Privacy Policy

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LOTTE Property&Development Inc.(hereinafter referred to as ‘the company’) abides by the relevant guideline and jurisdiction of personal information protection regulations such as 「Personal Information Protection Act」, 「Act on Promotion of Information and Communications Network Utilization and Information Protection」 and so on. The company also considers customers’ privacy important and does its best to protect the personal information the customers provide online while they use its services.

The company informs the customers the purposes and methods of using their personal information based on Privacy Policy and the measures it takes to protect their privacy.

The company encourages the customers to read this policy whenever they want by making it public on online services. If the Privacy Policy changed, it will be noticed on the services. This policy applies to LOTTE Property & Development, LOTTE World Tower & Mall, Workflex, SKY31 convention, Residence online services. The Privacy Policy can be changed due to the relevant guideline and jurisdiction of personal information protection regulations or the company’s internal policies.

[Indication of Major Personal Information Processing(Labeling)]

Purpose of Personal Information Processing
Personal Information Retention Period
Personal Information Processing Items
Personal Information
personal video information
Outsourcing and Overseas Transfer of Personal Information Processing
Provision of Personal Information to Third Parties
Automatic Collection of Personal Information
Destruction of Personal Information
Rights and Obligations of the Information Subject
Measures to Ensure Safety
Personal Information Protection Manager
Relief for Infringement of Rights and Interests
Image Information Processing Device
Revision of Personal Information Processing Policy

Article 1 (Purpose of Personal Information Processing)

The company collects personal information to provide various and convenient Internet services to customers.
The collected personal information will be used only for the following purposes and necessary measures will be implemented when changing the purpose of use.

A. Customer identification and response to customer inquiries
B. Contract signing and facility access card registration
C. Handling of complaints, prevention of illegal and unauthorized use of defective members

Article 2 (Personal Information Retention Period)

The company destroys personal information without delay when the purpose of collection is achieved.
However, in order to prevent the recurrence of illegal use of defective members, personal information may be preserved for three months after the termination of the use contract. Also, if it is necessary to preserve it according to the relevant laws, it shall be preserved for a certain period. In this case, the company uses personal information only for the purpose of storing it. In accordance with Article 15-2 of the Communications Secret Protection Act, the names, contact information, and e-mails necessary to provide communication fact-checking data shall be kept for 12 months.

개인정보의 처리 및 보유기간 내용에 관한 표
Category	Retention reason	Retention period
LOTTE Property&Development website	Receiving internal complaints	1 year
	For Partners Only	Destroy after 3 years from the date of collection
	For Tower tenants only	3 years (Workplex, SKY31 convention 1 month)
	Receiving Real Estate Information Subscription applications	Destroy immediately upon withdrawal from subscription
LOTTE World Tower & Mall website	Receiving Voice of Customers inquiries	3 years from the date of collection
	Receiving business inquiries	3 years from the date of collection
	Inquiries regarding parking refunds	3 years after the purpose is achieved (vehicle numbers are kept for 1 year)
SKY31 convention website	Receiving inquiries	Destroy within 1 month of receipt of the inquiry
	Signing contracts	5 years (according to 「Act on Consumer Protection in the Electronic Commerce Transactions」)
	In case of deposit refund	Destroy within 1 month after receiving the refund account
Workflex website	Receiving inquiries	Destroy within 1 month of receipt of the inquiry
	Signing contracts	5 years (according to 「Act on Consumer Protection in the Electronic Commerce Transactions」)
	In case of deposit refund	Destroy within 1 month after receiving the refund account
	Registering for the office access system	Destroy immediately when the purpose is achieved(within 1 month of contract expiration)
Common	Receiving customer complaints and disputes	3 years (according to 「Act on Consumer Protection in the Electronic Commerce Transactions」)
	Paying and Supplying of goods	5 years (according to 「Act on Consumer Protection in the Electronic Commerce Transactions」)
	Receiving surveys and event applications	Destroy immediately when the purpose is achieved(within 1 month of termination)

Article 3 (Personal Information Processing Items)

The company collects and uses the following personal information to provide various and convenient Internet services to customers.

A. We only process the minimum amount of personal information necessary to process personal information consent forms and contracts.

개인정보의 처리 및 보유기간 내용에 관한 표
Category	Contents	Required Information
LOTTE Property & Development website	Receiving internal complaints	(Essential) name, phone number, e-mail address
	For Partners Only	(Essential) name, phone number, e-mail address
	For Tower tenants only	(Optional) name, phone number, e-mail address
	Receiving Real Estate Information Subscription applications	(Essential) name, e-mail address (Optional) corporate name
LOTTE World Tower & Mall website	Receiving Voice of Customers inquiries	(Essential) name, phone number, e-mail address
	Receiving business inquiries	(Essential) name, phone number, e-mail address
	Inquiries regarding parking refunds	(Essential) name, car number, phone number, e-mail address, Account number, bank name, depositor name
SKY31 convention website	Receiving inquiries	(Essential) name, corporate name(when a person in charge of a corporation inquires), phone number, e-mail address, inquiry and contract history
	Signing contracts	(Essential) name, corporate registration number(when a person in charge of a corporation signs), birth date(when an individual signs), phone number, e-mail address
	In case of deposit refund	(Essential) Account number, bank name, depositor name
Workflex website	Receiving inquiries	(Essential) name, corporate name, e-mail address, phone number
	Signing contracts	(Essential) name, address, phone number, birth date, e-mail address, corporate name
	In case of deposit refund	(Essential) Account number, bank name, depositor name
	Registering for the office access system	(Essential) name, corporate name, phone number

B. In accordance with Article 32 of the Value Added Tax Act and Article 67 of the Enforcement Decree, unique identification information (resident registration number) is processed only for individual business owners for the purpose of issuing tax invoices.

Article 4 (Provision of Personal Information to Third Parties)

The company does not provide the customers’ personal information to third parties without notice.
However, except for followings.

A. When the customer agrees in advance
B. When a request is made by an investigative agency in accordance with the relevant guideline and jurisdiction of personal information protection regulations
C. When necessary for service charge
D. When necessary for the fulfillment of the contract
E. When there are sufficient grounds for disclosing the customer’s information in order to take legal action against it by causing mental and material damage to another person
F. When provided unidentifiably for statistics, marketing analysis and market research
G. When necessary for fulfillment of the contract related to services and extremely difficult to obtain normal consent due to economic or technical reasons

Article 5 (Entrustment of Personal Information Processing)

The company entrusts some personal information processing tasks to external companies to provide services. In this case, necessary measures are taken to ensure that personal information is safely managed in accordance with relevant laws. The company entrusts and processes personal information to the minimum extent necessary for smooth service provision. In the event of a change of trustees and consignment work, disclosure will be made through this policy without delay. - The Company outsources the processing of personal information as below for smooth job performance.

the purpose of consignment
Outsourced company	Outsourced task	Retain and Use period
LOTTE Innovate	Computing Systems Operation	Destroy immediately at the end of the contract
Daehong communications	Skyrun event operation and participant management, and LWT event operation agency work	Destroy immediately at the end of the contract
LOTTE Shopping	LOTTE World Mall Operation, Sales Analysis, Customer Analysis, VIP Selection, Customer Contact Services, Tenant and Safety Management	Destroy immediately at the end of the contract
The man	Security service(parking)	1 year
S-Tec system	Security service(security)	1 year
Proscom	Security service(security)	1 year
housetalk	Receiving and responding to defect complaints after moving in	Destroy immediately at the end of the contract
Hucorp	CCTV management Operate elevators and monitor safety	Destroy immediately at the end of the contract
Otis Elevator Korea	CCTV management Operate elevators and monitor safety	Destroy immediately at the end of the contract
ipinlabs	Development and provision of a biometric location-based worker safety and health management system	Destroy immediately at the end of the contract

Article 6 (Destruction of Personal Information)

The Company will destroy the information without delay once the purpose of collecting and using personal information has been achieved. However, if it is required to be stored according to other related laws, the personal information is moved to a separate database or stored in another storage location. The destruction procedure and method are as follows.

A. Destruction procedure
- - The information entered at the time of the inquiry will be transferred to another DB(another document box in the case of paper) after the purpose has been achieved and destroyed after being stored for a certain period based on the internal policy and other information protection grounds according to related laws(retention and refer to usage period)
- - The personal information separately transferred to the DB will not be used for any other purpose other than the possession unless it is required by law.
B. Destruction method
- - The personal information output on paper will be shredded by a shredder or destroyed through incineration.
- - Personal information stored in the form of electronic files will be deleted using technical methods that do not allow the recording to be replayed

Article 7 (Automatic Collection of Personal Information)

The company uses cookies that stores information related to users and find it frequently. A cookie is a very small text file sent to the browser on user's computer by the server used to operate the company's website and stored on users computer's hard disk.

A. Purpose of using cookie
- - Save settings customized by the user.
B. Cookie Settings
- 1) How to allow cookies(In case of using Explorer 9.0 or higher)
  Click Start> Control Panel> Internet Options. Click the "Personal Information" tab. Adjust the meter in "Settings" and set the level that allows cookies that suit users.
- 2) How to see received cookies(In case of using Explorer 9.0 or higher)
  Click Start> Control Panel> Internet Options. Click the General tab. Click the "Settings" button in "Search History". Click the “View File” button to confirm.
- 3) How to reject setting cookies(In case of using Explorer 9.0 or higher)
  Click Start> Control Panel> Internet Options. Click the "Personal Information" tab. Set the meter in "Settings" to a higher level and set it to "Block all cookies".

Article 8 (Rights and Obligations of the Information Subject)

A. The information subject(user), the legal representative of a child under the age of 14, may exercise the rights related to personal information protection(access to personal information, correction or erasure of personal information, suspension of processing of personal information) at any time, and the procedure is as follows.
- 1) Personal information can be accessed, corrected, or erased if a request is made to the person in charge of personal information management by e-mail or in writing, we will read, correct, or erase it after confirming the identity.
- 2) If the information subject(user) or the legal representative of a child under the age of 14 requests correction or deletion of an error in personal information, the company does not use or provide the personal information until the correction or erasure is completed.
B. The exercise of rights pursuant to “A” can be done through an agent, such as a legal representative of the information subject or a person who has been delegated. In this case, the information subject(user) must submit a power of attorney in accordance with the form of the Enforcement Rules of the Personal Information Protection Act.
C. The information subject(user) has the right to have their personal information protected, as well as the duty to protect it themselves and not to infringe on other people's information.
- 1) The information subject(user) is responsible for the accidents caused by incorrect information entered by themselves and for problems when entering false information, such as stealing other people's information.
- 2) The information subject(user) should be careful not to damage the personal information of others in accordance with the relevant laws and regulations.

Article 9 (Measures to Ensure Safety)

The company considers following managerial, technical and physical measures to protect personal information from being lost, stolen, disclosed, distorted, or damaged when dealing with customer’s personal information.

A. Managerial Measures
- 1) Minimization and education of personal information handlers
  The company limits the personal information handlers to the minimum and take measures such as regular education to those who process personal information to make them aware of the importance of protecting personal information.
- 2) Formulation and implementation of internal control regulations
  The company has formulated and implemented internal control regulations for safe processing of personal information.
- 3) Regular self-audits
  In order to ensure the safety related to processing personal information, the company carries out self-audits on a regular basis(Annually)
B. Technical Measures
- 1) Encryption of personal information
  Personal information such as resident registration number, name, contact information, bank account number, credit card number, etc. provided by the customer is encrypted by a secure encryption algorithm and stored and managed.
- 2) Measures to prevent the likes of hacking
  The company operates an intrusion prevention system 24 hours a day to prevent the leakage of customer's personal information. Personal sensitive information is encrypted to be safely transmitted on the network.
- 3) Storing records and Preventing forgery and modulation
  The company stores and manages the records related to accessing the personal information processing system for over a year, and use security measures to prevent them from being forged, altered, stolen or lost.
C. Physical Measures
- 1) Physical monitoring and blocking.
  The company sets up data processing room to store and process personal information in a controlled environment.

Article 10 (Personal Information Protection Manager)

The company does its best to make sure customers can safely use its service. The customers can report any kinds of complaints related to personal information protection to service to those managers below. The company will respond quickly and sincerely to them.

Managers in charge of Personal Information
	Chief Privacy Officer of Information Protection	Person in charge of Personal Information Protection
Name
Department
E-mail

Article 11 (Relief for Infringement of Rights and Interests)

Customers can apply for dispute resolution or consultation to Personal Information Dispute Mediation Committee, Korea Internet & Security Agency, and Personal Information Infringement Reporting Center.
In addition, you can refer to the below organizations.

- Personal Information Violation Report Center(http://www.118.or.kr, 118)
- Personal Information Dispute Coordination Committee(http://www.kopico.go.kr, 1833-6972)
- Cyber-crime Investigation Division of Supreme Prosecutor’s Office(http://www.spo.go.kr, 1301)
- Cyber Crime Reporting System Police Agency(http://ecrm.cyber.go.kr, 182)

Article 12 (Image Information Processing Device)

The company informs the information subject(user) of the purpose and method of the video through ‘Lotte Property&Development Inc Guidelines for closed circuit television’.