Hotel Park Habio (hereinafter referred to as “The Company”) shall comply with the regulation of personal information protection of the related laws that IT service provider must comply with such as the law regarding the promotion of information and communication network use and protection of information, Act on the protection of personal information, Communication Privacy Act, Telecommunication Business Act, Protection of Communication Secret, and is making its best efforts to protect the rights of users by establishing the privacy policy based on the related laws and regulations. This privacy policy shall be applied to Hotel Park Habio and the use of general services related to Hotel Park Habio which contains the following contents.

1. Items of personal information to collect and how to collect A. Items of personal information to collect
First, the Company is collecting personal information at minimum as the required items as follows when users join the membership in order to provide various services such as membership joining, customer consulting, and providing various services.
[Member Registration]
Required items: gender, name (English), date of birth, contact point, e-mail, nationality, ID, Password
Selected items : Name (Korean), address
Second, in the process of service use or business processing, the following information shall be automatically generated ad collected
IP Address, cookie, visit date, service use records, poor use records, machine information
Third, in the process of additional service or tailored service using an ID of Hotel Park Habio or in the application of event, the following information only for the one who uses the corresponding service shall be collected.
When receiving the consents for additional collection of personal information
Fourth, when using some services such as adult contents, paid service/games, if the identity verification is needed to comply with the relevant law, the following information shall be collected
- Gender, name (English), date of birth, contact point, e-mail, country, ID, Password
Firth, in the process of using the paid service, the following information shall be collected
- In case of payment by credit card: credit card company, credit card no.
- In case of payment by mobile phone: mobile phone no., telecommunication service provider, payment approval no. etc
- In case of transfer by bank : name of bank, account no.
- In case of using a gift coupon : gift coupon no.

B. How to collect personal information
The Company shall collect personal information by using the following method.
Website, written form, fax, telephone, consulting board, e-mail, application of event, request for delivery
Provided by partner company
Collected through information collecting tool
2. Purpose of collection and use of personal information A. Contract fulfillment for service to be provided and calculation of fare for service provided
Providing contents and specific tailored service, delivery of goods or sending a bill, identity verification, purchase and payment, fare collection
B. Membership management
Providing a membership service, personal identification; action to limit the use of service for the member who violated the terms and conditions of Hotel Park Habio; sanction of behavior that affects the smooth operation of service or the behavior of illegal use of service; verification of the will to join; limitation of subscription and the number of subscription; verification of the consent by legal attorney when collecting the personal information for child under 14; verification of legal attorney later; keeping the records for conciliation of dispute; treatment of complaints, delivery of notification, verification of the will for the cancellation of membership

C. Development of new service and utilization for marketing and advertisement
Development of new service and providing the tailored service; providing the service according to the statistical characteristics and posting the advertisement; verification of validity of service; providing the event information and opportunity of participation; providing the advertising information; identification of access frequency; statistics for the service use of member

3. Sharing and providing the personal information The Company shall use the personal information of users within the range notified on “2. Purpose of collection and use of personal information”, and not allowed to use out of range without prior consent of the user and disclose the personal information of user in principle. But, the following cases are allowed exceptionally:
A. When the prior consent of user is obtained
B. When requested by investigation agency based on the regulation of legislation or according to the procedure and method stipulated in the legislation for the purpose of investigation

4. The consigned company The consigned company for handling the personal information is operated to consign the personal information for the service improvement and in case of consignment contract, the necessary terms and conditions are defined according to the relevant laws and regulations so that personal information can be managed safely.
The personal information consignment institution of the Company and the contents of consignment duties are as follows.
Consignment duty of the trusted company : treatment for inquiries related to website
Possession of personal information and the period of use : by the time that member managed by website and system of GACHI Brother Co., Ltd. is canceled or until the consignment contract is terminated.

5. Possession of personal information and the period of use The personal information of user shall be disposed without hesitation in principle if the purpose of collection and use of personal information is accomplished. But, the following information shall be preserved during the specified period for the following reasons.

A. Reason of information possession by internal policy of the Company
Illegal record of use (abnormal service use records such as illegal subscription, punishment records etc)
Items preserved : gender, name (English), date of birth, contact point, e-mail, country, ID, Password, name (Korean), address
Reason for preservation: prevention of illegal subscription and use
Preservation period : 1 year
※ 'Illegal records of use' means the records limited by the Company due to illegal subscription or the message on the board that violates the operation principle.

B. Reason of information possession by relevant laws and regulation
When needed to preserve the information by the provisions of the related laws and regulations such as Commercial Law, Electronic Commerce Consumer Protection Act, the Company shall preserve the information of member during a certain period based on the related laws and regulations. In this case, the Company shall use the information preserved only for the purpose of preservation and the preservation period is as follows:
Records about subscription or cancellation
Reason of preservation: Electronic Commerce Consumer Protection Act
Period of preservation : 5 years
Records about payment and supply of goods
Reason of preservation : Electronic Commerce Consumer Protection Act
Period of preservation : 5 years
Records about electronic financial transactions
Reason of preservation : Electronic Financial Transaction Act
Period of preservation : 5 years
Records about complaints of consumers or treatment of dispute
Reason of preservation: Electronic Commerce Consumer Protection Act
Period of preservation : 3 years
Records of visits to website
Reason of preservation : Protection of Communication Secret Act
Period of preservation : 3 months

6. Procedure and method of disposal of personal information The personal information of user shall be disposed without hesitation in principle if the purpose of collection and use of personal information is accomplished.
The procedure and method of disposal of personal information by the Company is as follows.

A. Procedure of disposal
The information entered by user for member subscription shall be transferred to separate DB (in case of paper, separate document box) after the purpose is accomplished, and shall be stored for a certain period according to the reason of information protection by the internal policy or other relevant regulation (refer to the period of possession and use) and then disposed.
The personal information shall not be used for other purpose not for possession except for the case by the laws and regulation

B. Disposal method
The personal information printed on the paper shall be crushed by crusher or disposed through incineration
The personal information stored in the form of electronic file, shall be deleted using the technical method that prevents the regeneration of records.

7. The rights of user and legal attorney and the exercise method The user and legal attorney shall be able to view or modify the personal information registered for himself/herself or children under 14 at all the times and if not agreed to the treatment of personal information of the Company, shall be able to reject or request the cancellation of subscription (cancellation of membership). But, in that case, a part of or all of service may be limited to use.
To view or modify the personal information of the user or children under 14, click ‘change personal information’ (or ‘modify member information’) and for cancellation of subscription (cancellation of consent), click ‘cancellation of subscription’ to open, modify or cancel the subscription after verification of identity.
In addition, if contacted administrator in charge of personal information by letter, telephone or e-mail, we will take action immediately.
When the user requested to correct the error of personal information, the corresponding personal information shall not be used or provided until the completion of correction. In addition, if the wrong personal information already provided to the third party, the Company promises to notify the correction result to the third immediately to reflect the correction.
The Company shall treat the personal information cancelled or deleted by the request of user or legal attorney according to the provisions on “5. Possession of personal information and the period of use” and take actions not to be read or used for other purpose.

8. Matters of installation/operation and refusal of automatic collection device of personal information A. What is ‘Cookie’?
The Company uses ‘Cookie’ to store the information of user and import frequently in order to provide the personalized and tailored service.
Cookie is very small text file that the server used for operation of website sends to the browser of user, and is stored in the hard disk of user computer. And then, when user visits the website, the website server reads the contents of cookie stored in the hard disk of user and maintains the environment setting of user. Cookie is used to provide the tailored service
Cookie does not collect the information for personal identification automatically or manually and users are able to refuse the storage of such cookie or delete it anytime.

B. Purpose of Cookie use of the Company
The Company uses Cookie to identify the visit and use pattern of each service and web sites of Hotel Park Habio that users visited, popular search words, security access, news edition, size of user etc and provide the users with the optimized tailored information including the advertisement.

C. Installation/operation and refusal of Cookie
Users have the right to select the installation of Cookie. Thus, users can allow all Cookies by setting the option on web browser or have the verification procedure every time cookie is stored, or refuse the storage of all cookies.
But, if user refuses the storage of cookie, a part of service of Hotel Park Habio that requires a log in, shall be limited.
The method to designate whether to accept the installation of cookie (in case of Internet Explorer) is as follows
① Select [Tool] menu > [Internet Option]
② Click [personal information tab].
③ Set [personal information handling level]

9. Technical/managerial protection measures of personal information The Company is taking technical/managerial measures to secure the safety of personal information not to be lost, stolen, disclosed, modified or damaged when handling the personal information of users, as follows.

A. Encoding of password
The password of ID of member of Hotel Park Habio is encoded, stored and managed which is allowed user only to know and it is also allowed to verify and modify the personal information only by user who knows the password.

B. Countermeasures against hacking
The Company is making its best efforts to prevent the disclosure or damage of personal information of member due to hacking or computer viruses.
To prevent the damage of personal information, the data backup is frequently carried out and the personal information or data of users are protected from leakage or damage using the latest vaccine program and transferred safely on network through encoded communication.
And the penetration block system controls the unauthorized access from outside and all technical devices are equipped to secure the security in system

C. Minimization of handling staffs and training
The staff for handling the personal information of the Company is limited to the person in charge only and a separate password is updated regularly and the training for the staff in charge is carried out frequently to emphasize the compliance of privacy policy of Hotel Park Habio.

D. Operation of personal information protection team
The Company operates personal information protection team to verify the fulfillment of privacy policy of Hotel Park Habio and the compliance of the person in charge and if problem found, take actions for correction immediately.
However, even if the Company fulfilled its duty for personal information protection completely, the damage not attributable to the Company such as careless use or accident out of area not controlled by the Company, is not acceptable as the responsibility of the Company.

10. Contact to Manger and Staff in charge of personal information management Regarding the civil complaints related to all personal information protection incurred while using the service of the Company, you can contact the manager or department in charge. The Company will give you the quick and sincere reply to the reported matters.

Manager of personal information management / Staff in charge of personal information management
Name : Kwon Jin-woo
Department : Management Team
Tel.no.: 02-6925-9474
Title : Team Manager
e-mail: kjw6263@hanmail.net

11. Duty of notification When the contents of the current privacy policy are added, deleted or modified, the Company shall notify through ‘notices’ of website at least 7 days before revision. But, when there is important change of user’s right such as collection and utilization of personal information, providing to the third party, at least 30 days before revision.
Notified date: Apr. 20, 2017
Enforced date: Apr. 20, 2017