SINA BT CO., LTD. (hereinafter referred to as the “Company”) has established the following privacy policy in accordance with the Personal Information Protection Act to protect users’ personal information and rights and to handle grievances related to personal information smoothly. Your information is both a valuable personal asset and important data for the Company’s operations. Accordingly, the Company promises to make every effort to protect your personal information throughout all operational processes. The Company will announce any revision to this Privacy Policy through its website.

Chapter 1. Procedure for Consent to Personal Information Collection

The Company provides a procedure through which you may click either the “Agree” or “Disagree” button regarding the Privacy Policy or Terms of Use on the website. Clicking “Agree” is deemed consent to the collection of personal information.

Chapter 2. Purpose of Collection and Use of Personal Information

The Company uses personal information for the following purposes. Personal information processed will not be used for purposes other than those stated below, and prior consent will be obtained if the purpose of use changes.

• A. Name, ID, password: confirmation of membership application intent, prevention of improper service use, analysis of access frequency, and identity verification for membership services.
• B. Email address, telephone number (confirmation of receipt): delivery of notices, confirmation of intent, establishment of communication channels for complaint handling, provision of event and advertising information and participation opportunities, analysis of access frequency, and statistics on members’ use of services.
• C. Address, telephone number: securing accurate delivery information for prizes and goods.

Chapter 3. Transmission of Advertising Information

• A. The Company does not transmit commercial advertising information against your express refusal to receive it.
• B. The Company may notify you of changes to the Terms of Use, other changes concerning service use, new services/products or event information, and other product information through email, mobile text messages, or other electronic transmission media. In such cases, the Company complies with applicable laws regarding required disclosures and methods of disclosure.
• C. When transmitting advertising information by email or other means for online marketing, including product information, the Company takes measures to ensure that you can easily identify such information in the email subject line and body.

Chapter 4. Scope of Personal Information Collection

Most content may be accessed freely without a separate membership registration procedure. To use membership services, you must provide the following information.

• A. Items collected: name, email, date of birth, ID, password, gender, address, mobile phone number (telephone), email receipt preference, SMS receipt preference, service-use history, access logs, and recipient information (name, telephone number, address, email).
• B. Collection method: membership registration and bulletin boards on the website, etc.

Chapter 5. Retention and Use Period of Personal Information

The Company destroys the relevant information without delay once the purpose of collection and use has been achieved. However, the following information is retained for the period stated below for the reasons indicated.

• - Items retained: name, login ID, password, email, date of birth
• - Reason: prevention of repeated improper use by delinquent members
• - Retention period: 1 month

Where retention is required under applicable laws, the Company retains member information for the period prescribed by the relevant laws, as follows.

• - Records concerning consumer complaints or dispute resolution: 3 years (Act on the Consumer Protection in Electronic Commerce, etc.)

Chapter 6. Procedures and Methods for Destruction of Personal Information

In principle, the Company destroys personal information without delay when the purpose of processing has been achieved. The procedures, time limits, and methods for destruction are as follows.

- Destruction procedure
Information entered for membership registration, etc. is transferred to a separate database (or, in the case of paper records, a separate filing cabinet) after the purpose has been achieved, retained for a certain period in accordance with internal policies and applicable laws, and then destroyed. Personal information transferred to a separate database is not used for any purpose other than retention unless required by law.

- Destruction deadline
Where the retention period has expired, personal information is destroyed within five days from the end date of that period. Where personal information becomes unnecessary due to achievement of the processing purpose, discontinuation of the service, or termination of the business, it is destroyed within five days from the date it is deemed unnecessary.

- Destruction method
Electronic files are destroyed using technical methods that make the records irrecoverable.

Chapter 7. Measures to Ensure the Security of Personal Information

In accordance with Article 29 of the Personal Information Protection Act, the Company takes the following measures necessary to ensure security.

• A. Minimization and training of personnel handling personal information
  The Company designates personnel who handle personal information, limits them to those in charge, and implements measures to minimize the number of such personnel.
• B. Encryption of personal information
  Users’ passwords are encrypted for storage and management and are known only to the users themselves. The Company also uses additional security measures, such as encryption of important files and transmitted data or file-locking functions.

Chapter 8. Personal Information Protection Officer

The Company makes every effort to ensure that customers may use information safely. The person responsible for handling customers’ personal information responds promptly and sincerely to privacy-related inquiries.

Data subjects may contact the Personal Information Protection Officer or the responsible staff regarding all privacy-related inquiries, complaint handling, or damage relief arising from the use of the Company’s services.

Chapter 9. Collection of Opinions and Complaint Handling

The Company values members’ opinions, and members have the right to receive sincere answers to their questions at all times. The Company operates a customer service center for smooth communication with members.

Live chat and telephone consultations are available only during business hours. Inquiries by email or post will be answered sincerely within 24 hours of receipt. However, inquiries received after business hours, on weekends, or on public holidays will generally be processed on the next business day.

The Company takes the following measures for misappropriated personal information.

• 1. Upon becoming aware that a user has registered as a member by misappropriating another person’s personal information, the Company promptly takes necessary measures, including suspension of service use for the relevant ID or membership withdrawal.
• 2. Where a user who recognizes that his or her personal information has been misappropriated requests suspension of service use or membership withdrawal for the relevant ID, the Company takes immediate action.

For further consultation on personal information matters, you may contact the Personal Information Infringement Report Center, the Supreme Prosecutors’ Office Internet Crime Investigation Center, or the National Police Agency Cyber Terror Response Center.

• - Personal Information Infringement Center (http://www.118.or.kr)
• - Supreme Prosecutors’ Office Internet Crime Investigation Center (http://icic.sppo.go.kr)
• - National Police Agency Cyber Terror Response Center (http://www.police.go.kr/ctrc/ctrc_main.htm)

Chapter 10. Duty to Notify

This Privacy Policy takes effect from its effective date. Where additions, deletions, or corrections are made in accordance with laws or policies, the Company will provide notice through its announcements at least seven days before the changes take effect.