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bitsensing (hereinafter referred to as 'the company') establishes and publicly discloses the following personal information processing policy to protect the personal information of data subjects in accordance with Article 30 of the Personal Information Protection Act, and to promptly and smoothly handle related grievances.

Article 1(Purpose of Personal Information Processing)
The company processes personal information for the following purposes. The personal information being processed will not be used for purposes other than those specified, and if the purpose of use changes, necessary measures, such as obtaining separate consent in accordance with Article 18 of the Personal Information Protection Act, will be implemented.

1. Website Membership Registration and Management
We process personal information for the purposes of confirming intent to register for membership, identifying and authenticating individuals for membership-based services, maintaining and managing membership, verifying identity under the limited identity verification system, preventing fraudulent use of services, confirming parental/guardian consent when processing personal information of children under 14, and for various notices, notifications, and grievance handling.

2. Provision of goods or services
We process personal information for purposes such as product delivery, service provision, sending contracts and invoices, providing content, offering customized services, identity verification, age verification, payment processing and settlement, and debt collection.

3. Handling Complaints
We process personal information for purposes such as verifying the identity of the complainant, confirming the complaint, contacting and notifying for fact-finding, and informing of processing results.

Article 2 (Personal Information Processing and Retention Period)
① The company processes and retains personal information within the period of retention and use of personal information in accordance with laws, or within the period of retention and use of personal information consented to by the data subject at the time of collection.
② The processing and retention periods for each type of personal information are as follows:

1. Website Membership Registration and Management: Until withdrawal from the business/organization's website
However, in cases corresponding to the following reasons, it will be until the termination of that reason:
1) In cases where investigations or inquiries related to violations of relevant laws are ongoing, until the completion of such investigations or inquiries.
2) In cases where claims and debts remain due to website use, it will be until the settlement of such claims and debts.

2. Provision of goods or services: Until the completion of goods/services supply and payment/settlement.
However, in cases corresponding to the following reasons, it will be until the termination of that reason:
1) Records concerning display and advertising, contract details, and performance of transactions in accordance with the "Act on the Consumer Protection in Electronic Commerce, etc."
- Records concerning display and advertising: 6 months
- Records of contracts or subscription withdrawals, payment settlements, and supply of goods: 5 years
- Records concerning consumer complaints or dispute resolution: 3 years
2) Retention of communication fact verification data in accordance with Article 41 of the Telecommunications Secret Protection Act
- Subscriber's telecommunication date and time, start and end time, counterparty subscriber number, usage quantity, and originating base station location tracking data: 1 year
- Computer communication, internet log records, and access point tracking data: 3 months

Article 3(Provision of Personal Information to Third Parties)
① The company processes the personal information of data subjects only within the scope specified in Article 1 (Purpose of Personal Information Processing) and provides personal information to third parties only in cases falling under Articles 17 and 18 of the Personal Information Protection Act, such as with the data subject's consent or special provisions in the law. Otherwise, the company does not provide the personal information of data subjects to third parties.
② The company may provide personal information to third parties only to the minimum necessary extent, with the data subject's consent, in accordance with Article 17, Paragraph 1, Item 1 of the Personal Information Protection Act, for the smooth provision of services in the following cases.
- Recipient of personal information: (e.g., OOO Card Co., Ltd.)
- Purpose of the recipient's use of personal information: (e.g., Business partnership such as co-hosting events and issuing affiliated credit cards)
- Provided personal information items: (e.g., Name, address, phone number, email address, card payment account information)
- Recipient's retention and usage period: (e.g., During the transaction period according to the credit card issuance agreement)

Article 4(Outsourcing of Personal Information Processing)
① The company entrusts personal information processing tasks as follows to ensure smooth personal information handling:
- Content of entrusted tasks
- Recipient (Trustee): I'mweb Co., Ltd.
- Content of entrusted tasks: Provision of system for shopping mall hosting services, mobile app services, marketing services and additional/affiliate services, as well as proxy services for sending AlimTalk, FriendTalk, and text messages.
- Recipient (Trustee): PG company SPG
- Content of entrusted tasks: Payment and escrow services
- Recipient (Trustee): CJ Logistics Courier Service
- Content of entrusted tasks: Product delivery services
- Recipient (Trustee): bitsensing Customer Service Center
- Content of entrusted tasks: Customer consultation services
- Recipient (Trustee): OOO
- Content of entrusted tasks: Identity verification services
**Subcontractor**
- **Subcontractor (Trustee): I'mweb Co., Ltd. -> Infobip (Ltd.)**
-**Content of entrusted tasks: Sending text messages, sending KakaoTalk NoticeTalk (informational messages)**
-**Subcontractor (Trustee): I'mweb Co., Ltd. -> LunaSoft Co., Ltd.**
-**Content of entrusted tasks: Sending text messages, sending KakaoTalk NoticeTalk (informational messages) and FriendTalk messages**
② When concluding a consignment agreement, the company, in accordance with Article 25 of the Personal Information Protection Act, prohibits the processing of personal information beyond the purpose of the entrusted task, implements technical and administrative protective measures, restricts re-consignment, and supervises whether the consignee handles personal information safely.
③ If the content of the entrusted tasks or the recipient changes, we will promptly disclose it through this Privacy Policy.

Article 5 (Rights of Data Subjects and Legal Representatives and How to Exercise Them)

① Data subjects can exercise the following rights related to personal information protection against the company at any time:
1. Request for access to personal information
2. Request for correction if there are errors, etc.
3. Request for deletion
4. Request for suspension of processing
② You can exercise your rights under Paragraph 1 by contacting the company in writing, by phone, email, or fax. The company will take action without delay.
③ When a data subject requests the correction or deletion of personal information due to errors, etc., the company will not use or provide the personal information until the correction or deletion is completed.
④ You can exercise the rights under Paragraph 1 through an agent, such as a legal representative of the data subject or a person who has been delegated. In this case, you must submit a power of attorney in the form of Annex 11 of the Enforcement Rule of the Personal Information Protection Act.
⑤ Data subjects must not infringe upon their own or others' personal information and privacy being processed by the company, in violation of the Personal Information Protection Act and other relevant laws and regulations.

Article 6(Items of Personal Information Processed)
The company processes the following personal information items.

1. Website Membership Registration and Management
Required items: (e.g., Name, ID, Password, Address, Phone number, Gender, Email address, i-PIN number)
Optional items: (e.g., Marital status, Areas of interest)

2. Provision of goods or services
Required items: (e.g., Name, Date of Birth, ID, Password, Address, Phone number, Email address, i-PIN number, Credit card number, Bank account information, and other payment details)
Optional items: (Areas of interest, Past purchase history)

Article 7(Destruction of Personal Information)
① The company will promptly destroy personal information when it becomes unnecessary, such as when the personal information retention period expires or the purpose of processing has been achieved.
② Even if the personal information retention period consented to by the data subject has expired or the purpose of processing has been achieved, if the personal information must continue to be preserved according to other laws, it will be transferred to a separate database (DB) or stored in a different location.
③ The procedures and methods for personal information destruction are as follows:
1. Destruction Procedure
The company selects personal information for which a destruction reason has occurred and destroys it after obtaining approval from the company's Chief Privacy Officer.
2. Method of Destruction
The company destroys personal information recorded and stored in electronic file formats in a way that prevents the reproduction of records, and personal information recorded and stored on paper documents is destroyed by shredding or incineration.

Article 8 (Measures to Ensure the Security of Personal Information)
The company is taking the following measures to ensure the security of personal information:
1. Administrative measures: Establishment and implementation of internal management plans, regular employee training, etc.
2. Technical measures: Management of access rights to personal information processing systems, installation of access control systems, encryption of unique identification information, installation of security programs
3. Physical measures: Access control for computer rooms, data storage rooms, etc.

Article 9 (Matters Concerning the Installation and Operation of Automatic Personal Information Collection Devices and Refusal Thereof)
① The company uses 'cookies,' which store user information and retrieve it frequently, to provide individually customized services to users.
② A cookie is a small piece of information that a server (http) used to operate a website sends to a user's computer browser, and it is stored on the users' PC or mobile device.
③ Data subjects can set options to allow or block cookies through their web browser settings. However, if cookie storage is refused, difficulties may arise in using customized services.

▶ Allow/Block Cookies in Web Browser
- Chrome: Web browser settings > Privacy and security > Clear Browse data
- Edge: Web browser settings > Cookies and site permissions > Manage and delete cookies and site data

▶ Allow/Block Cookies in Mobile Browser
- Chrome: Mobile browser settings > Privacy and security > Clear Browse data
- Safari: Mobile device settings > Safari > Advanced > Block All Cookies
- Samsung Internet: Mobile browser settings > Browse history > Clear Browse data

④ The company collects and uses information about users' visits and usage patterns for each service and website visited, popular search terms, security connection status, etc., during the service usage process, in order to provide information optimized for the user.

Article 10(Chief Privacy Officer)
① The company is responsible for overseeing all personal information processing tasks and has designated a Chief Privacy Officer as follows to handle data subjects' complaints and provide redress for damages related to personal information processing.

▶ Chief Privacy Officer
Name: Sungjin Lee
Position: CEO (Chief Executive Officer)
Contact: +82 31 738 1474 (Phone) / wellnessinsight@bitsensing.com / +82 31 738 1483 (Fax)
* This connects you to the department in charge of personal information protection.

▶ Personal Information Protection Department
Department : Marketing Team
Contact: +82 31 738 1474 (Phone) / lena@bitsensing.com / +82 31 738 1483 (FAX)

② Data subjects can contact the Chief Privacy Officer and the relevant department with any inquiries, complaints, or requests for damage relief related to personal information protection that arise while using the company's services (or business). The company will respond to and address data subjects' inquiries without delay.

Article 11(Request for Access to Personal Information)
Data subjects can request access to their personal information in accordance with Article 35 of the Personal Information Protection Act from the department below. The company will strive to ensure that data subjects' requests for access to personal information are processed promptly.

▶ Department for Receiving and Processing Personal Information Access Requests
Department : Marketing Team
Contact: +82 31 738 1474 (Phone) / lena@bitsensing.com / +82 31 738 1483 (FAX)

Article 12(Remedies for Infringement of Rights and Interests)
Data subjects can contact the following organizations for remedies and consultations regarding personal information infringement:
1. Personal Information Dispute Mediation Committee: 1833-6972 (without area code) (www.kopico.go.kr)
2. Personal Information Infringement Report Center: 118 (without area code) (privacy.kisa.or.kr)
3. Supreme Prosecutors' Office: 1301 (without area code) (www.spo.go.kr)
4. National Police Agency: 182 (without area code) (ecrm.police.go.kr/minwon/main)

Article 13(Enforcement and Amendment of Privacy Policy)
This Privacy Policy takes effect on December 1, 2022.

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Company name: Bitsensing｜CEO: Lee Sungjin / Lee Jaeeun｜Address: A301, 3, Godeung-ro, Sujeong-gu, Seongnam-si, Gyeonggi-do, Republic of Korea｜Business Registration Information : 850-88-00679｜Tel. +82-31-738-1474｜ Fax : 031-738-1483 ｜ Mail order business report : 2022-Sungnam Soojung-0831

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