선미야클럽 (Sunmiya Club)

In accordance with Article 30 of the 「Personal Information Protection Act」, FingerLabs establishes and discloses the following privacy policy to protect the personal information of the data subject and to quickly and smoothly handle related difficulties. This privacy policy will be applied from April 22, 2022.Article 1. Purpose of Privacy PolicyFingerLabs collects personal information for the following purposes. The collected information will not be used for any purpose other than the following purposes, and if the purpose of use is changed, necessary measures will be implemented, such as obtaining separate consent under Article 18 of the Personal Information Protection Act.

Providing Goods or Services Personal information is collected for the purpose of identification, delivery of products and services and communications provided during the service use purpose on Sunmiya Club website.

Article 2. Processing and Retention Period of Privacy Policy① FingerLabs processes and holds personal information within the period of possession and use of personal information according to privacy legislation or the period of possession and use of personal information agreed upon when collecting personal information from the information subject. ② The period of processing and holding personal information is as follows.

When providing goods or servicesPersonal information will be deleted without any delays when the information become unnecessary, such as the expiration of the personal information retention period or achievement of the purpose of processing.Grounds for posession : consent of the data subjectIf personal information is required to be stored for a certain period of time in accordance with laws and regulations, personal information is stored separately during the period.Related Acts and subordinate statues: 3 years of record on consumer complaints or disputes

Article 3. Enstrustment of Privacy Policy① For a smooth processing of personal information, FingerLabs entrusts personal information processing as follows.

Name of consginee: Jellablue Korea Co., LtdConsginee (Trustee): Jeon Bong Gwan, Jellablue information security team / 02-456-0643Contents of entrusted duties: Identification, a phone-call or text message for delivery of goods, CS controls, delivering noticesConsignment period: Deleted without delay when the purpose is achieved

② In accordance with Article 26 of 「Personal Information Protection Act」, FingerLabs stipulates in documents such as prohibition of personal information processing, technical and administrative protection measures, re-entrustment restrictions, management and compensation for trustees, and supervises whether the trustee handles personal information safely.③ If the details of the entrusted work or the trustee changes, we will disclose it through this personal information processing policy without delay.Article 4. Rights and Obligations of the Information Subject and Legal Representative and the Method of Exercise Thereof① The information subject may exercise the right to view, correct, delete, or stop processing personal information to FingerLabs at any time.② The exercise of rights under ① of Article 4. may be conducted in writing, e-mail, or fax to FingerLabs pursuant to Article 41 (1) of the Enforcement Decree of the Personal Information Protection Act, and FingerLabs will take action without delay.③ The excercise of rights under ① of Article 4. may be conducted through a legal representative of the data subject or an agent, such as a delegated person. In such cases, you must submit a power of attorney in accordance with attched Form 11 of "Public notice on the processing method of personal information (No.2020-7)"④ The rights of the data subject may be limited pursuant to Articles 35 (4) and 37 (2) of 「Personal Information Protection Act」 for the requesting suspension of personal information access and processing.⑤ Correction and deletion of personal information cannot be requested if it is specified as collect objectives in other laws and regulations.⑥ FingerLabs checks whether the person who requested for lookup, correction or deletion according to the right of the information subject, or lookup when requesting suspension of processing, is the person or the legitimate agent.Article 5. Items of Personal Information Processed① FingerLabs processes the following personal information for identification, delivery of goods/services, and communication when providing goods or services.Required items: Phone number, nameArticle 6. Deletion of Personal Information① FingerLabs deletes personal information without any delay when the information become unnecessary, such as the expiration of personal information retention period or achievement of the purpose of processing.② In case of preserving personal information accordance with other laws and regulations, although retention period of personal information agreed by the data subject has been expired or the purpose of processing has been achieved, the personal information moves to a separate database (DB) or be stored elsewhere.

Legal basis: 3 years of record of consumer complaints or disputesPersonal information items to be preserved: Phone number, name③ The procedure and method of deleting personal information are as follows.Delete procedure FingerLabs selects personal information that has occurred due to destruction, and delete personal information with the approval of the person in charge of personal information protection of FingerLabs.Discarding method Information in the form of electronic files ues a technical method that does not allow recording to be played. The personal information printed on the paper is shredded or destroyed by incineration.

Article 7. Measures to Ensure the Safety of Personal InformationFingerLabs is taking the following steps to ensure the safety of personal information.① Minimize and train personnel handling personal information

We are implementing measures to manage personal information by designating employees who handle personal information and minimizing them by limiting the number of those in charge.

② Technical Measures Against Threats such as Hacking and etc...

FingerLabs installs security programs to prevent leakage and damage of personal information due to hacking or computer viruses, periodically update and inspect them, install systems in areas where access is restricted from the outside, and monitor and block them technically and physically.

③ Restricting Access to Personal Information

Measures are taken to control access to personal information by granting, changing, or canceling access to the database system that processes personal information, and unauthorized access from outside is controlled using the intrusion prevention system.

④ Control of Access to Unauthorized People

A separate physical storage place where personal information is stored is set and operated for access control procedures are established.

Article 8. Concerns Related to Installation, Operation, and Rejection of Automatic Personal Information Collection DevicesFingerLabs does not use 'Cookie' that stores information on the information subject and reads it from time to time.Article 9. Person in Charge of Personal Information Protection① FingerLabs is in charge of handling personal information, and designates a person in charge of personal information protection as follows to handle complaints and remedy damages of information subjects related to personal information processing.

Person in charge of personal information protectionName: Nayeon ParkRole: Person in charge of processing personal informationPosition: PMContact: 02-552-9514 / help_sunmiya@fingerlabs.io ※ You will be directed to the Privacy Department.

Privacy policy departmentDepartment name: Service Planning DivisionPerson in charge: Nayeon ParkContact: 02-552-9514 / help_sunmiya@fingerlabs.io

② The information subject can contact privacy policy department and person in charge for cases such as CS, damage relief, etc.. caused by using Sunmiya Club service of FingerLabs. FingerLabs will respond and process inquiries from the information subject without delay.Article 10. Request for Access to Personal InformationThe information subject may request the following department to view personal information under Aritcle 35 of ｢Personal Information Protection Act｣. FingerLabs will try to expedite the request for access to personal information by the information subject.

Receipt and processing department for personal information access requests.Department name: Service Planning DivisionPerson in charge: Nayeon ParkContact: 02-552-9514 / help_sunmiya@fingerlabs.io

Article 11. Methdo of Remedy for Infringement of Rights and Interests.The information subject may apply for dispute resolution or consultation with the Personal Information Dispute Mediation Committe and Korea Internet & Security Agency's Personal Information Infringement Report Center in order to receive relief from personal information infringement. In addition, please contact the institution below for reports and counseling of other personal information violations.

Personal Information Dispute Mediation Committee:1833-6972 (www.kopico.go.kr)Personal Information Infringement Report Center: 118 (privacy.kisa.or.kr)Supreme Prosecutors' Office: 1301 (http://www.spo.go.kr)Police Department: 182 (http://ecrm.cyber.go.kr)

A person who has been infringed on rights or interests due to disposition or omission by the head of a public institution may file an administrative trial as prescribed by the Administrative Appeals Act for requests under Articles 35 (View of Personal Information), 36 (Correction/Delete of Personal Information, etc.). ※ For more information on administrative trials, please refer to the website of the Central Administrative Appeals Commission (http://www.simpan.go.kr).Article 12. Change of Personal Information Processing Policy① This privacy policy will be applied from April 22, 2022.② If privacy policy changes in the future, FingerLabs will post the changes on privacy policy page on the website.