Privacy Policy

1. [Purpose of Collection and Use of Personal Information]

• The company will not use the user's personal information beyond the scope notified in this clause, except with the user's consent or as otherwise provided by law. The purposes of collecting and using personal information are as follows:

1. Contract Execution, Maintenance, Performance, Management, and Improvement: For the execution, maintenance, performance, management, and improvement of contracts.
2. Member Management: For verification of membership, personal identification, prevention of unauthorized use and fraudulent activities by malicious members, confirmation of intention to join, restrictions on registration, future legal guardian verification, record keeping for dispute resolution, age verification, complaint handling, and the provision of updated information such as notices.
3. Service Provision-related Contract Performance: For various service provisions, including the purchase of mobility, content provision, and other necessary matters.
4. Daedong e-Mobility Service: For the improvement and development of Daedong e-Mobility services, statistical analysis of service usage, guidance and information delivery related to service purposes, such as mobility driving distance, mobility usage history and remote control, emergency rescue, consumables and fault history management, BSS information, battery charging, and other necessary matters.
5. Daedong Mobility Vehicle Control Service: For control services related to Daedong Mobility product groups (dashboard, vehicle management, business management, member management, statistical analysis of service usage, etc.), guidance and information delivery related to service purposes.
6. Collection and Use for Investigating and Dealing with Accidents: For investigating the cause and handling of accidents.
7. Only with separate consent from members: For improvement of advertising information, events, promotions, satisfaction surveys, provision of services and advertisements tailored to Daedong e-Mobility products, and statistics extraction related to user service usage, such as understanding connection frequency.

2. [Items of Personal Information]

1. The items of personal information collected by the company for users to use the service are as follows. The company collects and uses personal information by categorizing it into 'mandatory consent items' necessary for service provision and 'optional consent items' for providing better services to customers.

   Service	Information
   Daedong Mobility Service:	Daedong e-Mobility Service Mandatory Consent Items: - Subscriber Information: Name, mobile phone number, address (residential or workplace), email address, ID, password. Optional Consent Items: - When Using Paid Services: Card company name, card number, card expiration date, first 2 digits of the password (collected in encrypted form), mobile phone number, carrier information, bank name, and account information, etc. Payment records.
   Daedong Mobility Telematics Service:	Mandatory Consent Items - Subscriber Information: Name, mobile phone number, address (residential or workplace), email address, ID, password. Optional Consent Items: - When Using Paid Services: Card company name, card number, card expiration date, first 2 digits of the password (collected in encrypted form), mobile phone number, carrier information, bank name, and account information, etc. Payment records.

2. Additional Services Application and Usage Information:
3. When users apply for and use additional services, information provided directly by users on forms may be collected after separate notification and consent. Additionally, during the user's service usage or business processing, the following information may be additionally collected:
   1. Use of Wire or Online Consultation Services: Consultation records (service usage history, recordings of wire and online consultations, etc.)/li>
   2. Website and Mobile Service Usage: Device and environment information during website and mobile service usage (IP Address, cookies, visit timestamps, device information, etc.)
4. In the event of an accident, the company may use sensor devices installed in mobility products to capture and record driving videos of the mobility product (including during stops) for prompt accident investigation and resolution.

3. [Collection Methods of Personal Information:]

The company collects personal information through the following methods:

1. Consent during membership registration and service usage process through the website and mobile services.
2. Consent during the use of wire or online consultation services.
3. Consent during event participation, prize redemption, and delivery requests.
4. Consent within the agreed scope through automated collection tools within the range of consent received from members.

4. [Retention and Use Period of Personal Information]

The company retains and uses the collected personal information during the period the user maintains membership. Upon withdrawal or loss of qualification, the collected member information is deleted and destroyed, unless there is a separate request from the user.

• Internal Policy for Information Retention:
  1. Restriction on rejoining for users with access restriction and fraudulent use: 1 year after service termination (except when specific regulations in related laws are specified).
  2. Record of withdrawn members to restrict rejoining: 3 months.
  3. Mobility usage history information and personal location information: Until the purpose of collection/use is achieved or consent is withdrawn.
  4. Uncompleted payment records: Until payment and settlement are completed.
  5. Handling customer complaints/disputes: Until resolution.

• Retention Based on Relevant Laws:
  1. Records related to e-commerce transactions and contracts under the "Act on Consumer Protection in Electronic Commerce, etc.": 5 years.
  2. Records related to withdrawal of contract or subscription: 5 years.
  3. Records related to payment and supply of goods: 5 years.
  4. Records related to consumer complaints or dispute resolution: 3 years.
  5. Records related to advertising: 6 months.
  6. Records related to the company's business ledger, important documents, and receipts related to business operations under the "Commercial Act."

5. [Right to Refuse Consent and Consequences of Refusal]

Users have the right to refuse consent for the collection and use of personal information. However, refusal to consent to essential personal information collection and use necessary for contract formation may render the service unavailable. Additionally, refusal to consent to the collection and use of personal information for marketing and promotional activities may result in the user not receiving information about events and benefits, as well as the unavailability of gifts, promotional items, and affiliated services.

6: [Purpose and Retention Period of Personal Location Information]

The company will promptly destroy the collected personal location information when the purpose of collection, use, or provision is achieved, or when the user partially or fully withdraws their consent. However, if there is a legal obligation to retain the information, it will be retained according to the relevant laws.

7. [Procedure and Method of Destruction of Personal Information and Personal Location Information]

1. The company will generally destroy personal information once the purpose of collection and use is fulfilled. If there is a legal obligation to retain personal information, it will be destroyed in an irreversible manner after the required period has elapsed. The company's procedure for the destruction of personal information is as follows:
   1. Procedure for Personal Information Destruction: Information entered by the user and collected by the company is transferred to a separate database after the purpose of collection and use is achieved. It is then stored according to internal regulations and relevant laws for a certain period or immediately destroyed. The transferred personal information will not be used for other purposes.
   2. Period for Retention of Personal Information: When the retention period of personal information has expired, or when the information is no longer needed for the purpose, it is deemed unnecessary, and the company will destroy it within 5 business days unless there are justifiable reasons.
   3. Method of Personal Information Destruction: Electronic files are destroyed using technical methods such as low-level formatting and wiping, making recovery and regeneration impossible. Personal information on paper is destroyed by shredding or incineration.
2. For the destruction of personal location information under the "Location Information Law" Article 24, Paragraph 4, when a member partially or fully withdraws consent, the company will promptly destroy the collected personal location information and related confirmation records. The destruction procedure and method will follow the provisions in the first paragraph.

8. [Refusal of Automatically Collected Personal Information]

The company installs and operates cookies to provide customized services for members. The purposes and details of refusing cookies are as follows:

1. Cookies: These are very small text files sent by the server operating the website to the member's browser, stored on their computer or mobile phone for operation.
2. Purposes of Using Cookies: Cookies are used to manage member access, provide individual user environments, understand user activity information, and analyze event and promotion statistics to offer optimized customized services.
3. Installation, Operation, and Refusal of Cookies: Members have the option to choose regarding cookie installation while using facilities. Members can set options in web browsers to allow all cookies, confirm each time a cookie is stored, or refuse the storage of all cookies. However, refusing cookie installation may cause difficulties in using some services that require login. The methods to specify cookie installation preferences are as follows:
   1. Internet Explorer Web Browser: [Settings] in the upper right menu > [Internet Options] > [Privacy] > [Advanced] > Set [Cookies from the current site].
   2. Chrome Web Browser: [Settings] in the upper right menu > [Site settings] > [Cookies] settings.
   3. Safari Web Browser: [Settings] > [Safari] > [Block all cookies] settings.

9. [Rights of Users and Methods of Exercise]

1. Users can access or modify their registered personal information at any time. If users do not agree with the processing of personal information by the company, they have the right to refuse consent or request withdrawal (membership withdrawal).
2. If a user requests correction of personal information errors, the company will not use or provide the information until the correction is completed. Additionally, if incorrect personal information has already been provided to a third party, the correction results will be promptly notified to the third party to ensure correction.
3. The company handles deleted personal information requested by users in accordance with the provisions of Article 7 and ensures that it cannot be accessed or used for other purposes.

10. [Third-Party Provision of Collected Personal Information]

1. The company utilizes the collected personal information of members, obtained with prior consent, within the scope notified in Article 1 and provides it to third parties (details are specified in paragraph 4). Without the prior consent of the user, the company will not exceed the agreed-upon scope of consent or provide it to third parties. However, exceptions are made in the following cases:
   1. When the user has given prior consent for third-party provision.
   2. When required by law, or when law enforcement or supervisory authorities request it through the procedures and methods specified by law for investigative or inquiry purposes.
   3. When necessary for statistical compilation, academic research, or market research, providing the information in a form that does not identify specific individuals.
2. In cases where the provision of personal information to a third party is necessary for better service provision, the company specifies in advance the third party receiving the personal information, the purpose of using the personal information by the third party, the items of personal information provided, the period of retention and use of the personal information by the third party, and the right to refuse information provision and any resulting disadvantages. The company seeks the user's consent after providing this information.
3. However, if a third party that has received personal information needs to retain and use information for internal reporting, auditing, investigation, dispute resolution, or any other necessary purposes, the information may be retained and used until the completion of performance or resolution of the dispute. If there are special provisions in related laws, the information may be retained in accordance with those provisions.
4. The company does not provide personal information to third parties without the user's consent.
5. Users have the right to refuse consent for the company to provide personal information to third parties. However, if the user refuses to provide the minimum necessary personal information for contract execution, services may be unavailable, and there may be disadvantages such as delays in handling mobility accident procedures.

11. [Handling of Personal Information Outsourcing]

1. The company entrusts part of the essential tasks necessary for service provision to external companies. The entrusted companies (outsourcers) are contractually obligated to handle personal information securely in accordance with personal information laws, including prohibiting processing personal information for purposes other than outsourcing, implementing technical and managerial protective measures, restricting re-outsourcing, and managing and supervising outsourcers.
2. The details of tasks outsourced for service provision, as required under Article 26, Paragraph 2 of the Personal Information Protection Act, are disclosed through this privacy policy, and any changes in the content of outsourced tasks or outsourcing companies are promptly disclosed through this privacy policy.
3. The company outsources the following tasks for the fulfillment of service provision agreements and the enhancement of user convenience.

12. [Measures to Ensure the Security of Personal Information]

In accordance with Article 29 of the Personal Information Protection Act, the company takes the following technical, administrative, and physical measures to ensure security:

1. Regular Internal Audits: Conduct regular internal audits to secure the handling of personal information.
2. Minimization and Education of Personnel: Designate specific personnel to handle personal information and limit access to them, minimizing the exposure of personal information. Provide education and training to personnel handling personal information.
3. Establishment and Implementation of Internal Management Plans: Develop and implement internal management plans to ensure the secure processing of personal information.
4. Technical Measures Against Hacking: Install security programs to prevent leakage and damage of personal information due to hacking, computer viruses, etc. Regularly update and check these programs. Use controlled access areas with monitoring and blocking systems to prevent unauthorized access.
5. Encryption of Personal Information: Store and manage personal information in encrypted form, ensuring that only the individual can access it. Use additional security features such as file encryption or file locking for important data.
6. Preservation and Prevention of Tampering of Access Records: Preserve access records to the personal information processing system according to legal requirements. Use security features to prevent tampering, theft, or loss of access records.
7. Restriction of Access to Personal Information Processing Systems: Control access to the database system handling personal information by granting, changing, or revoking access rights. Utilize intrusion prevention systems to control unauthorized access from external sources.
8. Use of Locking Devices for Document Security: Store documents containing personal information, auxiliary storage media, etc., in secure locations equipped with locking devices.
9. Access Control for Unauthorized Individuals: Establish and operate access control procedures for physical storage locations containing personal information, limiting access to authorized personnel only.

13. [Basis and Period for Retaining Confirmation Documents of Location Information Collection, Use, and Provision]

1. he company automatically records confirmation documents of location information collection, use, and provision in the location information system based on Article 16, Paragraph 2 of the Location Information Act. The company retains these confirmation documents for five years from the recording date for member complaint handling and other purposes.
2. If a member withdraws all or part of their consent, the company promptly destroys the collected personal location information and confirmation documents of location information collection, use, and provision, except in cases where separate consent has been obtained or when retention is necessary for handling ongoing or anticipated member complaints, compliance with tax laws, or other legal obligations.

14. [Third-Party Provision of Personal Location Information]

1. The company processes a member's personal location information only within the scope specified in Article 1 and provides it to third parties only with the member's consent, legal requirements, or special provisions under Article 17 and Article 18 of the Personal Information Protection Act, and Article 19 and Article 21 of the Location Information Act.
2. When providing a member's personal location information to a third party designated by the member, the company immediately notifies the member of the recipient, the date and purpose of the provision, through the communication terminal device through which the personal location information was provided. However, in the following cases, the company notifies the member in advance through the communication terminal device or email specified by the member:
   1. The communication terminal device through which the personal location information was collected does not have the capability to receive text, voice, or video.
   2. The member has previously requested notification through a communication terminal device or email other than the one used to collect personal location information.
3. Notwithstanding the provisions of Paragraph 2, if the member has agreed, the company may collect and notify the member of information provision records at intervals of up to 30 days, within a maximum range of 10 times, 20 times, or 30 times, and within a period of 10 days, 20 days, or 30 days.

15. [Rights and Obligations of Guardian for the Protection of Children Under 8 Years of Age in the Collection of Personal Location Information and Methods of Exercising]

1. If any of the following persons (hereinafter "guardian for the protection of children under 8 years of age") agrees to the collection, use, and provision of personal location information of a child under 8 years of age for the protection of the child's life or body, it is considered that the consent is given with the guardian's approval:
   1. Child under 8 years of age
   2. Guardian under limited guardianship
   3. Individuals with severe disabilities under the provision of Article 2, Paragraph 2, Item 2 of the Act on Welfare of Persons with Disabilities, corresponding to severe disabilities under the provision of Article 2, Paragraph 2, Item 2 of the Act on Promotion of the Employment and Vocational Rehabilitation of Disabled Persons (Limited to those registered as disabled under Article 32 of the Act on Welfare of Persons with Disabilities)
2. The guardian for the protection of children under 8 years of age refers to someone practically protecting a child under 8 years of age and includes one of the following:
   1. Legal guardian of a child under 8 years of age or a guardian under Article 3 of the Act on Guardianship of Minors in Protective Facilities
   2. Legal guardian of a guardian under limited guardianship
   3. Legal guardian of an individual under Article 58, Paragraph 1, Item 1 of the Act on Welfare of Persons with Disabilities, in charge of a residence facility for disabled persons (limited to facilities installed and operated by the state or local governments), the head of a mental health facility under Article 22 of the Act on the Promotion of Mental Health and the Management of Mental Illness Welfare Services or the head of a mental rehabilitation facility under Article 26 of the same Act (limited to facilities installed and operated by the state or local governments)
3. If a guardian for the protection of a child under 8 years of age wishes to consent to the collection, use, and provision of personal location information for the protection of the child's life or body, they must complete and submit a written consent form to the company. The form should include the following details and be signed or stamped by the guardian:
   1. Child's name, address, and date of birth
   2. Guardian's name, address, and contact information
   3. Statement that the purpose of collecting, using, or providing personal location information is limited to the protection of the child's life or body
   4. Date of consent
4. If a guardian for the protection of a child under 8 years of age gives consent to the collection, use, and provision of personal location information, the member (personal location information subject) is considered the guardian for the protection of the child under 8 years of age. The member can exercise their rights under Article 24 of the Location Information Act. The rights, obligations, and methods of exercising them as a member are in accordance with this clause

16. [Department and Person in Charge of Personal Information and Personal Location Information Protection Work]

The company designates the following department and person in charge to protect users' personal information and personal location information and handle related complaints. Users can report any complaints related to the protection of personal information and personal location information to the person in charge or the relevant department of the company. The company will promptly provide sufficient answers to the reported issues.

[Department in Charge of Personal Information and Personal Location Information Protection Work]

Department: Daedong Mobility Platform Strategy Team

Contact: 02-2270-7824

Email: jungsan005@daedongmobility.co.kr

[Person in Charge of Personal Information and Personal Location Information Protection]

Name: Kim Sunmu

Contact: 02-2270-7824

Email: jungsan005@daedongmobility.co.kr

17. [Revision and Notification of Privacy Policy]

1. This privacy policy is made publicly available on the homepage so that members and users can view it at any time. In the event of additions, deletions, or modifications to the content of the privacy policy, the company will announce the changed privacy policy, including the reasons for the changes, on the homepage and mobile application at least 7 days before implementing the changes. The content of this privacy policy may change at any time, so please check it when visiting the homepage or mobile application.
2. This privacy policy applies to all online services provided by the company, including mobile websites and applications. However, individual services may have separate privacy policies. Separate privacy policies for such individual services will be announced on the homepage and mobile application.

Supplementary Provision

• Article 1 (Effective Date): This policy is effective from November 30, 2023.