Personal Information Processing Policy

Company (hereinafter referred to as ‘the Company’) complies with the privacy protection regulations under relevant laws such as the Act on Promotion of Information and Communications Network Utilization and Information Protection, and the Personal Information Protection Act. In order to protect the rights and interests of users and to handle complaints promptly and smoothly, the Company has established the following privacy policy in accordance with relevant laws.

Article 1 Purpose of Personal Information

The Company processes personal information for the following purposes. The personal information is not used for purposes other than the following purposes. If the purpose of use is changed, we will request consent in accordance with Article 18 of the Personal Information Protection Act.

1. Project Euler @kr membership registration and management

We process your personal information for the purpose of identifying your membership, identifying your identity to provide membership service, maintaining and managing your membership status, various notices and handling complains.

2. Providing products and services

We process your personal information for the purpose of delivering products, providing services, contracts, billing, providing content, providing customized services, settlement, calculations, collection of debts.

3. Product and service inquiries

We process your personal information for the purpose of confirming the identity of the complainant, confirming the contents, contacting and notifying for the factual investigation, and notifying the result of processing.

4. Use in marketing and advertising

We process your personal information for the purpose of delivering advertising information such as services, products, seminars and events, providing services based on demographic characteristics, displaying ads and sending Email.

5. Use in the recruitment process

We process your personal information for the purpose of screening your entry, confirming your acceptance, communicating with applicants, and checking eligibility.

6. Employee’s personal information processing

The personal information included in the employment contract is collected and used for employee management such as payment of wages, education, issuance of certificates, welfare benefits of employee and so on.

Article 2 Processing and Retention Period of Personal Information

① The Company maintains personal information in accordance with laws and regulations, and hold personal information that is agreed upon when the personal information is collected from the information subject.
② Each personal information processing and retention period is as follows.

Category	Collected Items	Retention Period
Project Euler @kr membership registration and management	– Required: id, password, Email – Options: nickname, self- introduction – How to collect personal information: Registration on the website	year from the date of acceptance for collection and use
Providing products and services	– Required: name, phone, cell phone, company or organization name, rank, position – Options: past purchases – How to collect personal information: collected during sales activities	until the completion of products and services, settlement of accounts
Product and service inquiries	– Required: name, phone, e-mail, inquiry – Options: company or organization name, phone – How to collect personal information: website, phone	1year from the date of acceptance for collection and use
Use in marketing and advertising	– Required: name, phone, company or organization name, Email – Options: Position – How to collect personal information: website, online/offline events	1year from the date of acceptance of collection and use
Use in the recruitment process	– Required: name, date of birth, contact, Email – Optional: education, experience, photos, qualifications, etc. – How to collect personal information: application form submission via Email	1year from the filing date of the application
Employee’s personal information processing	– Required: name, resident registration number, address, contact, details of the calculation of the family allowance and other working conditions – Optional: education, experience, photos, qualifications, etc. – How to collect personal information: collected in writing by the employee during the recruitment process	3years from the date of retirement

③ In accordance with the relevant laws, including the Act on Consumer Protection in Electronic Commerce, we retain personal information for a specified period as follows, and we will never use this information for other purposes:

– Records related to advertising: Retained for 6 months
– Records related to contracts or withdrawal of offers: Retained for 5 years
– Records related to payment and supply of goods: Retained for 5 years
– Records related to consumer complaints or dispute resolution: Retained for 3 years

Article 3. Procedures and Methods for the Destruction of Personal Information

The company will promptly destroy personal information when it is no longer necessary, such as when the retention period has expired or the purpose of processing has been achieved. The procedures and methods for the destruction of personal information are as follows:

① Destruction Procedure

The company selects the personal information that needs to be destroyed based on the reason for destruction and obtains approval from the company’s personal information protection officer before proceeding with the destruction.

② Destruction Method

Personal information stored in electronic file format will be deleted using technical methods that render it irretrievable, while personal information recorded in paper documents will be destroyed either by shredding or incineration.

Article 4. Installation, Operation, and Refusal of Automatic Personal Information Collection Devices

The company uses “cookies” to store and retrieve user information in order to provide personalized services. A cookie is a small amount of information sent from the server (http) operating the website to the user’s computer browser, which may be stored on the user’s hard disk.

① Purpose of Cookie Use: Cookies are used to analyze the visit and usage patterns of each service and website visited by the user, including popular search terms and whether secure access was used, in order to provide optimized information to the user.

② Installation, Operation, and Refusal of Cookies: Users can refuse the storage of cookies through the settings in the Internet Options menu found in the Tools section at the top of the web browser.

③ Consequences of Refusing Cookie Storage: If cookies are refused, users may experience difficulties in accessing personalized services.

Article 5. Rights, Obligations, and Methods of Exercise of the Data Subject

① The data subject may exercise the following rights related to personal information protection against the company at any time:

a. Request for personal information access

b. Request for correction in case of errors

c. Request for deletion

d. Request for suspension of processing

② Rights under paragraph 1 can be exercised by written request, phone, email, or fax to the company, and the company will take action without delay.

③ If the data subject requests correction or deletion of errors in personal information, the company will not use or provide the personal information until the correction or deletion is completed.

④ Rights under paragraph 1 can be exercised through a legal representative or an agent authorized by the data subject. In this case, a power of attorney in accordance with the form prescribed in Appendix 11 of the Enforcement Rules of the Personal Information Protection Act must be submitted.

⑤ The data subject must not infringe upon the personal information and privacy of themselves or others that the company processes in violation
of the Personal Information Protection Act and other related laws.

Article 6. Provision of Personal Information to Third Parties

The company uses users’ personal information within the scope stated in [1. Purpose of Processing Personal Information] and does not use it beyond this scope or provide it to third parties without prior consent from the user. However, exceptions are made in the following cases:

① When users have given prior consent
② When providing information in a form that cannot identify specific individuals for statistical purposes, academic research, or market research
③ When required by national authorities under relevant laws
④ When there is a need for investigation into a crime or upon request from the Information and Communication Ethics Committee
⑤ When there are requests made in accordance with procedures established by other relevant laws

Article 7. utsourcing of Personal Information Processing

The company may outsource the processing of users’ personal information when necessary for providing services, and will establish the necessary provisions in accordance with relevant laws to ensure that personal information is managed securely during the outsourcing contract.

Article 8. Personal Information Protection Officer

① The company designates the following as the person responsible for the protection of personal information, overseeing related complaints, and remedies for damages associated with the processing of personal information.

▶ Personal Information Protection Officer
ㆍName: Jongpyo Kwon
ㆍPosition: Head of the Service Division
ㆍContact: 02-2039-3780, (duunni@synapsoft.co.kr)

▶ Personal Information Protection Department
ㆍDepartment Name: App Service Team
ㆍContact Person: Woogeun Lee
ㆍContact: 02-2039-3780, (skdnrms@synapsoft.co.kr)

② The information subject may inquire about all matters related to the protection of personal information, complaint handling, and remedies for damages that occur while using the company’s services. The company will promptly respond to and process the inquiries of information subjects.

Article 9. Measures to Ensure the Safety of Personal Information

The company takes the following measures to ensure the safety of personal information:

① Minimization and Training of Personnel Handling Personal Information

We designate and limit the personnel handling personal information to a minimum and implement measures to manage personal information effectively.

② Technical Measures Against Hacking and Other Threats

We have established and operate access control procedures for a separate physical storage location where personal information is kept..

③ Access Control for Unauthorized Persons
We have established and operate access control procedures for a separate physical storage location where personal information is kept.

*Effective date: June 12, 2023

*(Old) Personal Information Processing Guidelines (Effective date: April 11, 2016)