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SBI Zodia Custody Co. (hereinafter referred to as the “Company”) recognizes the importance of the protection and proper management of personal information and complies with the Act on the Protection of Personal Information (hereinafter referred to as the “Personal Information Protection Act”), related laws, guidelines and other norms. In addition to complying with the Personal Information Protection Act, related laws, regulations, guidelines, and other standards, the Company will comply with the following privacy policy (hereinafter referred to as the “Policy”) to protect the personal information of customers. In addition, we will strive to appropriately handle and protect the personal information of our customers in accordance with the following privacy policy.

[Basic Policy]

• 1)The Company will comply with the Personal Information Protection Law and related laws, guidelines, and other norms, and strive to handle personal information appropriately. In addition, it will review and continuously improve this policy and system in response to developments in information technology and as necessary.
• 2)When acquiring personal information, the Company shall specify and notify or publicly announce the purpose of use, acquire personal information to the extent necessary for such purpose, and handle personal information in accordance with such purpose.
• 3)Personal information shall be obtained by legal and appropriate means.
• 4)In order to prevent leakage of personal information and use of personal information for other purposes, we will implement reasonable safety control and other measures and manage personal information appropriately.
• 5)Personal information obtained will not be provided to third parties without the prior consent of the subject of the information, except as required by law.
• 6)When outsourcing the handling of acquired personal information to a third party, we will enter into a contract with such third party and provide necessary and appropriate supervision of the third party in accordance with laws, guidelines, and other standards.
• 7)The Company will respond in good faith to requests for disclosure, correction, deletion, or cessation of use of personal information in our possession from the subject of said personal information.

[Definition of personal information]

“Personal information” is defined in the Personal Information Protection Law as information about a living individual that can be used to identify the specific individual by name, date of birth, or other description contained in the information (including information that can be easily cross-checked with other information and thereby used to identify the specific individual). (including information that can be easily matched with other information and thereby identify a specific individual).
The term “subject of information, etc.” shall mean a specific individual identified by personal information and a person who has the proper authority to provide personal information.

[Purpose of use of personal Information]

The Company will handle personal information to the extent necessary to achieve the following purposes.

• 1)To enter and execute contracts, charge fees, and manage other transactions.
• 2)To provide services, support and after-sales service, and to contact in case of emergency.
• 3)To respond to inquiries, send materials when requested, and send necessary forms.
• 4)To confirm the identity of an account at a financial institution and to confirm the transfer of funds to the designated financial institution account.
• 5)To improve and develop products and services handled by the Company and to conduct marketing activities.
• 6)To conduct surveys, analyze usage conditions and trends, and prepare statistical data.
• 7)To provide information on products, services, and various campaigns handled by the Company and its affiliates and partners.
• 8)To notify changes to the terms and conditions, policies, etc. (hereinafter referred to as “Terms and Conditions, etc.”) regarding our services.
• 9)To respond to any violation of laws, regulations, or terms and conditions in connection with our services.
• 10)To perform tasks required by related laws and regulations and other related tasks.
• 11)To achieve other purposes incidental to the above purposes.

[Change in the purpose of use of personal information]

The Company may change the purpose of use of personal information to the extent that it is reasonably deemed to be of considerable relevance.
The Company will notify customers or publicly announce any changes to the purposes of use of personal information.

[Restrictions on the use of personal information]

The Company will not handle personal information beyond the scope necessary to achieve the purpose of use without obtaining the consent of the subject of the information. However, this does not apply in the following cases

• 1)When required by law.
• 2)When it is particularly necessary for the protection of the life, body, or property of an individual and it is difficult to obtain the consent of the subject of the information, etc.
• 3)Cases in which the provision of personal information is particularly necessary for improving public health or promoting the sound growth of children and in which it is difficult to obtain the consent of the subject of the information, etc.
• 4)When it is necessary to cooperate with a national agency, a local government, or an individual or entity entrusted by either a national agency or local government to execute affairs prescribed by law, and obtaining the consent of the subject of information is likely to impede the execution of such affairs.

[Appropriate acquisition of personal information]

We will acquire personal information in a proper manner and will not acquire it through deception or other wrongful means.
Please be aware that if you or other information subjects refuse to provide your personal information, we may refuse to provide you with our services, or we may not be able to provide you with our services properly.

[Security management of personal information]

The Company will exercise necessary and appropriate supervision over our employees to ensure that personal information is managed safely against risks such as loss, destruction, falsification, and leakage of personal information. In addition, when the Company outsources all or part of the work related to the handling of personal information, it will provide necessary and appropriate supervision to ensure that the outsourced company manages the personal information safely.

[Provision to third parties]

The Company will not provide personal information to third parties without obtaining the prior consent of the subject of the information, except in cases where disclosure is permitted under personal information protection or other laws and regulations. However, the following cases do not fall under the provision of personal information to third parties as stipulated above.

• 1)When the Company outsources all or part of the handling of personal information within the scope necessary to achieve the purpose of use.
• 2)When personal information is provided because of the succession of business due to a merger or other reasons.

[Disclosure of personal information]

When the Company receives a request from an individual for disclosure of his/her personal information held by us in accordance with the provisions of the Personal Information Protection Law, it will disclose the information to the individual without delay after confirming that the request is made by the individual himself/herself. However, if disclosure would result in any of the following cases, we may decide not to disclose all or part of the information, and if the Company decides not to disclose the information, it will notify to that effect without delay.

• 1)When there is a risk of harm to the life, body, property, or other rights or interests of the person concerned or a third party.
• 2)When there is a risk of significant hindrance to the proper conduct of business.
• 3)When it would violate laws and regulations.

In principle, the Company does not disclose information that does not fall under the category of personal information, such as access logs.

[Correction, etc. of personal information]

If a person requests that the Company correct, add, or delete (hereinafter referred to as “correct, etc.”) his/her personal information held by us because it is untrue in accordance with the provisions of the Personal Information Protection Law, it will, after confirming that the request is made by the person himself/herself, conduct the necessary investigation without delay to the extent necessary to achieve the purpose of use, unless special procedures are provided for in other laws or regulations, and based on the results, correct the content of the personal information and notify the person to that effect.
If the Company decides not to make any correction, it will notify the individual to that effect.

[Discontinuation of use of personal information]

If the Company receives a request from a customer to stop the use of or delete (hereinafter referred to as “stop using, etc.”) his/her personal information held by us on the grounds that it has been handled beyond the scope of the purposes of use or that it has been obtained through deception or other wrongful means, we will conduct the necessary investigation without delay, and if the request is found to be reasonable, the Company will stop using the personal information without delay upon confirmation that the request was made by the customer himself/herself, and notify the customer to that effect.
However, this shall not apply in cases where it is not obligated to cease use, etc. under the Personal Information Protection Law or other laws and regulations.

[Contact us]

For requests for disclosure, correction, suspension of use, etc. of personal information, opinions, questions, complaints, and other inquiries regarding the handling of personal information, please contact the customer service desk below.

Contact e-mail: ​ sbizc_legal_compl@sbizodiacustody.com

[Continuous Improvement]

The Company shall review the operational status of the handling of personal information from time to time and strive for continuous improvement, and may change this policy as necessary.