PERSONAL INFORMATION HANDLING POLICY

We, INSPIRE Integrated Resort Co., Ltd. (also hereinafter referred to as the “Company”), use our best efforts to protect your privacy and personal information, and to that end the Company is committed to complying with the Promotion of the Use of Information and Communication Networks and Protection of Information Act (the “Information and Communication Networks Act”), the Privacy Protection Act and all other relevant laws and regulations. This Privacy Policy is posted for public access on the Company’s website (inspireer.com) so you can be well informed of what we do to protect your personal information.

This Privacy Policy may be revised or updated from time to time according to changes to pertinent laws, government policies or the Company’s internal regulations and we will immediately notify you of such revisions or updates in order that you can be readily aware thereof.

The Company’s Privacy Policy contains the following:

1. Collection of Personal Information; Purposes of Collection; Items to Be Collected; and Methods of Collection

2. Disclosure and Sharing of Collected Personal Information

3. Outsourcing the Handling of Personal Information

4. Collection of Personal Information by the Use of Cookies

5. Retention and Destruction of Personal Information

6. Rights and Obligations of Users and Exercise of Rights

7. Measures for Security of Personal Information

8. Privacy Officer

9. Privacy Protection for Children under the Age of 14

10. Transmission of Advertising Messages

11. Linked Sites

12. Changes to the Privacy Policy

1. Collection of Personal Information; Purposes of Collection; Items to Be Collected; and Methods of Collection.

A. When you attempt to sign up for a newsletter and enquiries, we collect your personal information as may be required to identify you and provide online services. The personal information to be collected by the Company is as follows:

Items

Purpose

Period of Retention/Use

Career

Full name, e-mail address, Phone number

To respond the enquiries

Until the purpose of use is achieved

Newsletter

E-mail address

To provide IR news

Until withdrawal from subscription

Partnership leasing

Full name, e-mail address

To handle the enquiries

Until the purpose of use is achieved

B. When you sign up for INSPIRE newsletter, we selectively collect the following personal information from you:

Items

Purpose

Period of Retention/Use

Newsletter

Full name, Interests, date of birth

To provide IR news

Until withdrawal from subscription

Career

Consent form for the privacy policy

To respond the enquiries

Until the purpose of use is achieved

C. When you are using online services, we may collect such information as your IP address and service-use history only for the purposes of making such services available and/or verifying you.

D. We collect your personal information from your application for newsletter subscription on our website and by means of written notices, facsimile or phone communications, online message boards, promotional events and/or other approaches for collection of created information

2. Disclosure and Sharing of Collected Personal Information

A. We will not use or disclose to any third party any of your personal information, without your consent or except as required by law, for purposes other than those intended hereunder and specified herein.

B. If any business relations are formed through the services we provide, relevant information will be disclosed to the parties in question to the extent necessary for the conduct of transactions, subject to members’ consent.

C. Your personal information may be disclosed without your consent in accordance with applicable provisions of relevant laws:

– when needed to perform a contract relating to the provision of services.
– when duly and reasonably requested by an investigation authority for investigation purposes;
or
– when made available in unidentifiable form for the compilation of statistics or for academic or market research purposes.

3. Outsourcing the Handling of Personal Information

A. The Company, for the provision of its services, don’t have outsourced the handling of personal information.

4. Collection of personal information using cookies

A. Use of Cookies
We use cookies for the convenience of users. The information we collect through cookies includes your username and IP address and is used to keep you logged in and display
personalized advertising messages.

B. Installation and Use of Cookies; and Refusal of Use
You have the option to accept or decline the installation of cookies and may set your web browser to accept all cookies, alert you whenever a cookie is stored, or disable or block the storage of cookies. Disabling or blocking the storage of cookies may limit your access to services requiring you to log in.

5. Retention and Destruction of Personal Information

A. The Company will retain your personal information until the purposes of collection or
disclosure of such information are accomplished and will destroy your personal information immediately when such purposes are accomplished or upon the expiration of a retention period permitted by your consent. The times when we are required to destroy your personal information are as follows:

– Your membership/subscription information is destroyed when you withdraw or are dismissed.
– Your information collected for a survey or promotional event is destroyed upon when such survey or event is over.
– The information used to identify you is destroyed when your identity has been verified.

B. Notwithstanding the foregoing, when any of your personal information needs to be retained under relevant law.

C. Your personal information will be destroyed by the following procedures and methods: 
– Electronically stored information is permanently deleted in a technically irretrievable manner.

6. Rights and Obligations of Users and Exercise of Rights

A. You have the right at any time to delete your subscription, have it corrected or deleted, have
its processing suspended or withdraw your consent to the use and disclosure thereof, directly on the subscription page of our website or by contacting our Privacy Officer in writing, or by email, in which case we will respond forthwith after identity verification.

B. If you request that we correct an error in your registered personal information, such information will not be employed or disclosed until such correction is made accordingly.

7. Measures for Security of Personal Information

In handling your personal information, we use our best efforts to prevent such information from being lost, stolen, leaked, falsified or damaged by taking the following technical, administrative and physical measures for security assurance:

– Encryption of personal information
Your personal information is password-protected and stored and managed in encrypted form.
All data is encrypted for transmission and other important data is protected by separate
security features.

– Technical measures against hacking
All personal information is subject to Advance Threat Protection access security provided by Microsoft 365 and Azure. All our offices are firewalled with ATP platforms incorporated (IPS module).

– Limited access to personal information
We take necessary measures to control access to personal information by means of granting, modifying or canceling access to database systems that handle  personal information, and a
firewall system is employed to control unauthorized access from outside.
Multifactor authentication enabled and MDM (mobile devices management) platform to access data.

– Storage of access logs and prevention of data forging or tampering
We store and maintain a history of your access to our personal information processing system and use security features for your access log data not to be forged, tampered with, damaged, stolen or lost.

– Use of locks for document security
Company employs strict ITIL, ISO 20001, ISO 1779, and NIST 800-53 industry standards for IT management and data security. All data stored in our organization containers is protected by Office 365 Advance Threat Protection and Office 365 Threat Intelligence. Same for any database used on our future
website. Any CRM will be subjected to same level of protection and encryption, including data communication.

– The company minimizes the number of staff members who have access to personal information, emphasizes the importance of compliance with this Policy through frequent trainings conducted on employees in charge, and takes immediate action against any related problem. However, INSPIRE resort shall not be held liable for any occurrences attributable to customer errors or the nature of the Internet. Each customer must manage his/her personal information appropriately and be responsible for such management.

8. Privacy Officer

The Company has appointed the following departments and persons to be responsible for protecting its customers’ privacy and personal information and for gathering their opinions and handling their complaints:

CPO

Personal Information
Handler

Name

Ioan Mitulescu

Jade Y. Kim

Department

IT

PR

Title

Vice President

Director

Email address

ioan.mitulescu@inspireer.com

Jade.kim@inspireer.com

If you want to report a breach of your privacy or seek advice thereon, please contact:
– The Privacy Complaint Center (via privacy.kisa.or.kr or at 118);
– The Supreme Prosecutors’ Office High-tech and Financial Crimes Investigation Division (via
www.spo.go.kr or at 1301); or
– The National Police Agency Cyber Bureau (via www.ctrc.go.kr or at 182)

9. Privacy Protection for Children under the Age of 14

The Company does not collect any personal information of our member customers’ children under the age of 14 in compliance with the Juvenile Protection Act. If we need to collect personal information of the minors under the age of 14 with respect to our resort business, we will get consent from their legal representatives or guardians.

10. Transmission of Advertising Messages

A. We do not send you any advertising messages for commercial purposes so long as your withdrawal request is expressly given.

B. If we send any advertising message by email or otherwise for online marketing purposes such as presenting product information, we will ensure that in a plain and legible manner:
– ‘The email’s subject line communicates what the email is about, although it may not indicate “Advertisement”; and
– The body text contains the sender’s name, email address, as well as instructions on how to unsubscribe, so that the recipient can readily unsubscribe from further advertisements.

C. Likewise, if we send you an advertising message for commercial purposes by fax or mobile text message or via non-email means, we will ensure that the sender’s name is indicated in such message, even if you have agreed to the receipt of advertising messages.

11. Linked Sites

A. We may provide you with links to websites or materials of other companies, in which case we assume no responsibility for and make no guarantee as to the usefulness of such websites and materials over which we have no  control.

B. If you move to another website by clicking a link appearing on the Company’s website, we recommend that you carefully read the privacy policy of such website, as it is beyond the control of INSPIRE Integrated Resort.

12. Changes to the Privacy Policy

If any change is made to this Privacy Policy by addition, deletion or correction due to a modification or revision in relevant laws, government policies or the Company’s internal regulations, or a change of security technology, the Company will post such change immediately on its website.

- Enforcement Date: 2021-Mar-31
- Amended date: 2021-Mar-31