• These policy apply to foreigners with nationality other than South Korea.

INFINIQ PRIVACY POLICY HIGHLIGHTS


INFINIQ, 701, J-plaze, 186, Gasan Digital 1-Ro, Geumcheon-gu, Seoul, Korea ("We") respect your concerns about privacy. This Privacy Policy applies to the personal information we collect in connection with the services we provide, including in relation to our products [WELLID] and the use of our websites [Wellid ai] (the “Services”).

OVERVIEW OF PRIVACY POLICY

In this Privacy Policy, we describe the types of personal information we process in relation to the Services, how we use the personal information, how long we retain the personal information, with whom we share the personal information, and the choices available to you and your rights regarding the use of your personal information, including the right to object to some of the processing we carry out. More information about your rights, and how to exercise them, is set out in the Your Rights section below. This Privacy Policy will also tell you how to contact us about our privacy practices. Below is a list of key topics addressed in this Privacy Policy. For more detailed information on how we process your personal information, please continue to read below.

1. Collection of Personal Information
2. Use of Personal Information
3. Information Sharing
4. Retention of Personal Information
5. Your Rights
6. Protection of Personal Information
7. International Transfers and Related Processing
8. Updates to Privacy Policy
9. Contact Us

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INFINIQ PRIVACY POLICY

Effective Date: 14. 07. 2021

1. Collection of Personal Information

A. How we collect your personal information
• If you create an account on our Service
• If you buy a product or service directly from us
• If, with your permission where necessary, your contact details are passed to us by a partner or other third party
• When you communicate with our customer service staff

B. Personal information we collect
• Information you provide to us through your relationship with us, including but not limited to information provided by you when using the service, such as your first and last name, photos, age, gender, location-based information, e-mail and mailing address, and phone number
• Information collected by technology via the Service, such as device name, IMEI, web browser type, IP address, domain name, date/time log of your visit to the Service, unique device identifier (such as Android ID), language, and setting of the device.

2. Use of Personal Information

In this section we provide the legal ground on which we rely to process your personal information and under each legal ground, we explain the purposes for which we collect and use your personal information.

Provision of Services based on your contractual relationship with us

• Provide you with the Services
• Identify and authenticate you so you may use certain services
• Respond to your inquiries

Use of information based on legitimate interests of us and/or third parties

• Effectively manage our relationship with you, including by resolving technical issues, providing you with customer care support and sending you necessary information relating to our Services
• Protect against, identify and prevent fraud and other criminal activity, claims and other liabilities
• Monitor use of services and use your information to help us monitor, improve and protect our products and website
• Effectively manage our business, including by generating reports and analyzing the performance of our Services (through the use of aggregated information), auditing our business processes, using statistics to make informed business decisions.

Use of information based on your consent:

• Place cookies and use similar technologies in accordance with our Cookies Policy and the information provided to you when those technologies are used.

On other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time. When we rely on consent, you will have the right to withdraw your consent at any time. To exercise this right, please see the “Your Rights” section below.

Change of purpose

We will use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

For purposes which are required by law:

• Comply with and enforce applicable legal requirements; or
• Respond to requests from government or law enforcement

3. Information Sharing

We may disclose your personal information in relation to the Services as described below:

Affiliates and subsidiaries. Your information may be shared among our affiliates and subsidiaries for the purposes described in this Privacy Policy. The term ‘affiliates and subsidiaries’ refers to companies related to INFINIQ by common ownership or control. Our affiliates may include companies with the [INFINIQ] name or other companies under common ownership or control.
Service providers. We may disclose your information to carefully selected companies that provide certain services on our behalf, such as companies that help us develop and operate systems for services provided at customer contact centers, and customer care services that send emails on our behalf. These entities are limited by contractual provisions in their ability to use your information for purposes other than providing services for us.
Business Partners. Partners who we work together with to provide you with the Services you’ve requested or bought. For example, we may work with a bank so that you can use one of our Services to make faster and more efficient payments. These business partners control and manage your personal information.
Business Advisors: For example, our lawyers, accountants, business consultants, insurers, auditors, to the extent necessary for them to provide with their services.
Other parties if required by law or necessary to protect our Services. There may be instances when we disclose your information to a third party:
   - to comply with the law or respond to compulsory legal processes (such as a search warrant or other court order);
   - to verify or enforce compliance with the policies governing our Services; and
   - to protect the our rights, property, or safety, or, in compliance with data protection laws, any of our respective affiliates, business partners, or customers.
Other parties to transactions. We may disclose your information to a third party as part of a merger or transfer, acquisition or sale related to our business, or in the event of bankruptcy.
Other parties with your consent or pursuant to your request. In addition to the disclosures described in this Privacy Policy, we may disclose your information to third parties when you separately consent to or request such disclosure of your information.

4. Retention of Personal Information

We will take appropriate measures to ensure that we only process and retain your information for the duration as required:

• to provide you with the Services;
• under law or contract, including, for example, with regard to our statutory obligations under tax laws; or
• for the purposes for which it was collected and is processed (or longer if required under any contract, by applicable law), or for statistical purposes, in anonymized form, subject to appropriate safeguards.

When we no longer need to use your personal data, it is removed from our systems and records or anonymised so that you can no longer be identified from it.

5. Your Rights

Your personal information belongs to you. To the extent permitted under applicable laws, you may ask us to identify the personal information we have collected from you, and request that we delete it or correct any inaccuracies. You can also ask us to restrict or limit the processing of your personal information, as well as, to provide your personal information for a contract or in a structured, machine readable format, and to share (port) this data to another data controller.

In addition, to the extent permitted under applicable laws, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement).

These rights may be limited, for example, if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in both the GDPR and in equivalent national laws. We will inform you of relevant exemptions that we rely upon, if relevant, when responding to requests that you make. To exercise your rights or to make an inquiry, see the Contact Us section below.

6. Protection of Personal Information

We take protection of your information seriously and have put in place appropriate physical and technical measures to safeguard the information we collect in connection with the Services. Our security measures are state of the art. However, please note that although we take reasonable steps to protect your information, no website, Internet transmission, computer system, or wireless connection is completely secure.

7. International Transfers and Related Processing

Your use of our Services will involve the transfer, storage, and processing of your personal information within and outside of your country of residence, consistent with this Privacy Policy. In particular, your personal information will be transferred to the Republic of Korea. Please note that the data protection and other laws of countries to which your information may be transferred might not be as comprehensive as those in your country.

[For European Economic Area Residents Only]

In addition, your use of the Services may also involve the transfer to, or storage, and processing of your personal information by other countries; such countries include, without limitation, countries in the European Economic Area (the “EEA”), South Korea, We will take appropriate measures, in compliance with applicable laws, to ensure that your personal information remains protected. Such measures include for instance the use of the European Commission Standard Contractual Clauses to safeguard the transfer of information outside of the EEA, or reliance on your explicit consent.

8. Updates to this Privacy Policy

This Privacy Policy may be updated to reflect changes in our personal information practices with respect to the Services, or changes in the applicable law. We will post a notice on our Services to notify you in advance of material changes to our Privacy Policy and indicate at the top of the notice the dates on which it was most recently updated.

9. Contact Us

If you have any queries in relation to this Privacy Policy or to exercise your rights in relation to your personal information, please contact us at [sales@infiniq.co.kr](mailto:sales@infiniq.co.kr) or via post 701, J-plaze, 186, Gasan Digital 1-Ro, Geumcheon-gu, Seoul, Korea You can also contact the competent data protection authority that is the responsible supervisory authority.

[For EEA Residents Only]

If you are residing in the European Union, you can also contact our representative: [INFINIQ Europe S.à r.l Sven.orjan.larsson@infiniq.eu].

10. Personal Information of Children

Our Services are designed for a general audience and are not directed towards children. If we discover that we have processed personal information of someone who is under 16, we will take reasonable steps to promptly remove that person’s personal information from our records. If you believe we are processing personal information of a person who is under the age of 16, please contact us at sales@infiniq.co.kr.