Privacy Policy | FIMS: 작가들의 필터 판매 플랫폼

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

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

Through this Policy, Poze 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 Poze for protection of those personal information.

This Policy will be effective on the 1th day of October, 2018 and, in case of modification thereof, Poze 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 Poze are as follows:

• Information provided by the users

Poze may collect the information directly provided by the users.

Title of service

Items to be collected(examples)

Internet

membership

service

∘ Name, email address, ID, telephone number, address, national information, encoded

identification information (CI), identification information of overlapped membership (DI)

∘ For minors, information of legal representatives (name, birth date, CI and DI of legal representatives)

Online

payment

service

∘ Name, address, telephone number, and email address

∘ Payment information including account number and card number

∘ Delivery information including delivery address, name and contact information of recipient

∘ Information of bid, purchase and sales

Social

network

service

∘ Name, email address, ID, telephone number, address, national information, address list (acquaintance)

∘ Information of place of taking pictures and date of creation of files

∘ Information of service use of members such as the type of contents watched or used by members, frequencies and period of activities of members

frequencies and period of activities of members

• Information collected while the users use services

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

Lists

Items to be collected(examples)

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

∘ Information of device location including specific geographical location detected through GPS , Bluetooth or Wifi (limited to the region permissible under the laws)

Other information

∘ Preference, advertisement environment, visited pages regarding service use of users

(2) Method of collection

Poze collects the information of users in a way of the followings:

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

• provided by partner companies

2. Use of collected information

Poze 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, service fee payment and service fee settlement 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 help you connect with other users you already know and, with your permission, allow other users to connect with you

• 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

• To comply with applicable laws or legal obligation

• Use of information with prior consent of the users (for example, utilization of marketing advertisement)

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

3. Disclosure of collected information

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

∘ 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

Functionality

∘ Preference, advertisement environment, visited pages regarding service use of Users

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

(Examples of functionality cookies)

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

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

Targeting

cookies or

advertising

This cookie is connected with the services provided by a 3rd party such as the buttons of 'good' and 'share'. The 3rd party provides these services by recognizing that the users visits the website of Poze.

(Examples of targeting cookies or advertising cookies)

∘ Carry out PR to the users as targets in other websites by connecting through social networks and these networks use the information of users' visit

∘ Provide the information of users' visit to ad agencies so that they can suggest an ad which may attract the interest of the users

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 Poze.

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 Poze:

• 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 rights, you, as an user, use the menu of 'amendment of member information of webpage or contact Poze by sending a document or e-mails, or using telephone to Poze(or person in charge of management of personal information or a deputy), Poze will take measures without delay: Provided that Poze 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

Poze regard the security of personal information of uses as very important. Poze 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

7. Protection of personal information of children

In principle, Poze 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 Poze are the ones to be provided to ordinary people, in principle. The website or application of Poze has function to do age limit so that children cannot use it and Poze does not intentionally collect any personal information from children through that function.

(Additional procedure for collecting personal information from children) However, if Poze 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, Poze will go through the additional procedure of the followings for protecting that personal information of children:• verify, to the extent that efforts are reasonably made, whether they are children of the age at which consent from their guardian is required and the consenting person is an authorized one.

• 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 Poze

• 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

Poze has the right to amend or modify this Policy from time to time and, in such case, Poze 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. Others

10. Contact information of Company

•Company name : Poze

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

Address : Studio 5, iSquare, 2nd floor, Han-bit Building, 1, Kangwondaehak-gil, Chuncheon-si, Gangwon-do, Republic of Korea

Tel: +82 10 4759 2502

E-mail: help@pozeapp.io

(Add the following if designated of data protection officer) Poze designates the following Data Protection Officer (DPO) in order to protect personal information of customers and deal with complaints from customers.

DPO of Poze

Adress: Unit 401-13, 4th floor, 305, Gongji-ro, Chuncheon-si, Gangwon-do

Tel: +82 10 4759 2502

E-mail: help@pozeapp.io

(Add the following if the controller operating outside of the EU designates its deputy in the EU) Poze designates a deputy in the EU in order to protect personal information of customers and deal with complaints from customers.

Deputy of Poze

Adress: Unit 401-13, 4th floor, 305, Gongji-ro, Chuncheon-si, Gangwon-do

Tel: +82 10 4759 2502

E-mail: help@pozeapp.io

The latest update date: March 18th, 2019.

Appendix of Privacy Protection Policy

<1> Lawful processing of personal information under GDPR

Processing personal information by Poze 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.

- Performance of a contract in relation to providing the services required by users, payment and settlement of fees, etc.

• Processing is necessary for compliance with a legal obligation to which Poze 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 Poze

• Processing is necessary for the purposes of the legitimate interests pursued by Poze 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> 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 Poze:

• 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 rightss, you, as an user, use the menu of 'amendment of member information of webpage or contact Poze by sending a document or e-mails, or using telephone to Poze ( person in charge of management of personal information or a deputy), Poze will take measures without delay: Provided that Poze 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> Data transfer to other countries

Considering it engages in global businesses, Poze 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, Poze 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, Poze 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.

The website, product or service of Poze 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 Poze.

<5> Guide for users residing in California

If the user resides in California, certain rights may be given. Poze prepare preventive measures necessary for protecting personal information of members so that Poze can comply with online privacy protection laws of California.

In case of leakage of personal information, an user may request Poze to check the leakage. In addition, all the users in the website of Poze, can modify their information at any time by using the menu for changing information by connecting their personal account.

Moreover, Poze does not trace the visitors of its website nor use any signals for 'tracing prevent'. Poze will not collect and provide any personal identification information through ad services without consent of users.

<6> Guide for users residing in Korea

Poze guides several additional matters to be disclosed as required by the information network laws and personal information protection laws in the Republic of Korea as follows:

(1) Information collected

The items collected by Poze are as follows:

• Examples of required information

Title of service

Items to be collected(examples)

Internet

membership

service

∘ Name, email address, ID, telephone number, address, national information,

encoded identification information (CI), identification information of overlapped

membership (DI)

∘ For minors, information of legal representatives (name, birth date, CI and DI of legal representatives)

Online

payment

service

∘ Name, address, telephone number, and email address

∘ For payment with credit card : name of card company, number and expiration of card

∘ For small sum payment charged on the mobile phone: mobile phone number, payment approval number

∘ For payment by remittance: name of bank, account number and password of account

∘ For deposit without a bankbook: name of remitter, contact information

∘ Delivery information including delivery address, name and contact information of recipient

∘ Information of bid, purchase and sales

Social

network

service

∘ Name, email address, ID, telephone number, address, national information, address list (acquaintance)

∘ Information of place of taking pictures and date of creation of files

∘ Information of service use of members such as the type of contents watched or used by members, frequencies and period of activities of members

In the course of using services, the information as described below may be created and collected:

∘ Information of devices (equipment/device identifier, operation system, hardware version, equipment set-up and telephone number)

∘ Log information (Log data, use time, search word input by users, internet protocol address, cookie and web beacon)

∘ Location information (Information of device location including specific geographical location detected through GPS, Bluetooth or Wifi)

∘ Other created information

• Examples of optional items

The user may reject the collection and use of optional items and, even in case of rejection, there is no limit on use of services

Purpose of collestion

Items to be collected(examples)

User analysis

∘ The reason for membership, occupation, marriage status, wedding anniversary, interest category and SNS account information

Provision of

customized ad

∘ Contents and result of marketing activities and event participation

Delivery of

urgent notice

∘ Information provided by the users regarding execution, maintenance, execution, management of other agreements and event participation

Marketing

∘ Preference, advertisement environment, visited pages regarding service use of users

• Additional procedure for collection of sensitive information

If collection of sensitive information is indispensible, Poze may collect it by going through lawful procedure in accordance with relevant laws and regulations. The sensitive information which may be collected by Poze is as follows:

∘ Thoughts and belief

∘ Membership of and withdrawal from labor union or political party

∘ Political opinions

∘ Information of health and sexual life

∘ Genetic information obtained from the result of gene test

∘ Information of criminal record including announcement, exemption and suspension of sentences, care and custody, protective custody, treatment and custody, probation, lapse of suspension of sentence and cancellation of suspension of execution.

(2) Commission for collected personal information

For carrying out services, Poze commissions external professional companies (subcontractors) to process personal information as follows. This commissioned works for processing personal information is carried out by each subcontractor and service only if necessary for providing that service.

In commissioning process of personal information, in order to secure safety of personal information , Poze supervises and ensure to expressly state in the agreement with subcontractors so that those subcontractors will safely process personal information by strictly complying with directions regarding personal information protection, keeping personal information secret, not disclosing it to a 3rd party and being liable for accidents and returning or destructing personal information upon termination of the commission or process.

Name of subcontractors

Description of commissioned works (services)

AAA

Customer service

(3) Details of provision of personal information to 3rd party

Except for the following cases, Poze does not disclose or provide personal information of the users to a 3rd party:

Recipients of information

Purpose of use of recipien Items to be provided

Period of retention and use of recipient

BBB

Provision of service

tie-up

ID, Name and age

Until the date when the purpose of use is achieved or period as required by the laws

(4) Period for retention and use of personal information

In principle, Poze destructs personal information of users without delay when: the purpose of its collection and use has been achieved; the legal or management needs are satisfied; or users request: Provided that, if it is required to retain the information by relevant laws and

regulations, Poze will retain member information for certain period as designated by relevant laws and regulations. The information to be retained as required by relevant laws and regulations are as follows:

∘ Record regarding contract or withdrawal of subscription: 5 years (The Act on Consumer Protection in Electronic Commerce )

∘ Record on payment and supply of goods:5 years (The Act on Consumer Protection in Electronic Commerce )

∘ Record on consumer complaint or dispute treatment: 3 years (The Act on Consumer Protection in Electronic Commerce )

∘ Record on collection/process, and use of credit information: 3 years (The Act on Use and Protection of Credit Information )

∘ Record on sign/advertisement: 6 months(The Act on Consumer Protection in Electronic Commerce )

∘ Log record of users such as internet/data detecting the place of user connection: 3 months(The Protection of Communications Secrets Act )

∘ Other data for checking communication facts: 12 months (The Protection of Communications Secrets Act )

(5) Procedure and method of destruction of personal information

In principle, Poze destructs the information immediately after the purposes of its collection and use have been achieved without delay: Provided that, if any information is to be retained as required by relevant laws and regulations, Poze retain it for the period as required by those laws and regulations before destruction and, in such event, the personal information which is stored and managed separately will never be used for other purposes. Poze destructs: hard copies of personal information by shredding with a pulverizer or incinerating it; and delete personal information stored in the form of electric file by using technological method making that information not restored.

(6) Technical, managerial and physical measures for protection of personal information

In order to prevent the loss, theft, leakage, alteration or damage of personal information of the users, Poze takes technical, managerial and physical measures for securing safety as follows:

Items

Examples

Technical

measures

∘ Utilize security servers for transmitting encryption of personal information

∘ Take measures of encryption for confidential information

∘ Install and operate access control devices and equipments

∘ Establish and execute internal management plan

Managerial

measures

∘ Appoint a staff responsible for protecting personal information

∘ Provide education and training for staffs treating personal information

∘ Establish and execute internal management plan

∘ Establish rules for writing passwords which is hard to be estimated

∘ Ensure safe storage of record of access to personal information processing system

∘ Classify the level of authority to access to personal information processing system

Physical measures

∘ Establish and operate the procedure for access control for the facilities for storing personal information

∘ Store documents and backing storage containing personal information in safe places which have locking device

(7) Staff responsible for managing personal information

The staff of Poze responsible for managing personal information is as follows:

• Name of staff responsible for managing personal information:

Dept. : Poze

Tel. : +82 10 4759 2502

Contact : help@pozeapp.io

The latest update date: 18th, March, 2019.

Application and Website Terms of Use

Version 1.0

The Poze application and website located at Google Play , App Store and https://www.instagram.com/poze.official/ are a copyrighted work belonging to Poze. Certain features of the Site may be subject to additional guidelines, terms, or rules, which will be posted on the Site in connection with such features.