This policy will be effective on May 8, 2018.
1. Purpose of Processing Personal Information
FRONTEO Korea processes personal information of the Users for the purposes as specified below. FRONTEO Korea does not process or share the personal information of the Users beyond the original scope of purposes without prior consent of the Users.
A. Providing Goods and Services
FRONTEO Korea processes personal information of the Users for purpose of providing services and contents such as a customer survey and to enhance service qualification.
B. Use for Marketing and Advertising
FRONTEO Korea processes personal information for the purpose of developing service and serving customized service, offering advertising or event information and participation opportunities, providing service or promotion by demographic characteristics, checking the validity of the service, identifying the frequency of website access or statistics about the use of the member’s services, etc.
2. Method of Processing Personal Information and Retention Period
A. FRONTEO Korea processes and retains the personal information of the Users within the period of use and retention that is agreed upon when collecting the information from the Users subject to statutes and any other applicable laws.
B. Processing and Retention Period
FRONTEO Korea will hold and use personal information from the date on which the User consents to the collection and use of the personal information to the time of attaining the purpose of use or withdrawal of the consent by the User.
3. Providing Personal Information for Third Parties
A. FRONTEO Korea will use or provide the User’s personal information to any other corporation or institution only for the scope set forth in the purpose of collection and use of personal information with the Users’ consent and under the applicable laws and regulation.
B. FRONTEO Korea entrusts the processing of personal information of the Users to entrusted entities as shown below:
– Entrusted Entity: Netpathy Maillink
– Description of Service Entrusted: Email Service
– Period of Processing and Retention: Immediately after the service delivered
4. Items of Personal Information to be Processed
The items of personal information to be processed by FRONTEO Korea are as follows:
– Required Items: Name and e-mail address
– Optional Items: Mobile phone number, work phone number, job position and title in a company
5. Destruction of Personal Information
FRONTEO Korea shall destroy all personal information without delay when the retention of personal information is no longer necessary, where the purposes of processing personal information have been accomplished or the applicable Users have withdrawn their consents on the retention of their personal information.
– Storage Procedure
Personal information provided by the Users for use of the services will be placed in a separated/disconnected data-server (or filing cabinet in case of Personal Information printed on paper) and stored for a certain period of time based on grounds for information protection provided in FRONTEO Korea’s internal policy and other applicable laws and regulations.
– Period of Destruction
FRONTEO Korea will destroy personal information within 5 days from the end of the retention period or if personal information becomes unnecessary, such as the attainment of the purpose of processing personal information, the abolition of the service, and the termination of the business.
– Destruction Method
Personal information stored in electronic files will be discarded using technical methods preventing restoration.
Personal information printed on paper will be discarded by shredding or incineration.
6. Installation/Operation of Automatic Personal Information Collection Equipment and Objection Thereto
7. Personal Information Protection Managers
A. The personal information protection manager and the person in charge of receiving and dealing with requests for inspection of personal information of FRONTEO Korea are as follows.
▶ Personal Information Protection Manager
Name: Shirai Yoshikatsu
Contact: firstname.lastname@example.org, tel. 02-350-3000, fax. 02-3288-3363
▶ Person in Charge of Personal Information Protection
Name: David Lee
Team/Title: Strategic Marketing / Manager
Contact: email@example.com, tel. 02-350-3000, fax. 02-3288-3363
B. The Users can inquire about personal information protection related complaints, complaint handling, damage relief, etc. when using the service (or business) of FRONTEO Korea. FRONTEO Korea will respond without delay to inquiries from the Users.
This Policy is effective from the effective date (May 8, 2018). FRONTEO Korea will notify 7 days prior to the implementation of any changes including additions, deletions or corrections are made in accordance with the laws and policies.
9. Security Measures for Protection of Personal Information
FRONTEO Korea shall take technical, administrative and physical measures necessary to secure safety as follows under Article 29 of the Personal Information Protection Act.
A. Regular Self-Audit Execution
FRONTEO Korea conducts self-audits regularly (quarterly) to ensure the safety of handling personal information.
B. Minimizing and Training of Personal Information Handling Staff
Employees who deal with personal information are designated and limited to the person in charge, and measures are taken to minimize personal information.
C. Establishment and implementation of internal administration plan
FRONTEO Korea has established and is implementing an internal administration plan to safely manage personal information.
D. Installation and operation of security program
FRONTEO Korea installed security program to prevent leakage and damage of personal information due to hacking, computer virus, etc. and regularly updates and inspects such program. FRONTEO Korea installs the security program within the area where external access is limited and monitors the security program technically and physically and blocks external access.
E. Encryption of personal information
FRONTEO Korea encrypts out of the personal information of subjects of personal information to store and manage such information and perform additional security functions by encrypting files and transmission data of important data.
F. Keeping of access record and prevention of forgery or alteration
FRONTEO Korea keeps and manages the record of access to personal information management system for at least six months and uses security features to prevent forgery, alteration, theft or loss of access record.
G. Access control and restriction on access right
FRONTEO Korea takes measures necessary to control access to personal information by granting, changing or cancelling accessing right to database system that manages personal information and controls unauthorized access from outsiders by using firewall system.
H. Prevention of physical access
FRONTEO Korea keeps the documents, auxiliary storage device, etc. containing personal information in a safe place with locking system.
I. Access control to unauthorized persons
FRONTEO Korea has set up a separate physical storage area for personal information and set up access control procedures.
10. Remedies for Infringement on Rights and Interests
If you need to report or have consultation regarding any invasion of privacy, please contact the following agencies and institutions:
▶ Personal Information Infringement Reporting Center of Korean Internet Security Agency: 118 (http://privacy.kisa.or.kr)
▶ Personal Information Dispute Mediation Committee: 1833-6972 (www.kopico.go.kr)
▶ High-Technology Crime Investigation Division of Supreme Prosecutors’ Office: 02-3480-3573 (www.spo.go.kr)
▶National Police Agency Cyber Bureau: 182 (http://cyberbureau.police.go.kr)