We, at Noul Co., Ltd. (“NOUL”, “We”, “our” or “us”), respect your privacy and are strongly committed to keeping secure any information we obtained from you or about you. This Privacy Policy (the “Privacy Policy”) explains our practices with respect to personal information we collect from or about you when you use our website and services (collectively, the “Service(s)”).

TYPES OF INFORMATION WE COLLECT

We collect information that alone or in combination with other information in our possession could be used to identify you (“Personal Information”) as follows:

• Information provided by the users
  : NOUL may collect Personal Information directly provided by the users.

• Information collected while the users use services
  : When you visit, use and interact with the Services, NOUL may receive information about your visit, use or interactions.

HOW WE COLLECT YOUR INFORMATION

• We collect information you provide to use when you register online product inquiry or submit your job resume and cover letter.
• We collect information through a variety of technologies, such as cookies, pixels, tags, software development kits, and Web beacons, including when you visit our website via your browser. 
• We collect information using analytics tools, including when you visit our websites on third-party sites or platforms.

HOW WE USE YOUR INFORMATION

NOUL uses the collected information of users for the following purposes:

• To respond to the inquiries about products or services.
• To provide with the customer complaints services.
• To proceed the recruitment process and guide through the recruitment process steps.
• To send NOUL Newsletter and other news.
• To provide, administer, maintain, improve and/or analyze the services. 
• To make statistics on user’s website usage, to improve the Services based on statistical characteristics.
• To comply with applicable laws or legal obligations.

NOUL agrees that it will obtain a consent from the users, if NOUL desires to use information other than those expressly stated in this Privacy Policy.

DISCLOSURE OF COLLECTED INFORMATION

In certain circumstances we may provide your Personal Information to third parties without further notice to you, unless required by the applicable laws:

• Partners and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may provide Personal Information to partners and services providers, including but not limited to, providers of hosting services, cloud services, customer relationship management services and other information technology services providers. Pursuant to our instructions, these parties will access, process, or store Personal Information only in the course of performing their duties to us.
• Business Transfer: If we are involved in strategic transactions, reorganization, bankruptcy, receivership, or transition of service to another provider (collectively a “Transaction”), your Personal Information and other information may be disclosed in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of that Transaction along with other assets.
• Legal Requirements: If required to do so by applicable laws or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Services, or the public, or (v) protect against legal liability.

COOKIES, BEACONS AND SIMILAR TECHNOLOGIES

NOUL may collect collective and impersonal information through ‘cookies’ or ‘web beacons’. Cookies are very small text files to be sent to the browser of the users by the server used for operation of the website of NOUL and will be stored in hard-disks of the user’s computer. Web beacons are small quantity of codes which exist on the websites and e-mails. By using web beacons, we may know whether a user has interacted with certain websites or the contents of e-mail. These functions are used for evaluating, improving services and setting-up user’s experiences so that much improved services can be provided by NOUL to the users.

The items of cookies to be collected by NOUL and the purpose of such collection are as follows:

The users have an option for cookie installation. So, they may either allow all cookies by setting option in web browser, make each cookie checked whenever it is saved, or refuses all cookies to be saved: Select “Chrome Setting and Control“ (at the upper-right side of the web browser) > “Setting” > “Advanced” > “Contents Setting” in the “Personal Information and Security” section > select setting in the cookie section. Provided, however that, if the user rejects the installation of cookies, it may be difficult for that users to use the parts of services provided by NOUL.

YOUR RIGHTS

Depending on location, individuals in the EEA, the UK, and across the globe may have certain statutory rights in relation to their Personal Information. For example, you may have the right to:

• Access your Personal Information.
• Delete your Personal Information.
• Correct or update your Personal Information.
• Transfer your Personal Information elsewhere.
• Withdraw your consent to the processing of your Personal Information where we rely on consent as the legal basis for processing.
• Object to or restrict the processing of your Personal Information where we rely on legitimate interests as the legal basis for processing.

You can exercise some of these rights through your account. If you are unable to exercise your rights through your account, please send your request to privacy@noul.com.

DATA SECURITY, INTEGRITY, AND RETENTION

The security, integrity, and confidentiality of your information are extremely important to us. We have implemented technical, administrative, and physical security measures that are designed to protect guest information from unauthorized access, disclosure, use, and modification. We regularly review our security procedures to consider appropriate new technology and methods. Please be aware that, despite our best efforts, no security measures are perfect or impenetrable. We will retain your Personal Information for the length of time needed to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

CHILDREN’S PRIVACY

In principle, NOUL does not collect any information from the children under 13 or equivalent minimum age as prescribed in the laws in relevant jurisdiction. The website and services of NOUL are the ones to be provided to ordinary people, in principle. NOUL does not intentionally collect any Personal Information from children through its website.

However, if NOUL collects any Personal Information form children under 13 or equivalent minimum age as prescribed in the laws in relevant jurisdiction for the services for unavoidable reason, NOUL will go through the additional procedure of the followings for protecting that Personal Information of children:

• Verify, to the extent that efforts are reasonably made, whether they are children of the age at which consent from their guardian is required and the consenting person is an authorized one.
• Obtain consent from the parents or guardian of children so as to collect Personal Information of children or directly send information of products and services of NOUL.
• Give the parents or guardian of children a notice of NOUL’s policy of privacy protection for children including the items, purpose and sharing of Personal Information collected.
• Grant to legal representatives of children a right to access to Personal Information of that children/correction or deletion of Personal Information/temporary suspension of treatment of Personal Information/and request for withdrawal of their consent provided before.
• Limit the amount of Personal Information exceeding those necessary for participation in online activities.

LINKS TO OTHER WEBSITES

The Service may contain links to other websites not operated or controlled by NOUL, including cloud servers (“Third Party Sites”). Information that you share with Third Party Sites will be governed by the specific privacy policies and terms of services of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.

INTERNATIONAL USERS

By using our Service, you understand and acknowledge that your Personal Information will be transferred from your location to our facilities and servers.

For EEA, UK or Swiss users:

Legal Basis for Processing.  Processing Personal Information by NOUL shall be lawful only if and to the extent that at least one of the following applies:

• A user has given consent to the processing of his or her Personal Information.
• Processing is necessary for the performance of a contract to which a user is a party or in order to take steps at the request of a user prior to entering into a contract:
  • Member management, identification, etc.
  • Performance of a contract in relation to providing the services required by users, etc.
• Processing is necessary for compliance with a legal obligation to which NOUL is subject:
  • Compliance with relevant laws, regulations, legal proceedings, requests by the government.
• Processing is necessary in order to protect the vital interests of users, or other natural persons:
  • Detection of, prevention of, and respond to fraud, abuse, security risks, and technical issues that may harm users or other natural persons.
• Processing is necessary for the performance of a task carried out in the public interest or in the excise of official authority vested in NOUL.
• Processing is necessary for the purposes of the legitimate interests pursued by NOUL or by a third party (except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of Personal Information, in particular where the data subject is a child).

User’s rights when applying GDPR.  The users or their legal representatives, as main agents of information, may exercise the following rights regarding the collection, use and sharing of Personal Information by NOUL:

• The right to access to Personal Information: The users or their legal representatives may access information and check the records of the collection, use and sharing of such information under the applicable laws.
• The right to rectification: The users or their legal representatives may request to correct inaccurate or incomplete information.
• The right to erasure: The users or their legal representatives may request the deletion of information after the achievement of their purpose and the withdrawal of their consent.
• The right to restriction of processing: The users or their legal representatives may make temporary suspension of treatment of Personal Information in case of the disputes over the accuracy of information and the legality of information treatment, or if necessary to retain such information.
• The right to data portability: The users or their legal representatives may request to provide or transfer information.
• The right to object: The users or their legal representatives may suspend the treatment of Personal Information if such information is used for the purpose of direct marketing, reasonable interests, the exercise of official duties and authority, and research and statistics.
• The right to automated individual decision-making, including profiling: The users or their legal representatives may request to cease the automated treatment of Personal Information, including profiling, which has critical impact or cause legal effect on them.

If, in order to exercise the above rights, you may send an e-mail to NOUL (person in charge of management of Personal Information or a deputy), NOUL will take measures without delay; Provided that, NOUL may reject the request of you only to the extent that there exists either proper cause as prescribed in the applicable laws or equivalent causes.

Data transfer to other countries.  Considering it engages in global business, NOUL may provide the user’s Personal Information to the companies located in other countries for the purposes as expressly stated in this Privacy Policy. For the places where the Personal Information is transmitted, retained or processed, NOUL takes reasonable measures for protecting those Personal Information.

For the users in the Republic of Korea:

Information collected.  The items collected by NOUL are as follows:

Provision of Personal Information to third parties.  Personal Information of the users will be used by NOUL solely for the purposes set forth in above. NOUL will not use Personal Information beyond the original scope of such purpose or transfer personal information to any third party except allowed by Article 17 and 18 of Korean Personal Information Protection Act. 

NOUL will inform the data subject of the following when obtaining consent under Article 17 of Korean Personal Information Protection Act. If there is any change in any of the following, NOUL will inform the data subject of such change and obtain consent therefrom:

• The person who are provided with Personal Information;
• The purposes of using Personal Information by the person to whom Personal Information is provided;
• Items of Personal Information that is provided;
• The recipient’s retention period of the Personal Information; or
• The fact that the data subject is entitled to refuse to grant consent and the details of disadvantage (if any) arising from a refusal to grant consent.

Commission for collected Personal Information.  For carrying out the Services, NOUL commissions external professional companies to process Personal Information as follows. This commissioned works for processing Personal Information is carried out by each subcontractor and service only if necessary for providing that service.

Also, for carrying out the recruitment process, NOUL commissions external professional companies to process Personal Information as follows. This commissioned works for processing Personal Information is carried out by each subcontractor and service only if necessary for providing that service.

In commissioning process of Personal Information, in order to secure safety of Personal Information, NOUL supervises and ensure to expressly state in the agreement with subcontractors so that those subcontractors will safely process Personal Information by strictly complying with directions regarding Personal Information protection, keeping Personal Information secret, not disclosing it to a third party and being liable for accidents and returning or destructing Personal Information upon termination of the commission or process.

The Users and their legal representatives’ rights and obligations. The users or their legal representatives may exercise the following rights regarding the collection, use and sharing of Personal Information by NOUL:

• right to access to Personal Information, right to rectification, right to erasure, right to restriction of processing, etc.

The users or their legal representatives may exercise the foregoing rights by giving written notice or sending e-mail to NOUL in accordance with Article 41(1) of the Enforcement Decree of the Personal Information Protection Act, and NOUL will take measures without delay. You may exercise the foregoing rights through your legal representative, any other appointee or agent, subject to the submission of a power of attorney in the form of Form No. 11 of the Enforcement Rules to the Personal Information Protection Act, and NOUL will verify whether the person making a request under the above rights is the data subject themselves or a legitimate representative. 

Requests for access to Personal Information or cease processing may be restricted under Article 35(4) and 37(2) of the Personal Information Protection Act. If the Personal Information is explicitly designated as a collection target in other laws, deletion of such Personal Information cannot be demanded.

Procedure and method of destruction of Personal Information.  NOUL will promptly destroy Personal Information that is no longer needed, including when the purpose of collecting Personal Information is achieved or the foregoing retention period is expired. Notwithstanding the foregoing, if Personal Information must be retained pursuant to other laws, such Personal Information shall be transferred to a separate database or stored in a different location for retention. NOUL selects Personal Information for destruction when the reason for destruction occurs and destroys of Personal Information with the approval of NOUL’s Privacy Officer. The printouts, documents, etc. on which Personal Information is written shall be destroyed through crushing or incineration, and any Personal Information in an electronic file shall be destroyed by deleting such information permanently in a way that is impossible to restore such Personal information.

Personal Information transfer to other countries.  For carrying out the Services, NOUL transfers the user’s Personal Information to external professional companies located in other countries than the Republic of Korea as follows: 

Also, for carrying out the recruitment process, NOUL transfers the user’s Personal Information to external professional companies located in other countries than the Republic of Korea as follows:

The country, time and method of transfer of Personal Information are as follows:

The users may refuse the foregoing data transfer to other countries than the Republic of Korea by giving written notice or sending e-mail to NOUL’s Department responsible for the protection of Personal Information. However, if you refuse, it may be difficult to process the product inquiries or complaint services, or proceed with recruitment procedures.

Technical, managerial and physical measures for protection of Personal Information.  In order to prevent the loss, theft, leakage, alteration or damage of Personal Information of the users, NOUL takes technical, managerial and physical measures for securing safety as follows:

MODIFICATION OF PRIVACY POLICY

NOUL may change this Privacy Policy at any time. When we do, we will post an updated version on this page, unless another type of notice is required by applicable laws. By continuing to use our Service or providing us with Personal Information after we have posted an updated Privacy Policy, or notified you by other means, you consent to the revised Privacy Policy.

HOW TO CONTACT US

If you have any questions about NOUL’s Privacy Policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.

• Privacy Officer
  • Name: Kyung Hwan Kim
  • Title: Chief Legal Officer
  • E-mail: privacy@noul.com
• Department responsible for the protection of Personal Information
  • Department: IT/Security
  • Person in charge: Sangsu Nam
  • E-mail: privacy@noul.com