ICDI (hereinafter the “Company”) has established the following policy in accordance with the Personal Information Protection Act in order to protect users’ personal information and rights and to handle users’ complaints about personal information smoothly. When the Company amends this Privacy Policy, it will announce the change through a website notice (or an individual notice). This policy takes effect on December 24, 2024.

1. Purposes of Collecting and Using Personal Information
① The Company processes personal information for the following purposes. The personal information processed will not be used for any purpose other than the following, and if the purpose of use changes, the Company will take the necessary measures, such as obtaining separate consent pursuant to Article 18 of the Personal Information Protection Act.
a) Customer support: Personal information is processed for purposes such as contacting users to confirm and answer affiliation-related inquiries and notifying them of the results of processing.
b) Provision of information: Personal information is processed for purposes such as providing information about programs hosted by the Company.
② The Company collects personal information by the following method.
- Website

2. Personal Information Items Processed
① The Company processes the following personal information items.
a) Customer support
- Required items: name, contact information (access IP information, cookies, service usage records, access logs)
- Optional items: none
b) Provision of information
- Required items: name, contact information (access IP information, cookies, service usage records, access logs)
- Optional items: none

3. Processing and Retention Period of Personal Information
① The Company processes and retains personal information within the retention and use period prescribed by law or the retention and use period to which the data subject consented when the personal information was collected.
② The specific processing and retention periods are as follows.
a) Customer support: Personal information is processed for purposes such as contacting site users to confirm and answer their inquiries and notifying them of the results of processing.
b) Provision of information: Personal information is processed for purposes such as providing information about programs hosted by the Company.
c) Personal information retention period: 5 years

4. Destruction of Personal Information
① In principle, once the purpose of processing personal information has been achieved, the Company destroys the information without delay after the retention period has passed. The procedure, deadline, and method of destruction are as follows.
- Destruction procedure: Information entered by users is, once its purpose has been achieved, moved to a separate database (or, in the case of paper, a separate file) and stored for a certain period in accordance with internal policy and other relevant laws, or is destroyed immediately. Personal information moved to the database is not used for any other purpose except as required by law.
- Destruction deadline: When the retention period of a user’s personal information has elapsed, the information is destroyed within 5 days of the end of the retention period. When the information has become unnecessary, such as when the purpose of processing has been achieved, the relevant service has been discontinued, or the business has ended, it is destroyed within 5 days of the date on which processing is deemed unnecessary.
- Destruction method: Information in electronic file form is destroyed using technical methods that make the records unrecoverable. Personal information printed on paper is destroyed by shredding or incineration.

5. Provision of Personal Information to Third Parties
① In principle, the Company processes users’ personal information within the scope specified in “1. Purposes of Collecting and Using Personal Information,” and does not process it beyond that scope or provide it to third parties without the user’s prior consent.
However, personal information may be processed in the following cases.
- When the user has given prior consent to provision to, or disclosure to, third parties
- When provision is required by law or other regulations
- When the information is necessary for performing a contract relating to the provision of services, and obtaining ordinary consent is significantly difficult for economic or technical reasons
- When the information is processed into a form that cannot identify a specific individual before use
② When personal information is provided to a third party, the Company will always give notice, through the Privacy Policy, of the recipient, the purpose of use, the items of personal information provided, the retention and use period, and other details.
③ If a user does not consent to provision to or disclosure to third parties, the services provided by the Company may be restricted, or the user may be disadvantaged in obtaining information.

6. Outsourcing of Personal Information Processing
① The Company does not outsource the processing of personal information. If it does so, it will announce this through a separate notice at least 15 days in advance and then amend the Privacy Policy.

7. Rights and Obligations of Data Subjects and How to Exercise Them
① A data subject may exercise the following personal information protection rights against the Company at any time.
a) Request to access personal information
b) Request for correction if there are errors, etc.
c) Request for deletion
d) Request to suspend processing
② The rights under Paragraph 1 may be exercised against the Company in writing, by e-mail, by fax, etc., in accordance with Attached Form No. 8 of the Enforcement Rules of the Personal Information Protection Act, and the Company will take action without delay.
③ If a data subject requests correction or deletion of errors, etc. in personal information, the Company will not use or provide that personal information until the correction or deletion is complete.
④ The rights under Paragraph 1 may be exercised through an agent, such as the data subject’s legal representative or a person authorized by the data subject. In this case, a power of attorney in accordance with Attached Form No. 11 of the Enforcement Rules of the Personal Information Protection Act must be submitted.

8. Installation, Operation, and Refusal of Devices That Collect Personal Information
① The Company uses “cookies” and similar tools that store and retrieve your information from time to time.
a) What are cookies?
- To provide personalized and customized services, the Company uses “cookies” that store users’ information and retrieve it from time to time.
- Cookies are very small text files that the server used to operate a website sends to the user’s browser, and they are stored on the hard disk of the user’s computer. When the user later visits the website, the website server reads the contents of the cookie stored on the user’s hard disk in order to maintain the user’s settings and provide customized services.
- Cookies do not automatically or actively collect information that identifies individuals, and users may refuse or delete the storage of cookies at any time.
b) Purpose of the Company’s use of cookies
- Cookies are used to understand the visit and usage patterns, popular search terms, secure-connection status, and user volume for each of the Company’s services and websites that users have visited, in order to provide users with optimized, customized information, including advertising.
c) Installation, operation, and refusal of cookies
- Users have the right to choose whether to install cookies. Accordingly, users can set options in their web browser to allow all cookies, to be prompted for confirmation each time a cookie is stored, or to refuse the storage of all cookies.
- However, if you refuse to store cookies, you may have difficulty using some services.
- To specify whether cookie installation is allowed (for Internet Explorer):
(1) From the [Tools] menu, select [Internet Options].
(2) Click the [Privacy] tab.
(3) Set the [Privacy level].

9. Personal Information Protection Officer
① The Company assumes overall responsibility for personal information processing and has designated a Personal Information Protection Officer, as below, to handle data subjects’ complaints and provide remedies for damage related to personal information processing.
▶ Personal Information Protection Officer
- Department: ICDI
- Contact: 010-8268-0257 / 010-3221-0256
② While using the Company’s services, a data subject may direct all inquiries, complaints, requests for remedies, and other matters related to personal information protection to the Personal Information Protection Officer or the responsible department. The Company will respond to and handle the data subject’s inquiries without delay.