TERMS OF USE

Article 1 (Purpose)

The purpose of the following Terms and Conditions of Use(‘T&C’) is to establish guidelines on rights, duties and responsibilities of online shopping mall Users utilizing the internet-related services (hereinafter referred to as the ‘Services’) provided by ‘CROSS ENF Inc.’(hereinafter referred to as the “Company”) operated by ‘Cross Shop’ (hereinafter referred to as “Shop”).

Article 2 (Definition)

① “Shop” refers to a virtual business site established by company to trade goods or services (hereinafter referred to as ‘Goods and Services’) using computers and information communication facilities to provide Goods and Services to Users. The term can also be defined as a company operating an online shopping mall

② ‘User’ refers to a Member who has accessed the ‘Shop’ to use the services provided by the ‘Shop’ in accordance with this T&C.

③ ‘Member’ refers to a User who uses the services provided by the ‘Shop’ by subscribing for Membership.

Article 3 (Display, Explanation and Amendment of Terms and Conditions of Use)

① The ‘Shop’ shall, for easy recognition by Users, display the contents of this T&C, name of company and representative, business address(including an address handling customer complaints), phone number, email address, business license number, e-commerce permit number, and the name of personal information manager on Cross Shop main page. Only the content of this T&C can be displayed through a link page.

② Prior to User’s final agreement to this T&C, the ‘Shop’ shall provide a separate link or pop-up screen to obtain User’s verification on the terms of cancellation rights•delivery responsibilities•refund conditions and other important details.

③ The ‘Shop’ may make amendments within the permissible range without violating applicable laws such as the 「Act on Consumer Protection in Electronic Commerce」, 「Regulation of T&C」, 「Framework Act on Electronic Commerce and Electronic Document」, 「Electronic Financial Transaction Act」, 「Electronic Signature Act」, 「Act on Protection of Information and Promotion of Utilization of Information and Communications Network」, 「Door-To-Door Sales Act」, 「Framework Act on Consumers」 and other related Consumer Protection Laws.

④The ‘Shop’ shall specify the effective date and the reasons for amendment of the terms and have post on the initial screen for 7 days prior to effective date until the day before the effective date. If the amendment is modified to the User’s disadvantage, then the ‘Shop’ shall grant at least 30 days of grace period for notice. In this case, the ‘Shop’ shall clarify the ‘before and after’ changes in an ‘easy-to-understand’ manner.

⑤ When the ‘Shop’ makes an amendment to the T&C, the modified T&C shall be applied only to contracts concluded after the effective date, whereas all contracts concluded before the effective date will remain under the provisions of the old T&C. However, if the User who has already signed the contract wishes to have the amendments administered, then the User may send his/her intent to the ‘Shop’ and acquire consent from the ‘Shop’ within the notice period stated in Clause ③ and it shall be applied accordingly.

⑥ Any information not specified and interpreted in this T&C shall be in accordance with the e-commerce Transaction Guidelines and Related Consumer Protection Acts provided by the Fair Trade Commission and other applicable Consumer Protection Laws and Regulation of T&C Act.

Article 4 (Provision & Replacement of Service)

① The ‘Shop’ shall perform the following duties:

1. Provide information regarding Goods and Services and conclude purchasing contracts.
2. Other duties designated by the ‘Shop’.’

②The ‘Shop’ may replace Goods and Services provided in future T&C in the event that Goods and Services are sold out or technical specifications are revised. In this case, the ‘Shop’ shall immediately announce the replacement of Goods and Services and the date of application on the page where present Goods and Services are displayed.

③ In the event that Goods and Services are replaced because of a change in technical specifications or when Goods and Services are sold out, the ‘Shop’ shall immediately notify the cause of replacement to the Users.

④ Following the previous Clause, the ‘Shop’ shall compensate for all damages caused. However, this shall not apply if the ‘Shop’ proves that such an event is not caused by its intention or negligence.

Article 5 (Suspension of Service)

① The ‘Shop’ may temporarily suspend its services as a result of the following reasons: maintenance of computers and telecommunications equipment, replacement or damage repairs, and interruption of communication.

② The ‘Shop’ shall compensate User or any Third Party Member of damages caused by the temporary suspension of services due to reason(s) detailed in Clause ①. However, this shall not apply if the ‘Shop’ proves that such an event is not caused by its intention or negligence.

③ In the case of a conversion of business item, abandonment of business, merging between businesses and for other various reasons, the ‘Shop’ shall notify the consumer as specified in Article 8 and reward consumer in accordance with the conditions suggested by the original ‘Shop’. However, if the ‘Shop’ does not advise such standard of compensation, the ‘Shop’ shall pay Users for their mileage or reserve in kind or cash of which value corresponds to the currency being used at the ‘Shop’.’

Article 6 (Membership)

① The User shall apply for Membership by expressing his/her intent to agree to this T&C after filling out the form designated by the ‘Shop’ with Member’s personal information.

② The ‘Shop’ shall register all Users who apply for Membership in the manner stipulated in Clause ① unless the User is not engaged in one of the following issues:

1. After the applicant has lost Membership for reasons indicated in Article 7 Clause ③, the applicant may acquire approval to re-subscribe for Membership three years after the loss of Membership.
2. Entry of false information or omission in the registration form.
3. If deemed that registering the User would present technical difficulties to the ‘Shop’.’

③ Establishment of Membership becomes effective at the time that the Member receives the ‘Shop‘s approval of Membership.

④ In due course of time, the Member shall update the ‘Shop’ with any changes to his/her account information through the methods of editing personal information.

Article 7 (Membership Withdrawal & Loss of Eligibility)

① Members of the ‘Shop’ may request, at any time, to withdraw from Membership and the ‘Shop’ shall immediately process the request.

② The ‘Shop’ may limit or suspend Membership for the following reasons:

1. Entry of false information or omission in the registration form.
2. If the purchase payment of goods and other ‘Shop’ usage related liabilities have not been paid for before the appointed date.
3. If the Member interferes with others to use the ‘Shop’ or threatens the order of e-commerce (such as the illegal use of personal information).
4. If the Member uses the ‘Shop’ to act against public order and morals prohibited by the law and this ‘T&C.’

③ The ‘Shop’ may forfeit Membership of the Member whose Membership was suspended or limited, if the same actions are repeated twice or more, or if the cause is not corrected within 30 days.

④ When the ‘Shop’ forfeits Membership, all information will be canceled. Prior to cancellation, the ‘Shop’ shall notify the Member and give at least 30 days or more to grant an opportunity to explain the cause.

Article 8 (Notification to Members)

① Any notifications from the ‘Shop’ will be sent to the registered phone number via SMS

② In the event of sending public notifications, notification will be displayed on the website’s notice board for 1 week or more and this action may replace sending notifications to individuals. However, the ‘Shop’ shall send individual notice to a Member in regards to matters which may have a significant influence regarding his/her transaction.

Article 9 (Application for Purchase)

① The User shall apply for purchase in the following or in a similar manner, and the ‘Shop’ shall provide the User with the following information in an ‘easy-to-understand’ manner to aid in his/her request for purchase.

1. Search and select Goods and Services
2. Data input of Receiver’s name, address, phone number, mobile or phone number, etc
3. Confirm matter(s) in respect to the contents of this T&C, limited cancellation policies, delivery fees, installation fees, and others
4. Express agreement to this T&C and confirm or refuse number 3 (ex. mouse click)
5. Apply and confirm purchase of goods also Agree to allow confirmation of application from the ‘Shop’
6. Select payment method

② In case of an inevitable need for the ‘Shop’ to disclose User’s personal information to a third party, the ‘Shop’ shall specify to the User the provisions of 1) personal information that are being disclosed, 2) information of the receiving party, 3) purpose and intent of use and 4) the duration of how long the data are going to be used. (Same principal will be applied even if the agreed items has been changed)

③ In the event that the ‘Shop’ entrusts a third party with the handling the Buyer’s personal information, the ‘Shop’ shall specify the User the provision of 1) The person entrusted with the handling of personal information, 2) Information disclosure of the process details and obtains consent from the Buyer. (Same principle will be applied even if the agreed items have been changed). However, if it is necessary for the implementation of a contract on service provision and is related to the promotion of convenience of buyers, it is not necessary to go through the notification process and consent process by notifying it through the personal information handling policy in the manner prescribed by the 「Information and Communication Network Use Promotion and Information Protection Act.」

Article 10 (Conclusion of Contract)

① The ‘Shop’ may not accept request for purchase in Article 9 if it falls under one of the following items. In the event of concluding a contract with a minor, the ‘Shop’ shall notify that the failure to acquire agreement from a legal representative may cause cancellation of the contract by the minor him/herself or the legal representative.

1. Entry of false information or omission in the registration form
2. Purchase of cigarettes and liquor and other Goods and Services prohibited by the Youth Protection Law
3. If deemed that accepting application for purchase may cause technical problems to the ‘Shop’

② The contract is deemed to be concluded when the acceptance of the ‘Shop’ is delivered to the User in the form stipulated in Clause ① of Article 12.

③ The acceptance of the ‘Shop’ shall include confirmation on the User’s request for purchase, availability of sales, and correction or cancellation of the request for purchase.

Article 11 (Payment Method)

The method of payment for Goods and Services purchased through the ‘Shop’ may be selected from the following items. The ‘Shop’ may not collect any additional fees regarding payment for Goods and Services.

1. Account transfer through phone banking, internet banking, and other easy transfer payments.
2. Card payments through prepaid card, debit card, credit card, and others.
3. Payments without bank account
4. Electronic money
5. Payment upon receipt
6. Mileage points or points offered by the ‘Shop’
7. Gift voucher contracted or approved by the ‘Shop’
8. Other means of electronic payments

Article 12 (Notice of Receipt, Change and Cancellation of Application for Purchase)

① The ‘Shop’ shall send a notice of receipt to the User after receiving the User’s request for purchase.

② In the case of a discord between the User’s intent and the received notice, the User may change or cancel the request for purchase immediately after receiving the receipt. If the request for change or cancellation is made prior to delivery, the ‘Shop’ shall process the request accordingly without any delay. In the event that payment has already been made, User shall follow the guidelines detailed in Article 15 - Cancellation of Purchase.

Article 13 (Provision of Goods and Services)

① Unless otherwise specified, the ‘Shop’ shall take necessary measures such as customizing production and packaging and deliver Goods and Services within 7 days from the date of purchase. However, if the ‘Shop’ has already received payment in whole or in part, then delivery shall be processed within 3 business days from the date of receipt. In such instances, the ‘Shop’ shall take necessary measures to inform the User on procedures of provision and delivery status of Goods and Services.

② The ‘Shop’ shall specify delivery method, payer, and delivery time for each delivery method for the Goods and Services purchased by the User. In the event that the ‘Shop’ exceeds the designated period of delivery, it shall compensate the User for damages. However, this shall not apply if the ‘Shop’ proves that such an event is not caused by its intention or negligence.

Article 14 (Refund)

In the event that the Goods and Services are sold-out or unavailable and cannot be provided or delivered to a User who applied for purchase, the ‘Shop’ shall notify the User without any delay, and if payment for Goods and Services has already been made in advance, the ‘Shop’ shall take necessary measures or refund payment within 3 business days from the date of receipt.

Article 15 (Cancellation of Purchase)

① The User who purchased Goods and Services by concluding the contract with the ‘Shop’ in accordance to Clause ② of Article 13 in the 「Acts on Consumer Protection in Electronic Commerce」 may cancel purchase within 7 days from the date on which the User received a written contract (if the written contract is received later than the supply of Goods and Services, then the receipt date is set on the date when User received the Goods and Services or when Goods and Services have been supplied). But, cancellation of purchase according to 「Acts on Consumer Protection in Electronic Commerce」 shall comply with relevant laws and legislations in regards to affairs not mentioned in the Acts.

② The User may not return or exchange Goods and Services in the event of one of the following reasons:

1. In case delivered goods are lost or damaged due to the fault of the User (however, cancellation of purchase may be acceptable if packaging was damaged in the process of checking content)
2. Significant decrease in value of Goods and Services due to partial use or consumption by the User
3. Items that are not available for resale due to a significant decrease in value of Goods and Services from lapse of time
4. The Goods may be replaced by other similar Goods with the same performance, but if the packaging of the original is damaged, return or exchange cannot be done

③ In the case of items number 2 or 4 of Article 2 Clause ②, the cancellation of purchase by User will not be limited if the ‘Shop’ failed to clearly specify the fact that cancellation of purchase is limited or that it would take necessary measures to provide the Goods.

④ Despite Clause ① and ②, the User may cancel his/her purchase of goods within 3 months from the date of receipt of the goods or within 30 days from the date on which he/she recognized or could have recognized that Goods and Services differ from the advertisement or the provision of contract.

Article 16 (Effect of Cancellation of Purchase)

① In the event of a return of Goods from a User, the ‘Shop’ shall refund payment of Goods within 3 business days. In the event of a delay in refund, the ‘Shop’ shall pay User with the interest calculated by the number of days delayed with the overdue interest rate indicated on the 「Act on Consumer Protection in Electronic Commerce」 Clause 2 of Article 21

② In regards to the above-mentioned case, if the User made payment with credit card or electronic money, the ‘Shop’ shall immediately request the related company who provided such payment method to suspend or cancel the payment.

③ In the event of any cancellation of purchase, the User shall be responsible for all costs arising from the return process of the Goods. On the account of the User’s cancellation of purchase, the ‘Shop’ shall not claim charge for cancellation or compensation for damage. However, in the event of a cancellation of purchase caused by a disagreement in the contents of Goods and the advertisement or the provision of contract, the ‘Shop’ shall be responsible for all costs arising from the return process of the Goods.

④ If the User bore the delivery fees when he/she received the Goods, the ‘Shop’ shall specify and make noticeable as to who would be responsible for the delivery fees upon cancellation of purchase.

Article 17 (Protection of Personal Information)

① The ‘Shop’ collects a minimum amount of information necessary to provide the services.

② At the time of applying for Membership, the ‘Shop’ shall not collect information needed for the performance of purchase contract in advance. But, in the case where personal identification is required before the performance of a purchase contract, a minimum amount of specified personal information is collected for the fulfillment of obligation in regards to relevant laws and legislation.

③ The ‘Shop’ shall obtain consent from User to collect∙use personal information by notifying User with the aim/purpose of collection∙use.

④ The ‘Shop’ shall not use the personal information outside their intended purpose. In the event of an uprising of a new use or when disclosing to third parties, the ‘Shop’ shall notify the purpose of use and obtain consent from User during the stage of use·disclosure. However, there are exceptions for cases regulated in the relevant laws and legislations.

⑤ In the event that the ‘Shop’ is required to acquire the approval of User by Clause ② and ③, the ‘Shop’ shall specify its personal information manager (affiliation, name, phone number, other contact information), purpose of collection and use of information, information about Third Party (recipient, purpose of provision and the information to be provided), and the provisions stipulated in Clause 2 of Article 22 of the 「Act on Protection of Information and Promotion of Utilization of Information and Communications Network」. The User may at any time cancel his/her approval.

⑥ User may, at any time, request for confirmation and correction of error in their personal information possessed by the ‘Shop’,’ and the ‘Shop’ shall be responsible for taking any necessary measures without any delay. In the event that a User requests for the correction of an error, the ‘Shop’ shall not use the applicable personal information until the error is corrected.

⑦ For protection of personal information, the ‘Shop’ shall limit the number of persons handling personal information to a minimum, and shall be responsible for any damages caused by loss, theft, leakage, falsification, and disclosure of personal information including credit card and bank account information to third parties without consent of the User.

⑧ The ‘Shop’ or any Third Parties who received personal information from the ‘Shop’, shall without any delay destroy all personal information once the purpose of collection has been achieved.

⑨ The ‘Shop’ shall not have the agreement form regarding the collection∙use∙disclosure of personal information set to be filled out in advance. The ‘Shop’ must specify services that will be restricted if User does not agree to the collection∙use∙disclosure of personal information, and the ‘Shop’ shall not limit services or refuse to accept Membership applications on the basis of User’s refusal to agree to collecting∙using∙disclosing of personal information that do not include the collection of compulsory information.

Article 18 (Obligations of the ‘Shop’)

① The ‘Shop’ shall not take any actions against public policy or actions restricted by the law and this T&C. The ‘Shop’ shall put its best efforts in providing Goods and Services on a stable basis in accordance with the provisions in this T&C.

② The ‘Shop’ shall be equipped with a security system to protect personal information of Users (including credit information) and provide a safe environment for Users to use the online services.

③ In accordance with Article 3 of the Law related to 『Fairness of Display and Advertisement』, the ‘Shop’ shall be responsible to compensate User(s) if damages were caused by displaying or adding unjust or unreasonable advertisement for certain Goods and Services

④ The ‘Shop’ shall not send any marketing messages that are unwanted by the Users.

Article 19 (Obligations for ID & Password of Member)

① Member shall be responsible for the management of his/her ID and password, except for the case mentioned in Article 17.

② Member shall not allow any Third Party to use his/her ID and password.

③ When a Member recognizes that his/her ID and/or password is stolen or is being used by a Third Party, the Member shall immediately notify the ‘Shop’, and follow the instructions of the ‘Shop’.’

Article 20 (Obligations of User)

① Users shall avoid the following actions:

1. Register false information at the time of application or revision
2. Use of other person’s personal information
3. Altering information displayed on the ‘Shop‘
4. Transmission or posting of information (computer programs, etc.) other than informations established by the ‘Shop’
5. Violation of copyright or intellectual property rights of the ‘Shop’ or the Third Party
6. Take any action that harms the reputation and interrupts the operation of the ‘Shop’ or the Third Party
7. Disclose or display any information containing indecent or violent message, video, voice, and other information going against good public order and morals on the Shop.

Article 21 (Relation between ‘Shop’ and Associated ‘Shop’)

① In the event that the main shop and the sub-shop are linked with a hyperlink (ex. the subject of hyperlink includes text, image and video), hereinafter the former will be referred to as the Shop (Website) and the latter will be referred to as the Associated Shop (Website).

② If the Shop specifies and notifies the fact that they are not responsible for any transaction done by the User for any Goods and Services independently provided by the Associated Shop on the initial page of the website of the Shop or a pop-up window, it means that the Shop shall not be responsible for such transaction.

Article 22 (Copyright & Limitation of Use)

① The copyright and other intellectual property rights for the works produced by the ‘Shop’ shall belong to the ‘Shop’.

② The User may not use or cause any Third Party to use information contains intellectual property rights which belongs to the ‘Shop’ for reproduction, transmission, publishing, distribution, broadcasting or other profit-making use without prior consent from the ‘Shop’.

③ The ‘Shop’ shall notify the User upon using a copyright owned by the applicable User in accordance with mutual T&C.

Article 23 (Resolution of Dispute)

① The ‘Shop’ shall take any opinion or complaint made by User(s) into their consideration, as well as operating a process of compensation for any damages caused.

② The ‘Shop’ shall give priority to any opinion or complaint made by User(s). However, in the event that it may not be able to promptly deal with the matter, the ‘Shop’ shall notify the User with the cause along with a final settlement schedule.

③ When a User files for Compensation of Damage regarding a dispute between the ‘Shop’ and the User, the matter may be commissioned for arbitration by the Fair Trade Commission or a Dispute Conciliation Services Organization selected by the City Mayor.

Article 24 (Jurisdiction & Governing Law)

① All e-commerce related lawsuits between the ‘Shop’ and a User shall be in accordance with the address of the User at the time of indictment. If an address is nonexistent, then the lawsuit shall fall under exclusive jurisdiction of the district court in the vicinity of User’s place of residence. In the event that the address or residence of the User is not clear at the time of indictment or if User is a foreign resident, the lawsuit shall be filed to the competent court on the Civil Procedures Code.

② Any and all e-commerce-related lawsuits between the ‘Shop’ and a User shall be governed by the law of the Republic of Korea.

Article 25 (Reward Points Policy)

① The "Company" shall grant "Cross Shop Points" in accordance with its service policy as rewards when the user participates in actions such as purchasing goods, writing reviews, participating in events, or suffers delays due to shipment delays, depletion of stocks after the user's order is placed, or cancellation of a purchase.

② The "User" may use the acquired "Cross Shop Points" for "Goods" purchases in the "Shop" along with other payment methods in accordance with the reward points policy set by the "Company."

③ The "Company" is entitled to set different accrual standards, usage methods, expiration dates, and restrictions for "Cross Shop Points," subject to variations in goods, membership levels, payment methods, etc., and notifications regarding these policies shall be announced on the "Shop"'s homepage.

④ "Cross Shop Points" shall be used in the order of 1) points with the earliest expiration date; 2) in the case of points with the same expiration date, points that were acquired earlier will be used first.

⑤ "User" shall not transfer "Cross Shop Points" to a third party or to other users. Points also cannot be traded for any monetary value or converted into cash.

⑥ In the event that the "User" unlawfully acquires and uses "Cross Shop Points" by methods that are not approved by the "Company," provides false information, or violates these T&C, the "Company" may restrict the use of "Cross Shop Points" or collect them accordingly by methods determined by the "Company," cancel any purchase request made by the "User," and withdraw the "User"'s qualifications.

⑦ In the event that the "User" withdraws membership, the remaining "Cross Shop Points" will immediately expire. This action cannot be undone, and points will not be refunded even when the "User" attempts to renew the registration or login to the account.

Privacy Policy

CROSS ENF INC. (‘www.crossenf.com’, “CROSS ENF INC.”) will protect the personal information, rights and interests of the users and in order to facilitate the problems the users might encounter with the privacy policy, the following policies has been set in place.

In case of amendment in the privacy policy, CROSS ENF INC. will announce it through the website (or individual announcements).

1. The purpose of privacy management

CROSS ENF INC. will handle the personal information for the following purposes. The handled personal information will not be used for any other uses and in case the usage purpose changes, a consent will be asked prior to its application.

1. User subscription to homepage and management

   The personal information will be processed for the purpose of confirming subscription as a user, personal identification and certification for user’s service provision, self-identification for the restrictive identification system, prevention of misuse of the service, various notifications and announcements, difficulties treatment and the preservation of the records for dispute conciliation.

2. Provision of goods and services

   The personal information will be processed for the purpose of service provision, billing, contents provision, suited service provision, self-identification, age certification, and payments.

3. Usage in marketing as well as advertisements

   The personal information will be processed for the purpose of developing new service (product) and providing service, notification of events and provision of promotional information and participation opportunity, provision of service suited for the demographics and publication of advertisements, confirmation of the validity of the service, identification of connection frequencies or statistics of the usage of the service.

2. Processing and retention period of personal information

CROSS ENF INC. handles the following personal information items.

1. Personal information items

   (Required for using Cross Remittance Service) Mobile phone number, log-in password, gender, date of birth, name, bank account information, unique identification number including CI(Connected Information), address, nationality, occupation

   (Required for using Cross Shop Service) Mobile phone number, log-in password, gender, date of birth, name, address, nationality

   (Information that is automatically generated during service use process or business process) Service use record, access log, cookie, access IP information, payment record

   (Identity Check) Copy of ID, bankbook, proof of remittance, PIN

   (For ID verification) Copy of ID, name, citizen registration number, issuance date, driver’s license number and its serial number, passport number

   (Information that is collected during service use process or business process) Employer information, annual income, shipping information

2. Method of collection : Personal information is collected when users register on the website / check their identity
3. Basis of retention : Consent of user (Children under 17 years old cannot be registered)
4. Retention period : Personal information shall be retained and used for ‘the purpose of privacy management’ as delineated above starting from the date on which the user consents to the Privacy Policy, and then retained and used for 5 years after the termination of transaction(due to withdrawal of service membership, withdrawal of consent to the Privacy Policy, etc.) only for the purpose of financial accident investigation, dispute resolution, civil affairs, regulatory obligations, or the Company’s risk management.
5. Notwithstanding CROSS ENF INC.’s policy on personal information processing, the information required to be retained pursuant to the relevant laws and regulations will be retained for the period set by the law.
   • ①  Record of display / advertisement

     Basis of retention : Act on consumer protection in e-commerce
     Retention period : 6 months

   • ②  Record of agreement or withdrawal

     Basis of retention : Act on consumer protection in e-commerce
     Retention period : 5 years

   • ③  Record of complaints or disputes

     Basis of retention : Act on consumer protection in e-commerce
     Retention period : 3 years

   • ④  Record of financial transaction (sender/recipient information, transaction data)

     Basis of retention : Specific Financial Transaction Information Act
     Retention period : 5 years

3.Consignment of personal information processing

1. CROSS ENF INC. consigns the following personal information processing work for a better processing of personal information. Users have the right to refuse consent to personal information consignment(Provision). However, if a user refuse to consent, he or she may be restricted from using the service.

   1	Supplied to	Korea Mobile Certification Inc.
   	Purpose of sevice	SMS authentication for confirming ownership of mobile phone
   	Period of retention	Do not store separately
   2	Supplied to	Welcome Savings Bank
   	Purpose of sevice	Deposit (virtual account), payment
   	Period of retention	Until a user unsubscribes or ends a consignment contract, or as required by relevant laws
   3	Supplied to	Kakao Corp.
   	Purpose of sevice	KakaoTalk, PlusFriends message sending service
   	Period of retention	Until a user unsubscribes or ends a consignment contract, or as required by relevant laws
   4	Supplied to	Overseas financial institutions
   	Purpose of sevice	Cross-border remittance
   	Period of retention	Until a user unsubscribes or ends a consignment contract, or as required by relevant laws
   5	Supplied to	Korea Financial Telecommunications & Clearing Institute
   	Purpose of sevice	Withdrawal of funds from bank accounts per payment instructions generated via Open Banking API
   	Period of retention	Until a user unsubscribes or ends a consignment contract, or as required by relevant laws
   6	Supplied to	Channel Corp.
   	Purpose of sevice	Operating customer service and marketing
   	Period of retention	2 years
   7	Supplied to	Infobip
   	Purpose of sevice	SMS sending service
   	Period of retention	Until a user unsubscribes or ends a consignment contract, or as required by relevant laws
   8	Supplied to	NAVER Cloud Corp.
   	Purpose of sevice	Improvement of ID verification processing
   	Period of retention	Delete immediately after processing
   9	Supplied to	Fridays Lab
   	Purpose of sevice	Analyzing customer data
   	Period of retention	Until ends a consignment contract
   10	Supplied to	Coocon
   	Purpose of sevice	Verify ID authenticity, investigate residency status
   	Period of retention	Delete immediately after processing
   11	Supplied to	i-Aurora co., Ltd.
   	Purpose of sevice	Provision of user information for prepaid payment instruments
   	Period of retention	Maximum 5 years

2. CROSS ENF INC. is ensuring that the consignee processes the personal information safely and is clarifying the details related to responsibility such as the respect of the given purpose of consignment work, the technical and administrative protective action, limitation of re-consignment, and the management and supervision of the consignee in the contract in case of consignment agreement according to the article 25 of the Privacy Protection Act.
3. If the contents of the consignment works or the consignee changes, it will be revealed through the privacy management policy without any hesitation.

4. According to the rights and duties of the subject of the information, the subject may manifest its rights as mentioned below

1. The subject can exert the rights of privacy protection mentioned below to CROSS ENF INC. anytime
   • ①  Request to view the personal information
   • ②  Request to correct if there are errors
   • ③  Request to delete
   • ④  Request to cease the treatment
2. The exertion of rights mentioned in clause 1 may be processed through written and electronic post, or FAX (site name under the ‘site URL’) according to the privacy protection enforcement regulation form No.8, and it will be taken into account without hesitation.
3. Upon the request (site name under 'site URL') of correction or deletion of personal information by the subject, the personal information will not be used or provided until the correction or the deletion is completed.
4. The exertion of the rights mentioned in clause 1 may be processed through a legal representative, a delegate, or a proxy of the subject. In this case, the proxy statement respecting the privacy protection enforcement regulation form No.11 must be handed in.

5. Destruction of personal information

By the principle, CROSS ENF INC. will destroy the corresponding personal information without delay once it has reached its purpose. The procedure and the deadline of the destruction are as follows.

1. Destruction procedure:

   When the information inserted by the user has reached its purpose, it will be moved to a separate DB ( a separate document if it’s paper), and according to the inside policy as well as other related laws, it will be destroyed immediately or after being saved for a set period of time. In this case, the personal information moved to DB will not be used for other purpose unless it is required by law.

2. Deadline of destruction:

   The personal information of the user will be destroyed within 5 days when the personal information has reached its purpose, the corresponding service has shut down, the business shut down, the personal information is no longer necessary or when the possession period of personal information has passed.

3. Destruction method :

   Information in electronic files will be destroyed by technology method which does not allow the recovery of records. Personal information on papers will be destroyed by paper shredders or by incineration.

6. Safety of personal information securement measure

CROSS ENF INC. is taking technical/administrative as well as physical measure necessary mentioned below for the securement of safety in compliance to the article 29 of Privacy Protection Act.

1. Technical measure against hacking

   CROSS ENF INC. will install and regularly renew/inspect a security software to prevent the hackers or the virus to leak or damage the personal information. CROSS ENF INC. will also install a system in an area restricted from outside approach and is inspecting and blocking technically/physically.

2. Encryption of personal information

   The personal information and the password of the user is encrypted, saved and managed, and only the user can know it. Several safety functions such as encryption of files and transmission data of an important data, or the lock function of a file are being used.

3. Restriction to personal information access

   By giving, altering, canceling the access rights to the database systems that manages the personal information, the necessary control of access to personal information is being processed and by using a trespass block system, the unauthorized access from outside is being controlled.

4. Locking device for the security of documents

   Documents with personal information and additional storage mediums are well preserved in a secured place with a locking device.

5. Access control to unauthorized personnel

   CROSS ENF INC. have set up a separate physical storage area for personal information and set up access control procedures.

7. Personal information security officer

1. CROSS ENF INC. is responsible for the handling of personal information, and has designated the person responsible for the protection of personal information as follows to process complaints and personal information processing.

   Personal information security officer
   Name	Kim, Taegyu
   Position	CTO
   Number	1670-2624
   Email	support@crossenf.com

2. The information subject may inquire about personal information protection related to complaints, and damages relief as for the use of CROSS ENF INC.’s service (or business). Cross ENF will answer and handle inquiries of the information subjects without delay.
3. Users have responsibilities to maintain the security of the user’s ID and password. CROSS ENF INC. does not ask the user directly about the password. Therefore, please be careful not to let the password leak to other person. Especially if you are online in a public place.
4. Although CROSS ENF INC. has made technological improvements, it is not liable for damages to information due to unforeseen accidents caused by hacking.
5. Users may inquire about personal information protection related complaints, damages remedies, etc. while using the service. CROSS ENF INC. will answer and handle inquiries of the information subject without delay.
6. Notwithstanding the policy of this Privacy Policy, CROSS ENF INC. is obliged to provide personal information in accordance with the laws and regulations of the Republic of Korea.

8. Request for personal information

Please contact us if you are not satisfied with our personal information complaints, the relief of damages, or need further assistance.

• Personal Information Infringement Notification Center (Operated by Korea Internet & Security Agency)
  •   •    Responsibilities: Reporting personal information infringement facts, requesting consultation
  •   •    Website: privacy.kisa.or.kr
  •   •    Telephone: (without Area code) 118
  •   •    Address: (58324) 9, Jinheung-gil, Naju-si, Jeollanam-do, Republic of Korea, Korea Internet & Security Agency Personal Information Infringement Notification Center
• Personal Information Dispute Arbitration Committee (Operated by Korea Internet & Security Agency)
  •   •    Responsibilities: Personal information dispute settlement application, collective dispute settlement
  •   •    Website: www.kopico.go.kr
  •   •    Telephone: (without Area code) 1833-6972
  •   •    Address: (03171) 209, Sejong-daero, Jongno-gu, Seoul, Republic of Korea, Personal Information Dispute Arbitration Committee

9. Personal information process policy changes

This policy will be enforced on the start date. Notices of changes such as new policies or removal of old ones will be posted 7 days before the date of enforcement.

10. CROSS ENF INC. may install cookies and users may deny this.

Cookies are used to help users use the website faster and more conveniently and to provide customized services. However, users have right to install cookies. As a result, users can allow all cookies by setting options in their web browser, check each time a cookie is saved, or refuse to save all cookies. Moreover, refusing to install cookies may make the web browsing experience uncomfortable and difficult to access some services required users to sign in.

Addendum

(Effective Date) This Privacy Policy will be effective from 11 December 2023.