GATEPLUS CO., Ltd. ("GATEPLUS") operates a privacy policy (”Privacy Policy”) as shown below to protect the personal information of its data subjects (”Users”) and to process any related complaints in a prompt manner in accordance with applicable law. This Privacy Policy of GATEPLUS may be amended from time to time subject to the changes in the applicable laws and enforcement decrees or GATEPLUS’s internal policy, etc., and any such changes to the Privacy Policy will be announced on the GATEPLUS website so that Users may easily be informed of such changes.

This Privacy Policy will take effect from March 21, 2024 (”Effective Date”)

1. Purpose of Processing Personal Information

GATEPLUS collects the minimum amount of personal information that is necessary to provide services to Users and obtains consent from Users for the collection of such information. The items of personal information that are collected are shown below, which are used only for the notified purposes. GATEPLUS processes personal information for the following purposes and does not use it for any other purposes.

• To perform obligations under the service agreement, settle charges for services rendered, purchase and pay for service, and manage membership;
• To authenticate individuals prior to allowing the use of membership-based services for the management of Users, conduct personal identification, prevent illegal or unauthorized use by delinquent Users, confirm Users' intention to execute service agreements, verify age, handle complaints and other grievances, and provide notices to Users;
• To develop and specialize new services (products) for marketing and advertisements, deliver advertising information, such as event information, etc., understand access frequency or compile statistics on Users' use of the services; and
• To restrict the number of subscriptions, preserve records for dispute resolution, build a service environment to strengthen privacy protection, monitor Users' satisfaction with the service and goal satisfaction status, calculate statistics on classes, test frequency and interests, etc.
• To verify the Users’ identification, contact the Users for confirmation of inquiry and/or verification of fact, respond to the Users’ inquiry

2. Items of Personal Information to be Processed

1. GATEPLUS collects and processes different personal information items depending on the type of User:
   • For Institution Administrators, the required items are: name, mobile phone number, email address, institution name, business registration number, business phone number.
   • For Academy Teachers who are affiliated with institutions, the required items are: name, mobile phone number, email address.
   • For Private Tutors, the required items are: name, mobile phone number, email address, business phone number, tutor (business) name, academic certification documents such as graduation certificate or passing certificate of qualification examination, etc.
   • For Students, the required items are: name, mobile phone number, email address, grade, name of the school, grade, type of school, location of the school.
   • For Parents, the required items are: name, mobile phone number, email address.
   • Optional items: Agreement for receiving marketing advertisements, Parents' phone number for Students.
2. Information, such as access IP addresses, advertising ID (AAID, IDFA, etc.), cookies, and access date/time, etc. may be automatically generated and collected to check whether any content has been used in the process of using the service or operating the business or other matters.

3. Processing of Personal Information and Retention Period

1. GATEPLUS processes and holds personal information for the period of retention and use to which Users consented when the personal information was collected or within the period of retention and use permitted under the applicable law.
2. The specific periods for processing and retaining personal information are as follows:
   • Prevention of fraudulent subscription and inappropriate use: If there is a record of inappropriate use of the service, such as fraudulent subscription, unauthorized disclosure of posts, or sharing of ID, etc., the authentication information of subscription (e-mail address or Facebook serial number, legal representative’s e-mail address and mobile phone number in the case of a User under the age of 14), among other personal information: for 1 year from the date of cancellation of User’s membership.
   • User subscription and management: To prevent fraudulent activity and ease the account reactivation process, personal information is stored for 12 months after the service agreement or membership is terminated. However, if there remain any receivables or debtor-creditor relationship, personal information of the User will be retained until such receivables are collected or the debtor-creditor relationship is settled.
   • Records of e-commerce contracts and withdrawal of e-commerce subscription, payment records and records of supply of goods, etc.: for 5 years
   • Records of consumer complaints or dispute settlements: for 3 years
   • Records of User access logs (communication confirmation data): for 3 months
   • Records of subscribing newsletters: upon withdrawal of consent or termination of service