BeNX Corporation (hereinafter referred to as the “Company”) holds the personal data of its Weply service (hereinafter referred to as the “Service”) users (hereinafter referred to as the “Members”) to the upmost importance. Therefore, the Company has a strict privacy policy. Through this privacy policy (hereinafter referred to as the “Privacy Policy”), we inform our Members of the purpose and manner for which their personal data is being used and security measures the Company implements to safeguard the personal data. This Privacy Policy may be amended pursuant to changes in the applicable laws, regulations, and/or the Company’s policy, so please check the Privacy Policy from time to time for possible changes when using the Service.

① The following personal data is collected by the Company from the Members when they sign up for or use the Service.

② The Company collects personal data of the Members as above, but it does not collect sensitive personal data (e.g., race and ethnicity, ideology and beliefs, birthplace and domicile, political views and criminal record, health status and sex life) that may infringe upon the basic human rights of the Members and particular identification data.

③ The Company asks for permission to access the stored data or functions within a Member’s mobile device when the Members use the Service through a mobile application. When required, the Company asks for such permission in the form of either access that is necessary no matter what to provide the Service and access that is not, which can later be changed by the Member through the “Settings” option on their mobile device.

④ The Service is not intended for children (i.e., under 14 years old for Koreans and under 16 years old for foreigners). If the Company becomes aware that the collected personal data is from a child, we will delete the personal data and close the subject user’s account. If you believe that the Company has collected personal data from a child, please contact privacy@weply.io.

① The Company does not provide personal data of the Members to third parties; provided, however, this is not the case if otherwise provided for in an applicable law or the Member’s consent is obtained.

② The Company can get the consent of the users, if necessary, for the usage of service of the users, and consequently provide the personal information to a third party.

① Members can login to the Service and view/change their personal data through the MY > MY DATA section; provided, however, their ID (i.e., email) cannot be changed.

② In accordance with the restrictions and requirements under the relevant laws and regulations, the Members may exercise their rights relating to their personal data against the Company. For example, in Korea, a Member may request the Company to suspend its processing of his/her personal data, delete his/her personal data, and/or revoke consent to the Company’s collection/use of his/her personal data.

③ Data subjects may exercise their rights set forth in this Article by contacting support@weply.io or privacy@weply.io

In principle, if the Company collects a Member’s personal data, the personal data is retained from the time of sign up until the cancellation of the Member’s account (including cancellation requested by the Member and cancellation by the Company itself based on its direct authority). When a member terminates his/her account, the Company shall destroy the Member’s personal data so it cannot be viewed or used; provided, however, in circumstances where the personal data is required to achieve the Company’s purposes of collection/use and/or where retaining the personal data is required or permitted by law, the Company may retain the Member’s personal data even after his/her account is terminated. For example, under the relevant Korean laws such as the Commercial Act, Act on Consumer Protection in Electronic Commerce (“E-Commerce Act”), Electronic Financial Transactions Act, Specialized Credit Finance Business Act, Framework Act on National Taxes, Corporate Tax Act, and the Value-Added Tax Act, and the Service’s internal regulations, information that can be used to identify a transacting party (e.g., name, address) and information that can be used to verify the rights and obligations of the transacting party with respect to the transaction may be retained by the Company even if the Member withdraws his/her consent to the use of the Service. Transaction records shall be retained as follows.

① Records relating to advertisement and labelling
- Grounds for retention: E-Commerce Act
- Duration of retention: six months

② Records relating to contracts, cancellation of service, etc.
- Grounds for retention: E-Commerce Act
- Duration of retention: five years

③ Records relating to payment settlement and supply of goods
- Grounds for preservation: E-Commerce Act
- Duration of retention: five years

④ Records relating to processing of consumer complaints and dispute resolution
- Grounds for retention: E-Commerce Act
- Duration of retention: three years

⑤ Information requested by an investigative agency pursuant to a search and seizure warrant
- Grounds for retention: Protection of Communication Secrets Act
- Duration of retention: six months

In principle, once the personal data’s purpose of collection/use is achieved, the Company destroys the subject personal data without delay in accordance with the respective retention/use period. The procedure, method, and time for destroying personal data are as follows:

(1) Procedures for destroying personal data

① In the event that data provided by a Member when he/she signed up for membership must be retained or is permitted to be retained under an applicable law or regulation even after the purpose of collection/use is achieved, the data will be transferred to a separate database (if the data is provided in the form of a paper document, a separate filing cabinet), and destroyed after being retained for a certain period under the Company’s internal policy and other relevant regulations (see Article 4 (Retention/use period of personal data) above).

② The personal data that is moved to the separate database will not be used for purposes other than required or permitted by law.

(2) Methods for destroying personal data

① If stored in the form of electronic files, the personal data will be destroyed by technical means so that the records cannot be reproduced.

② If printed on paper, the personal data will be destroyed by shredding or incinerating the paper documents.

(3) Methods for destroying personal data of inactive accounts

Pursuant to Article 12 of weply’s Terms of Use, if a Member does not use the Service for at least one year, the Member’s inactive account may be terminated and the Member’s personal data may be destroyed.

The Company will notify Members at least 30 days prior to terminating an inactive account, and the notice will contain the following information:

- The fact that the Member’s personal data will be destroyed or separately stored

- Date and time of destruction

- The items of personal data to be destroyed

Notifications may be sent through email or other similar method.

As an exception, the information below may be maintained even after a year of inactivity.

- Where a Member and an information and communications service provider (e.g., the Company) enters into a separate agreement regarding the period of retention of personal data.

- Where the retention is required by applicable law or regulation

- For the prevention of fraudulent activities, emails of the deleted accounts will be encrypted with one-way password that renders decryption impossible and will be kept for 3 months, during which sign-ups are restricted.

- Once the 3-months period as explained above is over, the emails will be destroyed immediately.

The Company uses cookies to save and occasionally search through data related to Members. Cookies are small text files sent from website servers to the user’s computer browser (e.g., Internet Explorer, Safari, Chrome, Firefox). Cookies identify the computers used by the Members but do not identify the individual Members themselves.

(1) Operation of cookies

① Provide differentiated information depending on the individual’s area of interest.

② Engage in targeted marketing by determining the Members’ preferences and areas of interesting based on an analysis of how often Members and non-Members visited the website and/or used the Service.

③ Provide personalized service to Members on their next visit/use by tracking content that the Members showed an interest in.

④ Use as criteria in deciding whether and how to improve the Service by analyzing the customers’ habits.

(2) Members’ options regarding cookies

By adjusting the web browser, the Members can choose whether to accept all cookies, to be notified when cookies are installed, or deny all cookies; provided, however, if a Member refuses to install cookies, he/she cannot use some of the services that require the Member to log in.

Below are the steps for changing the settings for installation of cookies on Internet Explorer:

① Under the [Tools] menu, select [Internet Options].

② Click the [Privacy] tab.

③ In the [Settings] section in the [Privacy] tab, the user can select the cookies setting by moving the slider. (Moving the slider to the top will block cookies from all websites and moving the slider to the bottom will allow cookies from all websites.)

(3) Cookies will expire once the user closes the browser or logs out of the browser.

(1) In processing personal data, the Company may take reasonable safety measures to ensure that personal data is not lost, stolen, leaked, altered, or damaged. The Company may use the following technical measures for such purpose.

① A Member’s personal data is protected by password and encrypted information. Even with these safety measures, there is still a high possibility that a Member’s password or personal data may be leaked to others if a Member accesses the Internet in a public area or through other means. As such, what is most important is to thoroughly protect the personal data of the Members as much as possible. Therefore, all Members should also be careful not to leak or provide their personal data to others, and take responsibility in managing their personal data. The Company is not responsible for problems that may arise from the Member’s own negligence or the inherent dangers of using the internet.

② Fundamentally, the Members’ personal data is protected by password and encrypted information. Files and transferred data are encrypted and important data is protected by separate security features.

③ The Company uses anti-virus software to prevent damages that arise from computer viruses and regularly updates the software.

④ To prevent leakage or damage of Members’ personal data from hackings, computer viruses, and other sources of intrusion, the Company maintains a 24-hour intrusion detection and intrusion prevention system that monitors possible threats from outside sources.

(2) The Company recognizes the importance of protecting personal data, so we limit the number of employees who process personal data to only those that are necessary. The Chief Privacy Officer (CPO) regularly educates/trains these employees to ensure the protection of the Members’ personal data. Also, the Company regularly reviews the relevant employees’ compliance with the provisions of this Privacy Policy, and where a violation is found, the Company orders the employees to correct/improve the violation and take any other necessary measures.

The Company operates a customer service center in order to facilitate communications with Members regarding any feedback or complaints they may have regarding the protection of their personal data.

In Korea, if a dispute arises between the Member and the Company with respect to personal data-related matters, the Member may contact any one of the following agencies and seek consultation regarding a possible privacy violation.

(1) The Company has designated a Chief Privacy Officer as below, and the Company’s internal department responsible for managing matters related to the processing of personal data always puts forth its best efforts to protect your valued personal data.

Any Member who has any questions, comments, or complaints relating to his/her personal data, please reach out to one of the contacts listed below through email or by phone. The Company will make every effort to respond promptly and with sincerity.

In order to provide the Service to the Members, carry out the Service agreements entered into with the Members, and promote the convenience of the Members, the Company outsources the processing of the Members’ personal data to Korean and foreign third-party service providers (“Outsourced Processors”) specializing in data processing where necessary and within the scope disclosed under this Privacy Policy.

1) Outsourcing of processing to Korean third-party service providers:

2) Outsourcing of processing to foreign third-party service providers (i.e., cross-border transfer of personal data):

When entering into an outsourcing agreement with an Outsourced Processor, the Company makes sure that the following provisions are included in the agreement: prohibition on processing personal information for purposes outside the initial scope of processing tasks that were outsourced, technical and managerial safeguards, restrictions on subcontracting by the Outsourced Processor, matters relating to the supervision of the Outsourced Processor, and liability for damages that may arise out of a violation of the Outsourced Processor’s obligations. The Company also supervises the Outsourced Processor to ensure that it securely processes the personal data.

If there are any changes to the tasks to be outsourced or the list of Outsourced Processors, they will be reflected in this Privacy Policy without delay.

This Privacy Policy was promulgated on June 3, 2019. Any changes (e.g., addition, deletion or revision) to this Privacy Policy pursuant to amendments in the Company’s or Korean government’s policy will be notified in advance to the Members on the Company’s website. For material changes that may significantly impact the Members’ rights, notice will be given 30 days prior to the scheduled effective date of such changes.

Privacy Policy version number: V1.5

Effective date: 2019. 07. 15

Previous Privacy Policy v1.4 (Effective date 2019.06.21)

Previous Privacy Policy v1.3 (Effective date 2019.06.03)