PANA KOREA CO., LTD

This Privacy Policy (the "Policy") explains the way of treatment of the information which is provided or collected in the websites on which this Policy is posted.

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.

This Policy will be effective on the 22th day of march, 2016 and, 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, fax 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, telephone number)
• • 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.
  (Items to be collected: Log data, use time, search word input by users, internet protocol address, cookie)

(2) Method of collection

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

• • webpage, telephone calling, e-mailing, tools for collection of created information

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
• • Improvement of existing services and development of new services
• • Making notice of function of company sites or matters on policy change
• • Use of information with prior consent of the users
• • To make statistics on member’s service usage, to provide services and place advertisements based on statistical characteristics
• • To provide information on promotional events as well as opportunity to participate

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

3. Sharing collected information

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

• • when the Company shares the information with its affiliates, partners and service providers;
  - When the Company's affiliates, partners and service providers carry out services such as products delivery and dispute resolution for and on behalf of the Company
• • when the users consent the sharing 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
  - when the user selects to allow his or her personal information to be shared with the sites or -platform of other companies such as social networking sites
  - other cases where the user gives prior consent for sharing his or her personal information
• • when the sharing 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 and Similar Technologies

The Company may collect collective and impersonal information through 'cookies'

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

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:

(1) 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 of 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
• • Design testing: test other design of the website of Company

(2) 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 does 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. Users' right to access and option

The users or their legal representatives, as main agents of the information, may exercise the following options regarding the collection, use and sharing of personal information by the Company:

• • exercise right to access to personal information;
• • make corrections or deletion;
• • make temporary suspension of treatment of personal information; or
• • request the withdrawal of their consent provided before

If, in order to exercise the above options, you, as an user, use the menu of 'amendment of member information of webpage or contact the Company by using representative telephone or sending a document or e-mails, or using telephone to the responsible department (or person in charge of management of personal information), 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 regards 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
• • Countermeasures against hacking
  - Install a system in the zone the external access to which is controlled so as to prevent leakage or damage of users' personal information by hacking or computer virus
• • Establish and execute internal management plan
• • Install and operate access control system
• • Take measures to prevent forging or alteration of access record

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.

(Additional procedure for collecting personal information from children) However, if the Company collects any personal information from children under 13 or equivalent minimum age as prescribed in the laws in relevant jurisdiction for the services for unavoidable reason, the Company will go through the additional procedure of the followings for protecting that personal information of children:

• • obtain consent from the parents or guardian of children so as to collect personal information of children or directly send the information of products and services of the Company
• • give the parents or guardian of children a notice of Company's policy of privacy protection for children including the items, purpose and sharing of personal information collected
• • grant to legal representatives of children a right to access to personal information of that children/correction or deletion of personal information/temporary suspension of treatment of personal information/ and request for withdrawal of their consent provided before
• • limit the amount of personal information exceeding those necessary for participation in online activities

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

9. Responsible department of Company

The Company designates the following department and person in charge of personal information in order to protect personal information of customers and deal with complaints from customers:

• Department responsible for privacy protection and customer service : Kim Hae Na
• Address : 5F, 10, Bukbusunhwando-ro, Nam-gu, Ulsan, Korea
• Tel.: 052-910-6601
• E-mail: hnkim@panakorea.co.kr

The latest update date: 14thday of march, 2015