the small text file sent to browser of the user by server for operation of the website that it is store in hard disk of user’s computer. Cookie shall not collect information for identification automatically/voluntarily and the user shall be able to reject storage of cookie and delete anytime.
   2. Purpose of Use of Cookie
      • The purpose of using cookie is for analysis on the user’s log-in frequency, visiting time, interest, taste and movement tracing, event participation frequency, and the number of visit for target marketing and to provide customized service.
8. Clause 8 Measurement for Securing Stability of Personal Information

   KD Navien shall take the following technical/administrative and physical actions for securing stability of personal information for prevention of loss, stealing, leakage, falsification of personal information of the user.

   • Minimization of the number of staff for handling personal information and education.
     The company minimizes the number of staff handling personal information and limits the right for administrator only to manage personal information.
   • Establishment and practice of internal administration plan
     KD Navien has established and is practicing internal administration for handling personal information safely.
   • Encryption of personal information
     The password of personal information of the user shall be stored and managed through encryption; therefore the user knows it only. Further, important data shall be stored through a separate security function through encryption or file lock function.
   • Technical measurement for hacking
     We have installed a security program to prevent leakage and damage on personal information caused by hacking and computer virus. Further, the company shall renew/ inspect the program and installed security system for technical/physical monitoring and prevention in restricted area.
   • Technical measurement for hacking
     We have installed a security program to prevent leakage and damage on personal information caused by hacking and computer virus. Further, the company shall renew/ inspect the program and installed security system for technical/physical monitoring and prevention in restricted area.
   • Storage of access data, prevention of forgery and alteration
     Data of access to personal information processing system shall be stored for 6 months at the least. Further, the company uses security function to prevent forgery, alteration, stealing, and loss of the data.
   • Use of latching device for document security
     Document and auxiliary storage media for personal information shall be stored in a safe place with latching device.
   • Restriction of access for unauthorized persons
     The company has set up a physical place for storage of personal information and set up, and is operating access control procedure.
9. Clause 9 Administrator of Management/ Protection of Personal Information

   • KD Navien designates the following managers and administrators for management and protection of personal information to control the entire processes related to personal information, control user complaints, and recover from errors related to personal information process.

     Management/ Protection Administrator for Personal Information

     • Head of Management Information Team
     • E-mail : jw-kim@kdiwin.com
   • The user shall be able to make inquiry for all matters related to personal information protection, complain handling, and damage recovery using the service of KD Navien to management/protection administrator and manager. KD Navien shall respond and handle the problem promptly.
10. Clause 10 Modification of Privacy Policy

    This privacy policy shall take effect from the date of implementation. If there is any modification, deletion and changes in regulation and policy, it shall be notified on the website as of 7 days before the date of implementation in advance.
    Date of Notification: 30/ 04/ 2014
    Date of Implementation: 30/ 04/ 2014

11. Clause 11 Date of Implementation: 30/ 04/ 2014

    1. This Terms & Conditions shall be interpreted and governed by the law of Korea
    2. Seoul Central District Court shall sue the suit for conflicts between the company and user.