('halo' hereafter 'halo') processes personal information for the following purposes. The personal information being processed will not be used for any purpose other than the following, and if the purpose of use is changed, necessary measures such as obtaining separate consent in accordance with Article 18 of the 「Personal Information Protection Act」 will be implemented.
1. Handling civil complaints
We process personal information for the purpose of checking complaints.

① The Company processes and retains personal information within the period of retention and use of personal information in accordance with laws and regulations or within the period of retention and use of personal information agreed upon when collecting personal information from the information subject.
② Each personal information processing and retention period is as follows.
1.Processing of civil complaints Personal information related to handling of civil complaints is retained and used for the above purpose from the date of consent for collection and use to destruction without delay. Retention Basis: Consumer Protection Relevant laws: Records on collection/processing and use of credit information: 3 years

① The company processes personal information only within the scope specified in Article 1 (Purpose of processing personal information), and applies to Articles 17 and 18 of the 「Personal Information Protection Act」 such as the consent of the information subject and special provisions of the law. We provide personal information to third parties only when
② The company is providing personal information to third parties as follows.
Persons receiving personal information: halo
Purpose of use of personal information provided by the recipient: e-mail, mobile phone number, name
Retention and use period of the recipient: Destroy without delay

① For smooth personal information processing, the company entrusts the following personal information processing tasks.
② When the consignment contract is concluded, according to Article 26 of the 「Personal Information Protection Act」, the company is not responsible for the prohibition of processing of personal information other than the purpose of performing the consignment, technical and administrative protection measures, restrictions on re-entrustment, management and supervision of the trustee, compensation for damages Matters related to this are specified in documents such as contracts, and we supervise whether the trustee handles personal information safely.
③ If the contents of the consignment work or the trustee is changed, we will disclose it through this personal information processing policy without delay.

① The information subject can exercise the right to view, correct, delete, and suspend processing of personal information at any time with respect to halo.
② The exercise of rights pursuant to Paragraph 1 can be done in writing, e-mail, fax, etc. in accordance with Article 41 Paragraph 1 of the Enforcement Decree of the 「Personal Information Protection Act」 for halo, and halo will respond without delay I will take action.
③ The exercise of rights pursuant to Paragraph 1 may be done through an agent such as a legal representative of the information subject or a person who has been delegated. In this case, “Personal Information Processing Method Notice (No. 2020-7)” Attached Form No. 11 A power of attorney must be submitted.
④ The rights of the information subject may be restricted in accordance with Articles 35 (4) and 37 (2) of the 「Personal Information Protection Act」.
⑤ Request for correction and deletion of personal information cannot be requested if the personal information is specified as a collection target in other laws.
⑥ halo confirms whether the person who made the request, such as the request for reading, correction or deletion, request for suspension of processing, etc. is the person or a legitimate agent according to the rights of the information subject.

① is handling the following personal information items.

① When personal information becomes unnecessary, such as the elapse of the personal information retention period and achievement of the processing purpose, the company destroys the personal information without delay.
② If the personal information retention period agreed by the information subject has elapsed or the personal information has to be kept in accordance with other laws despite the achievement of the purpose of processing, move the personal information to a separate database (DB) or change the storage location Conserve otherwise.
1. Legal basis:
2. Items of personal information to be preserved: account information, transaction date
③ The procedure and method of personal information destruction are as follows.
1. Destruction procedure
The company selects the personal information for which the reason for destruction occurred, and destroys the personal information with the approval of the person in charge of personal information protection.

is taking the following measures to ensure the safety of personal information.
1. Establishment and implementation of internal management plan
We have established and implemented an internal management plan for safe handling of personal information.
2. Restricting access to personal information
We take necessary measures to control access to personal information by granting, changing, and canceling access rights to the database system that processes personal information, and use an intrusion prevention system to control unauthorized access from outside.