Article 1 [Purposes]

1. ① Gint Co., Ltd. (hereinafter referred to as "the Company”) collects and uses personal location information based on the consent of the service users and actively safeguards their rights (the right to self-determination regarding one’s personal information).
2. ② The Company complies with the relevant laws and regulations, including the Personal Location Information Protection Regulations and the Guidelines of the Republic of Korea, with which all providers of location information services must comply. “Personal Location Information Processing Policy” refers to the guidelines or standards that must be followed to protect users' valuable location information, enabling them to use the service with peace of mind.
3. ③ This Personal Location Information Processing Policy applies to the Daedong Connect Service and the PLUVA Auto Service (hereinafter referred to as the “Services”).

Article 2 [Purpose of Processing Personal Location Information and Period of Retention]

1. The Company uses and provides personal location information within the scope of the purposes specified in the Terms of Conditions of Use for Personal Location Information and follows the periods of retention stipulated in the relevant laws and regulations, such as the Act on the Protection and Use of Location Information.

Article 3 [Grounds for and Period of Retention of Data Verifying Collection, Use, and Provision of Personal Location Information]

1. Based on Article 16 (2) of the Location Information Act, the Company shall automatically records in its location information processing system the data certifying its collection, use, and provision of the location information of the personal location information subjects, and shall retain such data for six months or more.

Article 4 [Provision of personal location information to third parties]

1. ① In principle, the Company processes the personal location information of the personal location information subjects only within the scope of the purposes specified for its collection and use. Except in the following cases, the Company does not process or provide such information to third parties without obtaining the data subjects’ prior consent or beyond the specified purposes:

   1. When separate consent has been obtained from the personal location information subject;

   2. When otherwise provided under the relevant statutes;

   3. When it is recognized to be necessary explicitly to protect the life, bodily safety or economic profits of the data subjects or third parties from imminent risks, as the data subjects or their legal guardian or representative are unable to express their intention or their prior consent cannot be obtained due to reasons such as an unknown address;

   4. When personal location information is provided in a format that disables the identification of specific individuals for such purposes as the preparation of statistics or academic research;

   5. When it is required to investigate a crime, or to make or maintain an indictment;

   6. When it is required to facilitate court proceedings; or

   7. When it is required to execute a court sentence for punishment, custody, or protective disposition.

2. ② When the Company intends to provide a location information service to a third party designated by the personal location information subject, it shall inform the data subject of the recipient and the purpose of providing the service to that third party, and shall obtain the data subject’s consent thereto.
3. ③ When location information is provided to a third party pursuant to Paragraph 2 above, the Company shall immediately notify the subject by sending an SMS or e-mail message to the terminal device designated by the personal location information subject in advance.

Article 5 [Outsourcing of personal location information processing]

Article 6 [Rights of subjects of personal location information]

1. ① The personal location information subjects may withdraw all or part of their consent to the collection of their location information at any time.
2. ② The personal location information subjects may, at any time, request the Company to temporarily suspend its collection of their personal location information. In such a case, the Company shall not refuse such request; and it shall be equipped with the technical means to comply with such request.
3. ③ The personal location information subjects may request the Company to provide access to or notification of the data listed below, and may also request the correction of any errors found in such data: In such a case, the Company shall not refuse such request without justifiable cause.

   1. Data certifying the collection of the location information of an individual location information subject; and

   2. The reason for, and details of, the Company's provision of their personal location information to any third party under the Location Information Act or other statutes.

4. ④ When a personal location information subject wishes to withdraw all or a part of their consent to the Company's collection of their location information, the Company shall, without delay, destroy the collected personal location information and the data certifying the collection of location information. (However, this may be limited to the personal location information pertaining to the withdrawn portion if only a part of the consent is withdrawn).
5. ⑤ The personal location information subjects may request the Company, via email, telephone, personal visit, etc. to exercise their rights under the foregoing Paragraphs 1 through 4.
6. ⑥ When personal information subjects request a correction or the deletion of errors in their personal location information, the Company may restrict the related service, and it shall not use or provide the relevant personal location information until the correction or deletion has been completed.

Article 7 [Rights and obligations of the guardians and methods of exercising such rights and obligations]

1. ① The Company deems that minor information subjects (hereinafter referred to as "children aged 8 or under and other qualified persons") have also given their consent when the guardian of individuals falling under any of the categories listed below consents to the Company's collection, use, and provision of their personal location information in order to protect the life or bodily safety of children aged 8 or under and other qualified persons:

   1. Children aged 8 or under;

   2. Persons under adult guardianship; and

   3. Persons with mental disabilities as defined in Article 2, Paragraph 2, Subparagraph 2 of the Act on the Welfare of Persons with Disabilities, who also qualify as severely disabled persons under Article 2, Paragraph 2 of the Act on the Promotion of Employment of Persons with Disabilities and Vocational Rehabilitation (limited to those registered as persons with disabilities under Article 32 of the Act on Welfare of Persons with Disabilities).

2. ② To consent to the collection, use, and provision of personal location information to protect the life or bodily safety of a child aged 8 or under or other qualified persons, the guardian should attach documented evidence of their guardianship or agency to the consent form to be submitted to the Company. The guardian may exercise all of the rights of the personal location information subject when the guardian consents to the Company's collection, use, and provision of personal location information of a child aged 8 or under or other qualified persons.

Article 8 [Methods for exercising rights through legal guardians or representatives]

1. The rights of personal information subjects may be exercised through their legal representative, including their legal guardian or other delegated legal agent. In such cases, a power of attorney must be submitted in the format provided under Annex No. 11 of the Enforcement Rules of the Personal Information Protection Act.

Article 9 [Procedures and methods of destroying personal location information]

1. ① When a personal location information subject withdraws all or part of his or her consent pursuant to Article 24(4) of the Location Information Act, the Company shall promptly destroy the collected personal location information and the data certifying the Company's collection of the data subject’s location information in a manner that disables its recovery or reproduction (However, this may be limited to the relevant personal location information and related data certifying the withdrawn portion only in the case of partial withdrawal of consent.)
2. ② The Company shall promptly destroy the relevant personal location information in a manner that disables its recovery or reproduction, except for data certifying the Company's collection of location information, which it shall record and archive pursuant to Article 16 (2) of the Location Information Act when the purpose of collecting the location information has been achieved or when the personal location information subject withdraws all or part of his or her consent to the collection of his or her location information by the Company.

Article 10 [Items concerning measures for protecting personal location information]

1. The Company shall protect the location information of the personal location information subjects and implement the following security measures, which are appropriate for the protection of their personal location information, based on its policy on personal location information protection and Article 16 of the Location Information Act:
2. ① Development and implementation of internal control plans;
3. ② Encryption of personal location information;
4. ③ Implementation of technical measures against hacking, etc.;
5. ④ Restriction of access to personal location information, processing systems and procedures for identity authentication;
6. ⑤ Storage of access logs and prevention of falsification or tampering;
7. ⑥ Minimization of the personnel responsible for handling personal location information, and provision of regular training; and
8. ⑦ Periodic internal audits and administrative protective measures.

Article 11 [Persons responsible for protecting personal location information]

1. Users may contact the Location Information Manager or the Customer Service Center regarding all matters arising during the Company's protection of their personal location information or other matters pertaining to the protection of their personal location information, including inquiries, complaint handling, and damage relief. The Company shall respond promptly and handle effectively all issues or questions reported by the users.
2. ① The Company providing the services under these Terms and Conditions:

   ㆍCompany name: Gint Co., Ltd.

   ㆍAddress: 4th Floor, Building 1, 2nd Complex, Pangyo Seven Venture Valley, 17 Pangyo-ro 228-gil, Bundang-gu, Seongnam-si, Gyeonggi-do, Korea

   ㆍWebsite: http://www.gintlab.com/

3. ② The Company appoints the Location Information Manager to protect personal location information and efficiently handle complaints filed by personal location information subjects. The relevant information is as follows:

   ㆍLocation Information Manager: Kim Yong-hyun, CEO

   ㆍPhone No.: 031-212-4994

   ㆍE-mail: support@gintlab.com

Article 12 [Method of exercising rights by personal location information subjects]

1. The personal location information subjects may exercise their rights under Article 24 of the Location Information Act against the following department: The Company shall ensure that their rights are processed promptly.

   ㆍDepartment Name: Service Development Team

   ㆍContact: Lee Se-hwan

   ㆍPhone No.: 070-4225-4120

   ㆍE-mail: bpd@gintlab.com

   ㆍFax : 031-212-7840

Article 13 [Amendment of the personal location information processing policy]

1. The Company may amend its Personal Location Information Processing Policy to reflect changes in laws or services. Upon amending the Policy, the Company shall post the details of any changes, which shall take effect seven days thereafter. However, when a significant change is deemed likely to affect the users' rights, such as changes in the personal information items to be collected and the purpose of their use, the Company shall notify the users at least 30 days in advance.

   ㆍEnforcement data of Personal Location Information Processing Policy: 2024.12.16.