This Policy (the "Policy") explains the way of treatment of the information which is provided or collected in the web sites 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 applications of the Company which exist in the websites or platforms of other company. 

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

Through this Policy, the Company regards personal information of the users as important and inform them of the purpose and method of Company's using the personal information provided by the users and the measures taken by the Company for protection of those personal information._cc781905-5cde- 3194-bb3b-136bad5cf58d_

In case of modification thereof, the Company will make public notice of it through posting it on the bulletin board of Company's website or individual notice through sending mails 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.

   - Items to be collected

   ∘ Name, email address, telephone number, national information, company, encoded identification information (CI), identification information of overlapped membership (DI)

• Information collected while the users use services

Besides of information directly provided by the users, the Company may collect information in the course that the users use the service provided by the Company.

equipment information

∘ Equipment identifier, operation system, hardware version, equipment set-up, type and set-up of browser, use information of website or application and telephone number

Log information

∘ IP address, log data, use time, search word input by users, internet protocol address, cookie and web beacon

other information

∘ visited pages regarding service use of users

(2) Method of collection

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

webpage, written form, e-mailing, tools for collection of created information

Lawful processing of personal information under GDPR

Processing personal information by the Company shall be lawful only if and to the extent that at least one of the following applies:

• A user has given consent to the processing of his or her personal information.

• Processing is necessary for the performance of a contract to which a user is party or in order to take steps at the request of a user prior to entering into a contract:

  - Member management, identification, etc.

• Processing is necessary for compliance with a legal obligation to which the Company is subject

  - Compliance with relevant law, regulations, legal proceedings, requests by the government

• Processing is necessary in order to protect the vital interests of users, or other natural persons

  - Detection of, prevention of, and response to fraud, abuse, security risks, and technical issues that may harm users or other natural persons

• Processing is necessary for the performance of a task carried out in the public interest or in the excise of official authority vested in the Company

• Processing is necessary for the purposes of the legitimate interests pursued by the Company or by a third party (except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child).

2. Use of collected 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

• Improvement of existing services and development of new services

• Making notice of function of company sites or applications or matters on policy change

• To make statistics on member's service usage, to provide services and place advertisements based on statistical characteristics

• To comply with applicable laws or legal obligation

• Use of information with prior consent of the users

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

 User's right when applying GDPR

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:

• The right to access to personal information;

- The users or their legal representatives may access the information and check the records of the collection, use and sharing of the information under the applicable law.

• The right to rectification;

- The users or their legal representatives may request to correct inaccurate or incomplete information.

• The right to erasure;

- The users or their legal representatives may request the deletion of the information after the achievement of their purpose and the withdrawal of their consent.

• The right to restriction of processing;

- The users or their legal representatives may make temporary suspension of treatment of personal information in case of the disputes over the accuracy of information and the legality of information treatment, or if necessary to retain the information.

• The right to data portability

- The users or their legal representatives may request to provide or transfer the information.

• The right to object

- The users or their legal representatives may suspend the treatment of personal information if the information is used for the purpose of direct marketing, reasonable interests, the exercise of official duties and authority, and research and statistics.

• The right to automated individual decision-making, including profiling

- The users or their legal representatives may request to cease the automated treatment of personal information, including profiling, which has critical impact or cause legal effect on them.

If, in order to exercise the above rights, you, as an user, use the menu of 'amendment of member information of webpage or contact the Company by  sending a document or e-mails, or using telephone to the Company  ( person in charge of 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. 

3. Disclosure of collected information

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

• when the Company disclosing the information with its affiliates, partners and service providers;

- When the Company's affiliates, partners and service providers carry out services 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 in accordance with the procedure and method as prescribed in the laws and regulations

4. Cookies, 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 operation of the websites of the Company and will be stored in hard-disks of the users' computer.

Web beacon is a small quantity of code which exists on the websites and e-mails. By using web beacons, we may know whether an user has interacted with certain webs or the contents of 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:

​

Strictly necessary cookies

This cookie is a kind of indispensable cookie for the users to use the functions of website of the Company. This cookie does not collect any information which may be used for marketing or memorizing the sites visited by the users 

∘ Check whether login is made on website

∘ Check whether the users are connected with correct services of the website of the Company while the Company changes the way of operating its website

∘ Connect the users with certain application or server of the services

Performance cookies

This cookie collects information how the users use the website of the Company such as the information of the pages which are visited by the users most. This data helps the Company to optimize its website so that the users can search that website more comfortably. This cookie does not collect any information who are the users. Any and all the information collected by this cookie will be processed collectively and the anonymity will be guaranteed.

∘ Web analysis: provide statistical data on the ways of using website 

∘ Advertisement response fee: check the effect of advertisement of the Company

∘ Management of error: measure an error which may occur so as to give a help for improving website 

Functionality cookies

This cookie is used for memorizing the set-ups so that the Company provides services and improves visit of users. Any information collected by this cookie do not identify the users individually. 

∘ Memorize set-ups applied such as layout, text size, basic set-up and colors 

∘ Memorize when the customer respond to a survey conducted by the Company

The users have an option for cookie installation. So, they may either allow all cookies by setting option in 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 an user, use the menu of 'amendment of member information of webpage (MY PAGE)' or contact the Company by sending a document or e-mails, or using telephone to the company(or person in charge of 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

The Company regard the security of personal information of uses as very important. The company constructs the following security measures to protect the users' personal information from any unauthorized access, release, use or modification

• Encryption of personal information

- Transmit users' personal information by using encrypted communication zone

- Store important information such as passwords after encrypting it

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 relevant jurisdiction. The website, products and services of the Company are the ones to be provided to ordinary people, in principle.

Users and legal representatives can view, modify or ask for a deletion of their own or the child's information when the information about the child under 14 is registered

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 or e-mail) and obtain consent from the users if required by relevant laws. 

9. Data transfer to other countries

Considering it engages in global businesses, the Company may provide the users' personal information to the companies located in other countries for the purpose as expressly stated in this Policy. For the places where the personal information is transmitted, retained or processed, the Company takes reasonable measures for protecting those personal information. 

(If used in the US, additional security measures may be available) In addition, when the personal information obtained from the European Union or Switzerland is used or disclosed, the Company may have to comply with the US-EU Privacy Shield and Swiss-US Privacy Shield, take other measures or obtain consent from users so far as those complies with the regulations of EU so as to use a standardized agreement provision approved by executing organizations of EU or securing proper safe measures. 

10. 3rd party's sites and services

The website, product or service of the Company may include the links to the ones of a 3rd party and the privacy protection policy of the site of 3rd party may be different. Thus, it is required for the users to check additionally that policy of a 3rd party site linked to the site of the Company. 

11. Contact information of Company

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

- Company name : Neurocle Inc.

- Address : #301, 32, Maeheon-ro 16-gil, Seocho-gu, Seoul, 06770, Korea

- Tel.: 82-2-6952-6898

- E-mail:  neurocle@neuro-cle.com

Reference: Naver Corp.