1. General Provisions
PARON TECH Co., Ltd. (hereinafter referred to as “Company”) is dedicated to protecting the confidentiality
 and privacy of information that the users provided to http://swing.parongolf.com or
 http://www.paronscreen.com (hereinafter referred to as “Website”) as part of the registration process for
 using our services on the Website (hereinafter referred to as “Services”).

 As a part of this fundamental obligation, the Company is committed to taking all necessary precautions 
 and measures for appropriate protection and use of personal information that has been collected through
 the Website. 

The Company exercises due care to protect personal information of the users in accordance with relevant laws 
 and regulations such as the Protection of Communications Secrets Act and the Act on the Protection of 
Personal Information.

This Privacy Policy is to inform our users of how we collect and use their personal information and how
 we protect their personal information.

This Privacy Policy may be amended from time to time to reflect changes in relevant laws and regulations
 and internal policy of the Company.

 
2. Information to be Collected and Method of Collection

a) Personal information items that will be collected: Users need to provide essential information to use 
the basic services and optional information to use the specific services meeting their needs.

(1) Information to be collected when signing up:

1) For general membership:
Essential information: name, ID, password, mobile phone number and physical address, email address, nickname,
 duplicate check values and questions and answers for identification

(2) Information necessary for notification of winning gifts and delivery of such gifts
Name, postal code, physical address, contact information and mobile phone number of the recipient

(3) While using Services, the following information may be automatically generated and collected:
IP address, cookies, visit time, service use records, faulty use records, payment records, etc.


b) Method of collection: The Company collects personal information as follows:
Collected from website, written form, facsimile, phone, bulletin board, email, application for events and
 request for delivery

Information provided by clients at offline stores of PARON TECH Co., Ltd. 
Collected by generation tools
  
3. Purposes of Collection and Use

Personal identification for membership services:
ID, password, name, birthdate, etc.

Delivery of goods, billing, delivery of gifts and notification for purchasing:
Name, physical address, phone number, etc.

Notification, confirmation of individual opinions, securing communication channels for complaint handling or
 other reasons, marketing including announcements of events, information such as new services and products: 
mobile phone number, etc.

Delegation of providing information on behalf of the offline stores that the members visited
Mobile phone number, nickname, gender, birthdate, visiting frequency, etc.
Data for providing customized services
Other optional items
 
4. Retention and Use Period of Personal Information Collected by the Company
The Company may retain and use personal information of members to provide Services as long as members
 continue to use the Services. 

However, such personal information will be removed when users wish to delete their personal information
 or request to withdraw their membership from the Company.

Further, the Company shall immediately discard personal information once the temporary purpose of
 collecting such information (survey, event, identification, etc.) is fulfilled.

However, the Company may retain personal information of users whose membership was withdrawn due to false 
use of Services.

Such information shall be retained for 1 year from the date of withdrawal, and posts or other contents
 that those members disclosed while using the Services will be immediately deleted upon their request.

In addition to this, the Company may also retain the following personal information of users where such
 retention is deemed necessary according to relevant laws and regulations as follows:

Records related to contract or withdrawal:
Reason: Act on the Consumer Protection in Electronic Commerce, etc.

Retention Period: 5 years
Records related to payment and supply of goods:
Reason: Act on the Consumer Protection in Electronic Commerce, etc.
Retention Period: 5 years
Records related to consumer complaints and dispute handling:
Reason: Act on the Consumer Protection in Electronic Commerce, etc.
Retention Period: 3 years

Records related to indications and advertising:
Reason: Act on the Consumer Protection in Electronic Commerce, etc.
Retention Period: 6 months
Records related to personal identification:
Reason: Act on Promotion of Information and Communications Network Utilization and Information
 Protection, etc.
Retention Period: 6 months
Records related to visits:
Reason: Protection of Communications Secrets Act
Retention Period: 3 months

 
5.개인정보 파기절차 및 방법
Disposal Procedure and Method of Disposing Personal Information
The Company shall immediately discard personal information once its purpose of collecting and using such
 information is fulfilled or the period of retention and use expires.

The Company shall discard personal information as follows:

a) Disposal procedure
The Company retains information that users provided for singing up and discards such information once
 its purpose of collecting and usage of such information is fulfilled and the retention period based on
 the Company’s internal policy and relevant laws and regulations (see retention and use period) expires.

The Company does not use such information for purposes other than the ones specified by the relevant laws
 and regulations.

b) Method of disposal
Company crushes with shredder or incinerates documented personal information.
Company deletes personal information in electronic format.
 
6. Sharing and Provision of Personal Information Collected by the Company
The Company uses personal information within the range notified to users and does not use and,
 in principle, transfer such information to any third party to an extent exceeding the specified range.
 However, the following cases will be exceptions:

Where the users agree to disclosure of their personal information in advance;

Where the users violate the Terms and Conditions, other terms and operational principles that pertain to the
 use of Services;

Where the Company reasonably believes that such personal information should be disclosed in order to assist
 in legal actions against mental and physical damages caused by the users;

Where the judicial authority requests disclosure of such information based on relevant laws and regulations
 or in accordance with procedures and methods specified in the laws and regulations for investigation;

Where the Company provides such information without personal identification for the purposes of statistical
 documents, academic researches or market researches;

Where the Company provides such information to relevant service providers in order to process complaints or
 appeals raised by the users;

Where the Company provides such information including user ID, nickname, gender, tee, name, contact
 information and last visit date to offline stores that the users visit;

Where the Company provides such information including shipping information (name, physical address and phone
 number) to courier service providers in order to deliver products purchased by the users through Services;

Where the Company needs to transfer personal information due to transfer of businesses, it notifies
 the users of transfer of personal information in accordance with the relevant laws and regulations such as
 the Act on Promotion of Information and Communications Network Utilization and Information Protection, etc.
 and the users shall have the right to withdraw their agreement to transfer of their personal information.

The Company does not provide personal information of users to advertisers who display or send advertising
 messages to specific groups of users by gender, age or other conditions. It only provides personal
 information without identification of individuals for the purposes of statistical documents, academic
 researches or market researches.
  

Consignment of Processing Personal Information
The Company may consign external parties to process personal information of users for improved services.
 However, while doing this, the Company also specifies prohibition of disclosing personal information to
 any third party and liability for accidents due to disclosure of such information in accordance with
 the relevant laws and regulations for the safety of personal information under consignment.

Real name identification, individual identification, etc.
Delivery of gifts for various events, etc.
 
8. Management of Personal Information (Access, Modification and Deletion) by Users

Users or their legal representatives may gain access to or modify their personal information by using
 the Website and request to withdraw their membership from the Company at any time.
  
9. Withdrawal of Agreement to Collection, Use and Provision of Personal Information Users may also withdraw
 their agreement to collection, use and provision of personal information made while singing up at any time.
 
10. Matters Related to Cookies

The Company uses cookies that store and load personal information of users in order to provide customized
 services.

Cookies are a small packet of information that the server of Website sends to the browsers of users’ computers.

Sometimes, these cookies are stored in the hard disks of users’ computers. The Company uses these cookies in
 order to extract information related to their IDs for the purpose of providing better and more useful services.

The Company can identify specific computers by using cookies but not the specific users.

The Company can also provide more convenient services by identifying services of websites that the users
 visited and provide optimized services for each user.
 
Users may decide whether to enable cookies or not. They can configure options on their web browsers to let all
 cookies be made available, confirm every time cookies are stored or refuse to store cookies.

However, some of the services requiring cookies may not be available to those who refuse to store the cookies.
  
11. Measures to Protect Personal Information
Technical and Management Measures to Protect Personal Information
The Company pursues the following technical and management measures to keep personal information safe from
 loss, leak, alteration or damage while handling personal information of users:

Encrypted passwords
User passwords are stored and managed by one-way encryption in order to prevent their decryption. Thus,
 the users shall not accidentally pass on their passwords to hackers in the process of signing into the website.

In order for this measure to be fully effective, the Company recommends that users log out from their
 account on our website and shut down their web browsers after using computers.

In particular, when users share computers with others or use computers in public spaces (company, school,
 library or internet café), they will need the above mentioned measures to protect their personal information
 from leakage.

The Company is not responsible for any damages caused by leakage of personal information due to negligence
 of users or problems in network connections.

Measures against malicious actions such as hacking
The Company shall exercise due care to protect personal information of users from leakage or damage due to
 hacking or computer viruses.

The Company also performs data backup on a regular basis to prepare for damages to personal information;
 uses up-to-date vaccine programs to prevent leakage of or damage to personal information;
 and ensures safe transmission of personal information through networks by cryptographic communication.

In addition to this, the Company also controls unauthorized access to personal information by using access
 blocking systems and also uses other systems to ensure security at the system level through all possible
 technical means.

Minimized number of personnel for handling personal information and training

Employees of the Company handling personal information are limited to the ones who are responsible for
 such duty. 

These employees are obliged to renew password on a regular basis. The Company also provides training to
 these personnel from time to time in order to emphasize the importance of complying with the Privacy Policy.

 
12. Transmission of Advertising Information
The Company does not transmit advertising information for commercial purposes to those who expressly
 refuse to receive such information.

The Company sends advertising information to those who agreed to receive such information via email with
 clearly indicated titles and contents so that they can easily identify it as advertising information.
 
Title of the email: The Company may not indicate an email message as advertising in its title but
 in the contents of the message.

Contents of the email: The Company clearly indicates the name, email address and phone number of the
 sender so that the users can easily express their refusal to receive such information.


The contents of the email are as follows:
Name of the sender: PARON Screen
Email address: sales@parongolf.com
Physical address: 4F Cheongwoo Bldg., 257, Digital-ro, Guro-gu
Phone number: 1666-0753

Where the Company sends advertising information for commercial purposes via facsimile or mobile phone
 messages other than emails, it indicates the wording ‘advertising’ at the beginning of the messages
 and includes contact information of the sender in the contents.
  

13. Contact Information of the Privacy Manager and Personnel Responsible for Personal Information:
The Company assigns a separate privacy manager and personnel who are responsible for personal information
 so that it can process appeals and complaints related to protection of personal information in a timely
 and prompt manner.

If you want to report or seek advice with respect to infringements of personal information, please contact
 the following organizations:

Korea Internet Security Center (www.118.or.kr / 118)

ePRIVACY Mark Certification Committee (www.eprivacy.or.kr / 02-580-0533~4)

High-Tech and Financial Crimes Investigation Division, Supreme Prosecutors’ Office (http://www.spo.go.kr /
 02-3480-2000)

Cyber Terror Response Center, National Police Agency (www.ctrc.go.kr / 02-392-0330)
  
14. Revisions

The Company will notify amendments to Privacy Policy at the ‘Notice’ section on the Website at least
 seven days prior to their application date.
Date of notification: August 01, 2009
Date of commencement: August 01, 2009

Phone: 1666-0753
Department: Domestic Business Division
Email: Sales@parongolf.com
Privacy Manager