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Privacy Policy

Spero Inc. (hereinafter referred to as “Spero”) legally processes and safely manages personal information in compliance with the 「Personal Information Protection Act (개인정보보호법)」 and related laws to protect the freedom and rights of information subjects. Accordingly, in accordance with Article 30 of the 「Personal Information Protection Act」, the following personal information processing policy is established and disclosed to guide information subjects on the procedures and standards for personal information processing and to quickly and smoothly handle complaints related to this.

Article I. Purpose of personal information processing, collection items, retention and use period 

  1. Spero processes the personal information of the data subject as follows. The personal information being processed will not be used for any purpose other than the following, and if the purpose of use is changed, necessary measures such as obtaining separate consent in accordance with Article 18 of the 「Personal Information Protection Act」 will be implemented.

  2. Spero processes and retains personal information within the period of retention and use of personal information in accordance with laws and regulations or within the period of retention and use of personal information agreed upon when collecting personal information from the information subject.

  • Information Subject: Solution users​

    • Purpose of processing

      • Member identification, confirmation of sign-up intention, identity verification, fraudulent use prevention, service provision​

      • Service quality improvement, research and analysis for new service development, customized service and report provision

      • Customer support service 

    • Processing items

      • Required: Name, email, contact information, IP address, browser and device identifier and operating system

      • Optional: cookie, access log, service use record, company name

    • Retention and use period: until service supply is completed, fee settlement is completed, membership is withdrawn, and the deadline of relevant laws and regulations are expired

Article II. Matters concerning entrustment of personal information management

  1. Spero entrusts the following personal information processing tasks for smooth personal information processing​

  • Trustee: SPERO Inc.

  • Entrusted affirs:

    • ​Provide cloud server and web hosting service;

    • Processing of personal information to provide customer support services;

    • Technical measures related to securing the safety of personal information (management of access rights such as personal information processing system, installation of access control system, encryption of personal information, installation and renewal of security program)

  • Retention and use period: until the end of the consignment contract

2. When signing a consignment contract, in accordance with Article 26 of the 「Personal Information Protection Act」, Spero makes sure that matters related to the prohibition of processing of personal information other than the purpose of performing the entrusted work, technical and administrative protection measures, restrictions on re-entrustment, management and supervision of the trustee, and compensation for damages are specified in documents such as contracts and supervise whether the trustee handles personal information safely.

3. If the contents of the consignment work or the consignee is changed, we will disclose it through this privacy policy without delay.

Article III. Matters concerning overseas transfer of personal information (provision and storage)

  1. Spero provides personal information to overseas third parties as follows and may process the personal information of the information subject on a server located outside the country where the information subject resides.

  • Amazon Web Services, Inc. (https://aws.amazon.com/ko/compliance/data-privacy/)

  • The purposes of use of the corporation to whom the personal information is to be transferred: provision of cloud server and web hosting service

  • Items of the personal information to be transferred: name, email, contact information

  • Countries where the personal information is to be transferred: Japan, Singapore

  • Date and time, and methods of transfer: Transmission through the network at the time of service use

  • Retention and use period: consistent with the storage period stipulated in this privacy policy

Article IV. Matters concerning procedures and methods of destruction of personal information 

  1. Spero destroys the personal information without delay when the personal information becomes unnecessary, such as the expiration of the personal information retention period or achievement of the purpose of processing. 

  2. If the personal information retention period agreed by the information subject has elapsed or the purpose of processing has been achieved, if personal information needs to be kept according to other laws, the personal information may be moved to a separate database (DB) or stored in a different location. Preserved. 

  3. The procedure and method of personal information destruction are as follows. 

  • Destruction procedure

    • Spero selects the personal information for which the reason for destruction occurred, and destroys the personal information with the approval of the person in charge of personal information protection.

  • How to destroy

    • Spero destroys personal information recorded and stored in the form of electronic files so that the record cannot be reproduced, and personal information recorded and stored in paper documents is destroyed by shredding or incineration.

Article V. Rights and Duties of Information Subjects and Legal Representatives and Method of Exercising 

  1. The information subject can exercise the right to view, correct, delete, or stop processing of personal information at any time with respect to Spero. 

  2. You can exercise your rights through e-mail in accordance with Article 41, Paragraph 1 of the Enforcement Decree of the 「Personal Information Protection Act」 with respect to Spero, and Spero will take action without delay. 

  3. The exercise of rights may be done through an agent such as the legal representative of the information subject or a person who has been delegated. In this case, you must submit a power of attorney in the form of Attachment No. 11 of the “Personal Information Handling Method Notice (No. 2020-7)”. 

  4. The rights of the information subject may be restricted in accordance with Article 35 (4) and Article 37 (2) of the 「Personal Information Protection Act」. 

  5. Request for correction and deletion of personal information cannot be requested if the personal information is specified as a collection target in other laws. 

  6. Spero checks whether the person who made the request, such as a request for access, a request for correction/deletion, or a request for suspension of processing, is the person or a legitimate agent according to the right of the information subject. 

Article VI. Measures to ensure the safety of personal information 

Spero takes the following measures to ensure the safety of personal information. 

  1. Administrative measures: establishment and implementation of internal management plan, operation of a dedicated organization, regular employee training 

  2. Technical measures: Not applicable (Consignment to CRScube Inc.)

  3. Physical measures: Not applicable (Cloud service use) 

Article VII. Matters concerning installation, operation and rejection of automatic personal information collection device 

  1. Spero uses 'cookies' to store and retrieve usage information from time to time to provide users with individually customized services. 

  2. A cookie is a small amount of information sent by the server (http) used to operate the website to the user's computer browser and is also stored on the hard disk of the user's PC computer. 

  3. Purpose of use of cookies: It is used to provide optimized information to users by identifying the types of visits and usage, popular search terms, and secure access to each service and website visited by the user.

  4. Installation, operation, and rejection of cookies: You can refuse to save cookies by setting options in Tools>Internet Options>Personal Information menu at the top of the web browser. 

  5. If you refuse to store cookies, you may experience difficulties in using customized services. 

Article VIII. Personal Information Protection Officer 

  1. Spero is responsible for overall handling of personal information, and has designated a person in charge of personal information protection as follows to cope with complaints and damage relief from information subjects related to personal information processing.

  • Dept. in charge: Development ​team (in charge of personal information inspection request, consulting and reporting related to personal information protection)

  • Person in charge: Development Team Manager 

  • Contact information

2. The information subject may inquire about all personal information protection-related matters, complaint handling, damage relief, etc. that occurred while using Spero's service to the person or the department in charge of personal information protection. Spero will answer and handle inquiries from the information subject without delay. 

Article IX. Remedies for Infringement of Rights and Interests of Information Subjects 

  1. The information subject may apply for dispute resolution or consultation with the following organizations in order to receive relief from personal information infringement. The following institutions are separate from Spero, and if you are not satisfied with Spero's own personal information-related complaint handling and damage relief results, or if you need more detailed help, please contact us. 

  2. Personal Information Dispute Mediation Committee: (without area code) 1833-6972 (www.kopico.go.kr)  

  3. Privacy Infringement Report Center: (without area code) 118 (privacy.kisa.or.kr)  

  4. Cyber Investigation Division, Supreme Prosecutors' Office: (without area code) 1301 (www.spo.go.kr)  

  5. National Police Agency Cyber Security Bureau: Police Civil Service Call Center (without area code) 182 (ecrm.police.go.kr)  

  6. 「Personal Information Protection Act (개인정보보호법)」 Article 35 (Perusal of personal information), Article 36 (Correction and deletion of personal information), Article 37 (Suspension of processing of personal information, etc.) A person whose rights or interests have been infringed due to disposition or omission may file an administrative appeal in accordance with the Administrative Appeals Act. 

  7. Central Administrative Tribunal: (without area code) 110 (www.simpan.go.kr)  

Article X. Change of Privacy Policy 

  1. This Privacy Policy is effective from 15 September 2023 

  2. The previous version of privacy policy can be found as below.

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