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Information to Be Collected and Methods for Collection

Personal information to be collected by “GREAT MINDS” for the purpose of membership registration and the Services are as follows:

1. Information you provide us directly

   • Essential information : ID (e-mail address), password, your country information

   • Optional information : Name

   • Collection Method: Membership registration homepage

2. Information Automatically Collected During Use of Services

   • IP address, log data, access time, service use records, abusive use records

   • Collection Purpose: Client convenience (Session supervision and moves made to previous pages, etc.)

3. Information Collected by Social Media or Other Contents Platforms

   When users log into social networks like Facebook, Google, or third parties, and make use of the services, they may allow “GREAT MINDS” to access their social network profile to save specific information. Such information may include the users’ email addresses and names.

Our Use of Collected Information

“GREAT MINDS” uses the collected information of users for the following purposes:

1. Provision of Requested Services

   Collected data may be used to identify the users’ requests pertaining to the Services and info of“GREAT MINDS.” For example, the users' contact information may be used to complete purchases and provide requested Services.

2. Communication

   “GREAT MINDS” may use collected data to send e-mail newsletters and event promotions. Additionally, data can be used when sending e-mails featuring the users' account information and site updates.

3. Personalization

   Collected personal information is also used for the discovery of new services and improvement on existing services such as demographic analyses, service access records and use record analyses, and customized services founded on personal info and interests, among others. Personal information is also used for service use records, access frequency analyses, service use statistics, in addition to customized services and advertising publications according to service analyses and statistics.

How We Share Your Information

We do not share your personal information with third parties unless (1) we obtain your prior consent; (2) we are required to (i) comply with laws or to respond to lawful requests and legal processes, including, for example, to comply with a court order or subpoena, (ii) protect the rights and property of GREAT MINDS, our users and others, including to enforce our terms, policies, rules and agreements and/or (iii) protect the safety and security of any person, GREAT MINDS and our website and application; or (3) in connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction or proceeding involving sale, transfer, divestiture or disclosure of all or portion of our business or assets for use in accordance with applicable laws.

Cookies and Similar Technologies

“GREAT MINDS” operates “cookies” to save and collect the users' personal information.

Cookies are very small text files sent to the browser of the users by the server utilized for the operation of the websites of “GREAT MINDS,” and are stored in hard disks of the users' computer. “GREAT MINDS” uses cookies for the following purposes:

1. Use Purposes for Cookies

   Cookies analyze statistics on access frequency and visiting times of members and non-members, identify the users' preferences and interests, trace the users' activities, and provide target marketing and personally customized services through various event attendances and access count.

   Therefore, you can set up the options in the users' web browser to allow all cookies, or to pass through authentication processes whenever cookies are saved, or refuse to save any cookies altogether.

2. Refusal Methods for Cookie Setups

   Ways for refusing cookie setups would be that of the user selecting web browser options to allow all cookies to pass through authentication processes whenever cookies are saved, or refuse to save any cookies altogether.

3. Cookie Retention Period

   Cookies expire when web pages are closed.

   Set-up Method Example (For Internet Explorer): Tools on the upper part of web page > Internet Options > Personal Information Tab

   If the user rejects the installation of cookies, access to the Services provided by “GREAT MINDS” in whole or in part may be limited.

4. Types of cookies we use

   There are a number of different types of cookies, however, our Services uses:

   • • Functionality - we use these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.

     • Advertising - we use these cookies to collect information about your visit to our Services, the content you viewed, the links you followed and information about your browser, device, and your IP address. We sometimes share some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website.

     • Essential Cookies- we use these cookies to enable you to order and receive our Services.

     • Performance Cookies- we use these cookies to enable us to analyze the performance and design of our Services and detect errors.

Period for Retention and Use of Personal Information

We keep your personal information only as long as we need it for the purpose listed in this Privacy Policy and these are either for legitimate business interests, as required by law or as necessary to perform the Services to you. We may anonymize your personal information and retain this information for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so unless prohibited by applicable laws. However, your membership information may be retained until your membership withdrawal subject to your consent; provided, however, that such information may be stored in a separate space for five days from the date of membership withdrawal and thereafter destroyed permanently, unless otherwise required by applicable law. Notwithstanding the foregoing, we will keep your ID permanently to prevent users from creating duplicate member IDs.

Delegation of Personal Information Processing to a Third Party

In principle, “GREAT MINDS” does not delegate to a third party the processing of your personal information without your consent; provided, however, that GREAT MINDS delegates the personal information processing to the below third party, subject to your consent to the extent that you use the relevant services:

Rights of Users

We would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

1. The right to access- You have the right to request us for copies of your personal information. We may charge you a small fee for this service.

2. The right to rectification- You have the right to request that we correct any information you believe is inaccurate. You also have the right to request us to complete the information you believe is incomplete.

3. The right to erasure- You have the right to request that we erase your personal information, under certain conditions.

4. The right to restrict processing- You have the right to request that we restrict the processing of your personal information, under certain conditions.

5. The right to object to processing- You have the right to object to our processing of your personal information, under certain conditions.

6. The right to refusal- You have the right to refuse to provide and - without impact to data processing activities that have taken place before such withdrawal - withdraw your consent to processing of your Personal Information at any time.

7. The right to data portability- You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you would like to exercise any of these rights, please click here. (or please email us at support@thegreatminds.com)

Security Measures for Privacy Protection

GREAT MINDS takes the following measures to safeguard your personal information:

1. Implementation of Regular Self-Inspections

   Regular self-inspections are implemented once every quarter to secure safety for the treatment of personal information.

2. The Minimum Number of and Training Sessions for Employees Processing Personal Information

   The processing of personal information is assigned to the minimum number of our employees who is responsible for managing personal information.

3. Establishment and Practice of Internal Management Plan

   Internal management plans are established and practiced for the safe treatment of personal information.

4. Technical Measures as Countermeasures against Hacking

   To prevent leakage of or damages to users' personal information through hacking or computer viruses, security programs are installed, updated and inspected regularly. Various measures to monitor and prevent any security breaches are carried out both technically and physically by installing and operating external access control systems.

5. Encryption of Personal Information

   A user’s personal information is encrypted when stored and carefully managed, with only the user’s access to his/her personal information. Critical data is stored after its file and transmission data is encrypted or locked through the use of separate security functions.

6. Storage and Prevention of Forgery or Alteration of Access Records

   Access records for processing of personal information are stored and managed for a minimum of one year, and records of addition of the personal information of more than 50,000 data subjects, or treatment of unique identification information or sensitive information are stored and managed for a minimum of two years. To prevent any forgery or alteration of access records, security functions are used.

7. Restriction on Access to Personal Information

   Appropriate measures by such as granting, modifying and cancelling the authority to access to the database system that processes personal information are taken for control over access to personal information, and a firewall system is used to control any unauthorized external access.

8. Use of Locking Device for Document Security

   Documents and supplementary storage mediums containing personal information are stored in safe places with locking devices.

9. Access Control against Unauthorized Personnel

   The physical storage containing personal information is managed separately and the procedures to control access to such storage are established and operated.

Protection of Personal Information of Children

GREAT MINDS” has general clients as its targets, and does not collect any information from children under 13 years of age. If in any case a collection of personal information is made inadvertently from children under 13 years of age without prior consent from their parents, “GREAT MINDS” will take rational measures to delete such info as soon as possible. If you are a minor between thirteen (13) and eighteen (18) years old, you must get permission from your parent or guardian.“GREAT MINDS” complies with the requirements prescribed by age limits and relevant jurisdiction laws.

Your Choice

We offer you certain choices in connection with the personal information we obtain about you.

To update your preferences, limit the communications you receive from us, or submit a request, please contact us as specified in the Contact Info section below.

The Services may offer choices related to the collection, deletion and sharing of certain information and communications about products, services and promotions that are unique to specific Services. You can access the relevant settings of each Service to learn about choices that may be available for that Service. If you decline to allow the Services to collect, store or share certain information, you may not be able to enjoy full use of all of the features available through the Services.

International Transfer of Data

Your use of Services will involve the transfer, storage and processing of your personal information outside of your country of residence to Korea consistence with this Policy. Also, your use of the Services may also involve the transfer, storage and processing of your Personal Information to other counties including without limitation the United States of America , based on your consent. We use standard contract clauses approved by the European Commission or other suitable safeguard to permit data transfers from your country to other countries. Standard contractual clauses are commitments between companies transferring personal information, binding them to protect the privacy and security of your data. For more information, please contact us as specified in the Contact Info section of this Privacy Policy.

Modification of Privacy Policy

We keep our Policy under regular review and places any updates on this Services. When we update this Privacy Policy, we will notify you by posting the new version and changing the last updated date at the top of the Privacy Policy. However, if we make material changes to our Privacy Policy, we will provide you with a prominent notice describing the changes, and if required by law, seek your consent to such changes by clicking "yes" or "I accept," ticking a checkbox or any other similar method of confirmation.

Contact Info

1. Please refer to the following address when making any inquiries on the Privacy Policy or Services:

   • 281, Hallyuworld-ro, Ilsandong-gu, Goyang-si, Gyeonggi-do, Republic of Korea, EBS (Educational Broadcasting System)

   • email : support@thegreatminds.com