SMTOWN TRAVEL PRIVACY POLICY

We, at the ‘S.M. C&C Global Package’ (http://global.smtowntravel.com/ hereinafter referred to as the 'Company' or ‘Global Package’) handle all personal information in relation to the services offered under ‘S.M. C&C’ as follows.

This Privacy Policy (the "Policy") explains the way of treatment of the information which is provided or collected in the websites on which this Policy is posted. In addition the Policy also explains the information which is provided or collected in the course of using the applications of the Company which exist in the websites or platforms of other company.

Through this Policy, the Company regards personal information of the users as important and inform them of the purpose and method of Company's using the personal information provided by the users and the measures taken by the Company for protection of those personal information.

This Policy will be effective on the 18th day of April, 2017 and, in case of modification thereof, the Company will make public notice of it through posting it on the bulletin board of Company's website or individual notice through sending mails, fax or e-mails).

1. Information to be collected and method of collection

1. Personal information items to be collected
   Personal information items to be collected by the Company are as follows:
2. Information provided by the users
   The Company may collect the information directly provided by the users.
3. Items to be collected
   - Name
   - Email address
   - ID
   - Password
   - Telephone number
   - Sex
   - National information
   - Birth date
4. Method of collection
   - Webpage, written form, fax, telephone calling, e-mailing, tools for collection of created information
   - Provided by partner companies

2. Use of collected information

The Company uses the collected information of users for the following purposes:
- Member management and identification
- To detect and deter unauthorized or fraudulent use of or abuse of the Service
- Performance of contract and service fee settlement regarding provision of services demanded by the users
- Improvement of existing services and development of new services
- Making notice of function of company sites or applications or matters on policy change
- To help you connect with other users you already know and, with your permission, allow other users to connect with you
- To make statistics on member’s service usage, to provide services and place advertisements based on statistical characteristics
- To provide information on promotional events as well as opportunity to participate
- To comply with applicable laws or legal obligation
- Use of information with prior consent of the users (for example, utilization of marketing advertisement)

The Company agrees that it will obtain consent from the users, if the Company desires to use the information other than those expressly stated in this Policy.

3. Sharing collected information

Except for the following cases, the Company will not share personal information with a 3rd party:

When the Company shares the information with its affiliates, partners and service providers;

Sharing of collected information
- When the Company's affiliates, partners and service providers carry out services such as bill payment, execution of orders, products delivery and dispute resolution (including disputes on payment and delivery) for and on behalf of the Company

When the users consent the sharing in advance;

Sharing of collected information
- when the user selects to be provided by the information of products and services of certain companies by sharing his or her personal information with those companies
- when the user selects to allow his or her personal information to be shared with the sites or platform of other companies such as social networking sites
- other cases where the user gives prior consent for sharing his or her personal information

When the sharing is required by the laws
- if required to be disclosed by the laws and regulations; or
- if required to be disclosed by the investigative agencies for detecting crimes in accordance with the procedure and method s prescribed in the laws and regulations

4. Cookies, Beacons and Similar Technologies

The Company may collect collective and impersonal information through 'cookies' or 'web beacons'.
Cookies are very small text files to be sent to the browser of the users by the server used for operation of the websites of the Company and will be stored in hard-disks of the users' computer.
Web beacon is a small quantity of code which exists on the websites and e-mails. By using web beacons, we may know whether a user has interacted with certain webs or the contents of email.
These functions are used for evaluating, improving services and setting-up users' experiences so that much improved services can be provided by the Company to the users
The items of cookies to be collected by the Company and the purpose of such collection are as follows:

Collecting cookies

Strictly necessary cookies
This cookie is a kind of indispensable cookie for the users to use the functions of website of the Company. Unless the users allow this cookie, the services such as shopping cart or electronic bill payment cannot be provided. This cookie does not collect any information which may be used for marketing or memorizing the sites visited by the users
- Memorize the information entered in an order form while searching other pages during web browser session
- For the page of products and check-out, memorize ordered services
- Check whether login is made on website
- Check whether the users are connected with correct services of the website of the Company while the Company changes the way of operating its website
- Connect the users with certain application or server of the services

Performance cookies
This cookie collects information how the users use the website of the Company such as the information of the pages which are visited by the users most. This data helps the Company to optimize its website so that the users can search that website more comfortably. This cookie does not collect any information of the users. Any and all the information collected by this cookie will be processed collectively and the anonymity will be guaranteed.
- Web analysis: provide statistical data on the ways of using website
- Advertisement response fee: check the effect of advertisement of the Company
- Tracing affiliated companies; one of visitors of the Company provides anonymously feedback to the affiliated companies
- Management of error: measure an error which may occur so as to give a help for improving website
- Design testing: test other design of the website of Company

Functionality cookies
This cookie is used for memorizing the set-ups so that the Company provides services and improves visit of users. Any information collected by this cookie does not identify the users individually.
- Memorize set-ups applied such as layout, text size, basic set-up and colors
- Memorize when the customer respond to a survey conducted by the Company

Cookies or advertising cookies
This cookie is connected with the services provided by a 3rd party such as the buttons of 'good' and 'share'. The 3rd party provides these services by recognizing that the users visit the website of the Company.
- carry out PR to the users as targets in other websites by connecting through social networks and these networks use the information of users' visit
- provide the information of users' visit to ad agencies so that they can suggest an ad which may attract the interest of the users

The users have an option for cookie installation. So, they may either allow all cookies by setting option in web browser, make each cookie checked whenever it is saved, or refuses all cookies to be saved: Provided that, if the user rejects the installation of cookies, it may be difficult for that user to use the parts of services provided by the Company.

5. Users' right to access and option

The users or their legal representatives, as main agents of the information, may exercise the following options regarding the collection, use and sharing of personal information by the Company:

- exercise right to access to personal information;
- make corrections or deletion;
- make temporary suspension of treatment of personal information; or
- request the withdrawal of their consent provided before

If, in order to exercise the above options, you, as an user, use the menu of 'amendment of member information of webpage or contact the Company by using representative telephone or sending a document or e-mails, or using telephone to the responsible department (or person in charge of management of personal information), the Company will take measures without delay: Provided that the Company may reject the request of you only to the extent that there exists either proper cause as prescribed in the laws or equivalent cause.

6. Security

The Company regards the security of personal information of uses as very important. The company constructs the following security measures to protect the users' personal information from any unauthorized access, release, use or modification

Security measures
Encryption of personal information
- Transmit users' personal information by using encrypted communication zone
- Store important information such as passwords after encrypting it
- Countermeasures against hacking
- Install a system in the zone the external access to which is controlled so as to prevent leakage or damage of users' personal information by hacking or computer virus
- Establish and execute internal management plan
- Install and operate access control system
- Take measures to prevent forging or alteration of access record

7. Protection of personal information of children

In principle, the Company does not collect any information from the children under 13 or equivalent minimum age as prescribed in the laws in relevant jurisdiction. The website, products and services of the Company are the ones to be provided to ordinary people, in principle. The website or application of the Company has function to do age limit so that children cannot use it and the Company does not intentionally collect any personal information from children through that function.

(Additional procedure for collecting personal information from children) However, if the Company collects any personal information from children under 13 or equivalent minimum age as prescribed in the laws in relevant jurisdiction for the services for unavoidable reason, the Company will go through the additional procedure of the followings for protecting that personal information of children:
- obtain consent from the parents or guardian of children so as to collect personal information of children or directly send the information of products and services of the Company
- give the parents or guardian of children a notice of Company's policy of privacy protection for children including the items, purpose and sharing of personal information collected
- grant to legal representatives of children a right to access to personal information of that children/correction or deletion of personal information/temporary suspension of treatment of personal information/ and request for withdrawal of their consent provided before
- limit the amount of personal information exceeding those necessary for participation in online activities

8. Modification of Privacy Protection Policy

The Company has the right to amend or modify this Policy from time to time and, in such case, the Company will make a public notice of it through bulletin board of its website (or through individual notice such as written document, fax or e-mail) and obtain consent from the users if required by relevant laws.

9. Commission for collected personal information

For carrying out services, the Company commissions external professional companies (subcontractors) to process personal information as follows. This commissioned works for processing personal information is carried out by each subcontractor and service only if necessary for providing that service.

In commissioning process of personal information, in order to secure safety of personal information , the Company supervises and ensure to expressly state in the agreement with subcontractors so that those subcontractors will safely process personal information by strictly complying with directions regarding personal information protection, keeping personal information secret, not disclosing it to a 3rd party and being liable for accidents and returning or destructing personal information upon termination of the commission or process.

Name of subcontractors	Description of commissioned works (services)
CJ E&M	confirm ticket
Hotels View all List	confirm reservation
Local Travel Agency View all List	confirm reservation

Details of provision of personal information to 3rd party
Except for the following cases, the Company does not disclose or provide personal information of the users to a 3rd party:

Recipients of information	Purpose of use of recipient	Items to be provided	Period of retention and use of recipient
CJ E&M	confirm ticket	Name	Until the date when the purpose of use is achieved or period as required by the laws
Hotels View all List	confirm reservation	Name, Sex	Until the date when the purpose of use is achieved or period as
Local Travel Agency View all List	confirm reservation	Name, Sex	Until the date when the purpose of use is achieved or period as

10. Period for retention and use of personal information

In principle, the Company destructs personal information of users without delay when: the purpose of its collection and use has been achieved; the legal or management needs are satisfied; or users request: Provided that, if it is required to retain the information by relevant laws and regulations, the Company will retain member information for certain period as designated by relevant laws and regulations. The information to be retained as required by relevant laws and regulations are as follows:

- Record regarding contract or withdrawal of subscription: 5 years (The Act on Consumer Protection in Electronic Commerce)
- Record on payment and supply of goods: 5 years (The Act on Consumer Protection in Electronic Commerce)
- Record on consumer complaint or dispute treatment: 3 years (The Act on Consumer Protection in Electronic Commerce)
- Record on collection/process, and use of credit information: 3 years (The Act on Use and Protection of Credit Information)
- Record on sign/advertisement: 6 months(The Act on Consumer Protection in Electronic Commerce)
- Log record of users such as internet/data detecting the place of user connection: 3 months (The Protection of Communications Secrets Act)
- Other data for checking communication facts: 12 months (The Protection of Communications Secrets Act)

11. Procedure and method of destruction of personal information

In principle, the Company destructs the information immediately after the purposes of its collection and use have been achieved without delay: Provided that, if any information is to be retained as required by relevant laws and regulations, the Company retain it for the period as required by those laws and regulations before destruction and, in such event, the personal information which is stored and managed separately will never be used for other purposes. The Company destructs: hard copies of personal information by shredding with a pulverizer or incinerating it; and delete personal information stored in the form of electric file by using technological method making that information not restored.

12. Establishing and Operating Information Protection System

We establish and operate proper security systems in order to safely manage your information. Important information such as your password is stored in an encrypted format.
Technical, managerial and physical measures for protection of personal information In order to prevent the loss, theft, leakage, alteration or damage of personal information of the users, the Company takes technical, managerial and physical measures for securing safety as follows:

Technical measures
- Utilize security servers for transmitting encryption of personal information
- Take measures of encryption for confidential information
- Install and operate access control devices and equipments
- Establish and execute internal management plan

Managerial measures
- Appoint a staff responsible for protecting personal information
- Provide education and training for staffs treating personal information
- Establish and execute internal management plan
- Establish rules for writing passwords which is hard to be estimated
- Ensure safe storage of record of access to personal information processing system
- Classify the level of authority to access to personal information processing system

Physical measures
- Establish and operate the procedure for access control for the facilities for storing personal information
- Store documents and backing storage containing personal information in safe places which have locking device

13. Staff responsible for managing personal information

The staff of the Company responsible for managing personal information is as follows:
Name of staff responsible for managing personal information : Hwang, Doohyun
Dept. : S.M. C&C
Tel. : +82-2-6240-9360
Contact : travel@smtown.com
The date of latest update:April, 2017