Personal Data Protection Policy

• In accordance with Article 30 of the Personal Information Protection Act and Article 27-2 of the Act on Promotion of Information and Communications Network Utilization and Information Protection, etc., BWL Korea Co., Ltd. establishes and discloses the following personal information processing policy in order to protect users’ personal information and to promptly and smoothly process complaints related thereto.
• BWL Korea Co., Ltd. places great importance on the protection of users’ personal information and complies with the Personal Information Protection Act, the Act on Promotion of Information and Communications Network Utilization and Information Protection, and other laws and regulations related to personal information protection.

Article 1 (Purpose of Processing Personal Information)

BWL Korea Co., Ltd. processes personal information for the following purposes. The personal information processed will not be used for any purpose other than the following purposes, and if the purpose of use changes, we will take necessary measures such as obtaining separate consent in accordance with Article 18 of the Personal Information Protection Act.

• Membership registration and management

  Personal information is processed for the purpose of confirming the intention to join the membership, identifying and authenticating the person in accordance with the provision of membership services, maintaining and managing membership, identifying the person in accordance with the implementation of a limited identity verification system, preventing unauthorized use of the service, payment of benefits, public certification for consumer damage compensation, various notices and notifications, and grievance handling.

• Provision of goods or services

  We process personal information for the purpose of delivering goods, providing services, sending contracts and invoices, providing content, providing customized services, identification, age verification, payment and settlement, and debt collection.

• Utilization for marketing and advertising

  With the consent of the user, personal information is processed for the purpose of event and marketing planning/management, service development, promotional events, advertising promotion and sales solicitation such as private banking, etc.

Article 2 (Processing and Retention Period of Personal Information)

BWL Korea Co., Ltd. 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 users. The period of processing and retention of personal information is as follows.

• Membership registration and management: Until the time of membership withdrawal, but if the following reasons apply, until the termination of such reasons
• In the event of an ongoing investigation or investigation in violation of relevant laws and regulations, until the end of the investigation or investigation.
• Until the settlement of the debt/obligation relationship based on the transaction of the company.
• Until the retention period for retained items in accordance with relevant laws and regulations
• Information related to the provision of goods or services: 5 years after the termination of the contract for the provision of goods and services and the settlement relationship (this period takes into account the period of statute of limitations for commercial debts and the protection of transaction users and the period of burden of proof under Article 36 of the Act on Door-to-door Sales, etc.)
• Retention of Personal Information by Applicable Law

Applicable laws	Retention items	Retention period
The Communications Privacy Act	Login history	3 months
The Consumer Protection i Electronic Commerce Act	Records about Display/Advertising	6 months
	Records about contracts or withdrawals	5 years
	Records of payments and supply of goods and services	5 years
	Records of consumer complaints or dispute handling	3 years
National Tax Base Act	Tax Base and Tax Amount Returns (Calculation of statute of limitations for tax collection rights, etc.	5 years
Value-added tax laws	VAT taxable base and tax returns, etc.	5 years
Electronic Financial Transactions Act	Records of electronic financial transactions, information about counterparties, etc.	5 years

Article 3 (Provision of personal information to third parties)

BWL Korea Co., Ltd. processes personal information only within the scope specified in Article 1 (Purpose of Processing Personal Information) and provides personal information to third parties only in accordance with Articles 17 and 18 of the Personal Information Protection Act, including the consent of the user and special provisions of the law.

BWL Korea Co., Ltd. provides personal information to third parties as follows.

• Provision of personal information to the MAC&CO: In accordance with Article 37 of the Act on Door-to-Door Sales, etc., BWL Korea Co., Ltd., which has entered into an insurance transaction agreement with the MAC&CO, provides members’ personal information after obtaining consent in order to submit sales data and other information to the MAC&CO.

Division	Recipient	Purpose of use	Items provided	Retention and Use Period
Required	MAC&CO	Performing consumer damage compensation (deductible payment) work	Name, order number, member code, order amount	92 days




• Provision of personal information between upline and downline member: BWL Korea Co., Ltd. provides personal information of users to upline or downline member only when consent is given for use for business purposes such as management of user allowances and consultations. If the user does not consent, provision of information is restricted, and the user may withdraw consent at any time.

Division	Recipient	Purpose of use	Items provided	Retention and Use Period
Option	User sponsor and upline and downline	Organization management, sending of marketing information, education, online consultation, provision of information on various events	Name, contact information, member code	Until the user withdraws consent to provide

Article 4 (Transfer of Personal Information Abroad)

Details on the overseas transfer of personal information of users of BWL Korea Co., Ltd. are as follows:

Article 5 (Consignment of Personal Information Processing)

• BWL Korea Co., Ltd consigns personal information processing tasks as follows for smooth personal information processing.

Fiduciary	Contents of the entrusted work
Ohyeon Logistics Co., Ltd. Post Office Delivery	Product Delivery
Korea Information and Communications Corporation	Provision of card payment service and account verification
Nice Information Service Co., Ltd.	Providing identity verification service and real name authentication




• When entering into a consignment contract, BWL Korea Co., Ltd. states in the contract or other documents matters related to responsibilities such as prohibition of processing personal information for purposes other than the performance of the consigned work, technical and administrative protection measures, restrictions on re-consignment, management and supervision of the consignee, and compensation for damages in accordance with Article 26 of the Personal Information Protection Act, and supervises whether the consignee safely processes personal information.
• If the content of the entrusted work or the trustee changes, we will disclose it without delay through this personal information processing policy.

Article 6 (Rights and Obligations of Users and Legal Representatives and How to Exercise Them)

• The user may exercise the right to view, correct, delete, or suspend the processing of personal information at any time against BWL Korea Co., Ltd.
• The exercise of the rights under Paragraph 1 may be made in writing, e-mail, facsimile transmission (FAX), etc. to the company in accordance with Article 41 (1) of the Enforcement Decree of the Personal Information Protection Act, and the company will take action without delay.
• The exercise of the rights under Paragraph 1 may be made through a representative, such as a legal representative of the user or a person who has been delegated. In this case, you must submit a power of attorney in the form of Attachment No. 11 to the “Notification on the Method of Processing Personal Information (No. 2020-7)”.
• Requests for access to personal information and suspension of processing may be limited by Article 35 (4) and Article 37 (2) of the Personal Information Protection Act.
• A request for correction and deletion of personal information cannot be made if the personal information is specified as the subject of collection in other laws.
• BWL Korea Co., Ltd. shall verify that the person making a request for access, correction, deletion, or suspension of processing in accordance with the user's rights is the user or a legitimate representative.

Article 7 (Items of Personal Information Processed and Method of Collection)

• In order to provide smooth user consultation and various services, BWL Korea Co., Ltd. collects the following personal information when first signing up for membership. We promise that we will never use the user's personal information for purposes other than those stated, and that we will obtain consent from all registered users if the purpose and use of personal information changes. If consent to the collection and use of personal information is withdrawn, we will delete the personal information after a certain period of time.
• Information about membership registration and management

Required	Name, Birth of date, ID, Address, Phone number, mobile number, e-mail, gender, Domestic and Foreigner Information
Option	Spouse's name, spouse's date of birth, spouse's phone number (when registering spouse)




• Information related to the provision of goods or services, payment of allowances and reporting and payment of various taxes

Required

Name, date of birth, gender, ID, address, phone number, mobile phone number, email, payment information such as credit card number, bank account information, and resident registration number (for the purpose of collecting and using sponsorship allowances and collecting income from the source of the allowance)




• The following personal information items may be automatically generated and collected in the process of using the Internet service.
  Access IP address, cookies, access logs, service usage records, visit history, etc.
• BWL Korea Co., Ltd. collects personal information in the following ways.
• When the user agrees to the collection of personal information and enters the information directly when registering for membership and using the service online or in writing
• Through mail, fax, telephone, etc. in the process of consultation through the customer center
• Participation in events/events held online or offline, etc.

Article 8 (Destruction of Personal Information)

• BWL Korea Co., Ltd. shall destroy the personal information without delay when the personal information becomes unnecessary, such as the expiration of the personal information retention period or the achievement of the purpose of processing.
• If the retention period of personal information agreed to by the user has elapsed or the purpose of processing has been achieved, but the personal information must continue to be preserved in accordance with other laws and regulations, the personal information shall be transferred to a separate database (DB) or preserved in a different storage location.
• The process and methods for destroying personal information are described below.
• Destruction Procedure
  BWL Korea Co., Ltd selects the personal information for which the reason for destruction has occurred and destroys the personal information with the approval of the personal information protection officer of the company.
• Method of destruction
  Personal information printed on paper is destroyed by shredding or incineration, and personal information stored in the form of electronic files is destroyed using a technical method that makes it impossible to reproduce the records.

Article 9 (Measures to secure the safety of personal information)

BWL Korea Co., Ltd. takes the following measures to ensure the safety of personal information.

• Establishment of internal planning management and minimization and training of employees handling personal information
  We have established and implemented internal planning management, and we take measures to manage personal information by designating employees who handle personal information and minimizing it by limiting it to those in charge.
• Technical measures against hacking, etc.
  In order to prevent leakage and damage of personal information due to hacking or computer viruses, we install security programs, periodically update and inspect them, install systems in areas where access is controlled from the outside, and monitor and block them technically and physically.
• Encryption of Personal Information
  Users' personal information and passwords are encrypted and stored and managed, so only the user can know them, and important data uses separate security features such as encrypting files and transfer data or using file locking functions. Therefore, users should not disclose their passwords to anyone. To this end, the company basically recommends that users log out online and close their web browser after using their PC. In particular, if you share a PC with others or use it in a public place (such as a company, school, library, or internet game room), the above procedures will be even more necessary to prevent users' personal information from being disclosed to others. user must manage your personal information responsibly. The company is not responsible for any leakage of passwords or personal information.
• Restriction of access to personal information
  The Company takes necessary measures to control access to personal information by granting, changing, and canceling access rights to the database system that processes personal information, and controls unauthorized access from the outside using an intrusion prevention system.
• Use locks to secure documents
  I keep documents, secondary storage media, etc. that contain personal information in a secure location with a lock.

Article 10 (Installation, Operation, and Rejection of Automatic Personal Information Collection Devices)

• The Company uses 'cookies' to store and retrieve usage information from time to time to provide individualized customized services to users.
• Cookies are small amounts of information sent to the user's computer browser by the server (http) used to operate the website and are stored on the hard disk of the user's PC computer.
• Purpose of use of cookies: Cookies are used to provide optimized information to users by identifying the types of visits and use of each service and website visited by users, popular search terms, secure connection, etc.
• Installation, operation and rejection of cookies: user can reject the storage of cookies by setting the options in the Tools>Internet Options>Privacy menu at the top of user web browser.
• If user refuse to save cookies, user may experience difficulties in using customized services.

Article 11 (Personal Data Protection Officer)

• BWL Korea Co., Ltd. is responsible for the overall handling of personal information and designates the person in charge of personal information protection as follows to handle user complaints and damage relief related to the handling of personal information.

Personal Data Protection Officer	Personal Data Protection Department
Name: Joo-Hyun Yoon Position: Deputy CM of BWL Korea Phone: 02-3675-9190 E-mail: joshua.yoon@kr.bwlgroup.com	Department Name: Customer Support Team Person in Charge: Park Hyo-jin Phone Number: 02-3675-9190 E-mail: jinny.park@kr.bwlgroup.com

Personal Data Protection Officer

Name: Joo-Hyun Yoon Position: Deputy CM of BWL Korea Phone: 02-3675-9190 E-mail: joshua.yoon@kr.bwlgroup.com

Personal Data Protection Department

Department Name: Customer Support Team Person in Charge: Park Hyo-jin Phone Number: 02-3675-9190 E-mail: jinny.park@kr.bwlgroup.com

• Users may inquire about all personal information protection-related matters, such as complaints, damage relief, etc. that arise while using BDL Korea’s services (or business) to the personal information protection manager and the department in charge. BDL Korea will respond to and process user inquiries without delay.

Article 12 (Request to view personal information)

Users may request to view personal information in accordance with Article 35 of the Personal Information Protection Act to the department in Article 11, Paragraph 1. BWL Korea Co., Ltd. will endeavor to promptly process users’ requests to view personal information.

Article 13 (Methods of Redress for Rights Infringement)

Users may apply for dispute resolution or consultation to the Personal Information Dispute Mediation Committee, the Personal Information Infringement Report Center of the Korea Internet & Security Agency, etc. to receive relief for personal information infringement. For other reports or consultations on personal information infringement, please contact the following organizations.

• Personal Information Dispute Mediation Committee: (without area code) 1833-6972 (www.kopico.go.kr)
• Personal Information Infringement Report Center: (without area code) 118 (privacy.kisa.or.kr)
• Supreme Prosecutors' Office: (without area code) 1301 (www.spo.go.kr)
• National Police Agency: (without area code) 182 (cyberbureau.police.go.kr)

Any person whose rights or interests have been infringed upon due to a disposition or inaction by the head of a public institution in response to a request pursuant to Article 35 (Access to Personal Information), Article 36 (Correction/Deletion of Personal Information), or Article 37 (Suspension of Processing of Personal Information, etc.) of the Personal Information Protection Act may request an administrative review in accordance with the Administrative Appeals Act.

※ For more detailed information on administrative appeals, please refer to the Central Administrative Appeals Commission (www.simpan.go.kr) website.

Article 14 (Changes to Personal Information Processing Policy)

• This personal information processing policy will be applied from April 13, 2022.