CLASSUM Co., Ltd. (“CLASSUM”) operates a privacy policy (“Privacy Policy”) as shown below to protect the personal information of its data subjects (“Users”) and to process any related complaints in a prompt manner in accordance with Article 30 of the Personal Information Protection Act. This Privacy Policy of CLASSUM may be amended from time to time subject to the changes in the applicable law, policy, or CLASSUM's internal policy, etc., and any such changes to the Privacy Policy will be announced on the website so that Users may easily be informed of the changes.

This Privacy Policy will take effective from February 11th, 2022 (“Effective Date”).

1. Purpose of Processing Personal Information

CLASSUM collects the minimum amount of personal information that is necessary to provide services to Users and obtains consent from Users for the collection of such information. The items of personal information that are collected are shown below, which are used only for the notified purposes. CLASSUM processes personal information for the following purposes and does not use it for any other purposes.

• To perform obligations under the service agreement, settle charges for services rendered, purchase and pay for service, manage membership, and verify identification;
• To authenticate members prior to allowing the use of membership-based services for the management of members, conduct personal identification, prevent illegal or unauthorized use by delinquent members, confirm members' intention to execute service agreements, verify age, handle complaints and other grievances, and provide notices to members;
• To develop and specialize new services (products) for marketing and advertisements, deliver advertising information, such as event information, etc., understand access frequency or compile statistics on members' use of the services; and
• To restrict the number of subscriptions, preserve records for dispute resolution, build a service environment to strengthen privacy protection, monitor members' satisfaction with the service and goal satisfaction status, calculate statistics on lectures, classes, and interests, etc.

2. Items of Personal Information to be Processed

1. CLASSUM processes the following items of Personal Information
   • Required items: name, mobile phone number, e-mail address, affiliated organization, major, legal representative’s information for members under the age of 14 (name, date of birth, gender, e-mail address, mobile phone number of the legal representative)
   • Optional items: occupation, consent to receive marketing information
2. Information, such as mobile device IDs, access IP address, advertising ID (AAID, IDFA, etc.), cookies, and access date/time, etc. may be automatically generated and collected to check whether any content has been used in the process of using the service or operating the business.
3. CLASSUM collects the following personal information from a third party when Users subscribe for membership (or subscribe for service) through external platforms or by synchronizing accounts.
   • Google: Google ID, e-mail address
   • Apple: Apple ID, e-mail address (if selected, collected only once initially)
   • Facebook, Inc.: Facebook ID, e-mail address (optional), profile photo (optional)
   • Membership through an institution affiliated with CLASSUM: The member’s name and e-mail registered with the affiliated institution

3. Processing of Personal Information and Retention Period

1. CLASSUM processes and holds personal information for the period of retention and use to which Users consented when the personal information was collected or within the period of retention and use permitted under law.
2. The specific periods for processing and retaining personal information are as follows:
   • Prevention of fraudulent subscription and inappropriate use: If there is a record of inappropriate use of the service, such as fraudulent subscription, unauthorized disclosure of posts, or sharing of ID, etc., the authentication information for subscription (e-mail address or Facebook serial number, legal representative’s e-mail address and mobile phone number in the case of a member under the age of 14), among other personal information, will be retained for one year from the date of cancellation of User’s membership.
   • User subscription and management: Until the service agreement or membership is terminated. However, if there remain any receivables or debtor-creditor relationship, personal information of the member will be retained until such receivables are collected or the debtor-creditor relationship is settled.
   • Records of e-commerce contracts and withdrawal of e-commerce subscription, payment records and records of supply of goods, etc.: 5 years
   • Records of consumer complaints or dispute settlements: 3 years
   • Records of User access logs (communication confirmation data): 3 months

4. Providing Personal Information to a Third Party