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Nespresso Privacy Policy Nestlé Korea Nespresso business unit including the affiliates of Nespresso (hereinafter referred to as “Nespresso”) is doing its best to protect the personal information of its users while you operate the Nespresso brand website. Nespresso complies with the personal information protection regulations of relevant laws including the Personal Information Protection Act, the Protection of Communications Secrets Act, the Telecommunications Business Act, the Act on Promotion of Information and Communications Network Utilization etc., all of which must be observed by telecommunication service providers, and the privacy guidelines enacted by the Korean government including the Korea Communications Commission (KCC), the Ministry of Science and ICT and the Ministry of the Interior and Safety. This Privacy Policy will show you how and in what purpose the personal information you provide is used, and what measures have been taken to protect the personal information. Nespresso’s Privacy Policy is easily accessible to its users on the first page of the website. This Privacy Policy is subject to change due to changes in government laws and guidelines, or Nespresso’s in-house policies. If there is any change in the Privacy Policy, it will be updated on the website immediately and the users may be easily accessible to such changes with a date of revision. The Privacy Policy of Nespresso includes the following contents: 1. Items of personal information to be collected and collection methods 2. Collection of personal information and purpose of use 3. Period of retention and use of collected personal information 4. Procedures for destruction of personal information 5. Consignment of personal information 6. Rights of users and legal representatives, and methods of exercise of the rights 7. Technical and administrative protection of personal information 8. Installation/operation and refusal of cookies 9. Transfer of personal information to third parties 10. Cross-border transfer of personal information 11. CPO and relevant department 12. Obligation of notification upon revision of the Privacy Policy 1. Items of personal information to be collected and collection methods In order to help its users sign up for membership, and receive consultation and different services, Nespresso collect the following items of personal information: Name, email, address, mobile phone number (mobile phone number), zip code In addition, service use log, access log, cookies, access IP information, membership information processed for the purpose of marketing, etc. may be created and collected during the process of service use or business operation. Also, personal information such as the brand and number of a credit card (when paid by credit card), the name of a bank and account number (when paid by wire transfer) may be collected during the process of purchasing Nespresso products. And other personal information such as the name, phone number, address, zip code of the recipient may be collected in case of the delivery of products. 2. Collection of personal information and purpose of use Most services provided on the brand website are available without registration. However, Nespresso collects personal information of its users to improve the quality of its services including customized services through brand membership service, purchase of products, participation of various events, consumer survey, etc. Any collected personal information is utilized for the following purposes: 2.1. Implementation of a contract for services and charging upon the provision of services Provision of contents, provision of customized services, delivery of products or invoice, identity certification, purchase and settlement, collection of fees 2.2. Membership management Use of membership services and identification in line with limited verification of identity, personal identification, prevention of unauthorized use by a bad member and prevention of unauthorized use, verification of the intent for subscription, Subscription and restriction of the number of subscription, confirmation of the consent of legal representatives when collecting personal information of children under 14 years old, subsequent personal identification of legal representatives, record keeping for reconciliation, handling of complaints, and notification 2.3. Marketing advertisement Development of new services and provision of customized services, provision of services and advertisements customized for different statistical properties, confirmation of validity of services, provision of promotion and participation of events, verification of access frequency, statistics of service use 3. Period of retention and use of collected personal information Nespresso retains and utilizes the personal information of its users in accordance with regulations while a user as a member of the Nespresso brand website uses the customer services provided by Nespresso. When a member requests for cancellation of subscription or when the purpose of collecting and using personal information is achieved, the information concerned is destroyed immediately. Yet, the following information shall be retained for a certain period of time. Personal information shall be retained for a certain period of time when relevant laws, such as Commercial Act and the Act on the Consumer Protection in Electronic Commerce, etc., mandate the retention of such information. 1) Retention items: Record on contracts, cancellation of a contract, etc. Relevant laws and policies: Act on the Consumer Protection in Electronic Commerce, etc. Retention period: 5 years 2) Retention items: Record on payment, supply of goods, etc. Relevant laws and policies: Act on the Consumer Protection in Electronic Commerce, etc. Retention period: 5 years 3) Retention items: Record on consumer complaints or handling of disputes Relevant laws and policies: Act on the Consumer Protection in Electronic Commerce, etc. Retention period: 3 years 4) Retention items: Record on labeling/advertising Relevant laws and policies: Act on the Consumer Protection in Electronic Commerce, etc. Retention period: 6 months 5) Retention items: Accounts regarding all transactions regulated by tax laws, and documentary evidence Relevant laws and policies: Framework Act on National Taxes Retention period: 5 years 6) Retention items: Record on electronic financial transactions Relevant laws and policies: Electronic Financial Transactions Act Retention period: 5 years 7) Retention items: Service access history Relevant laws and policies: Protection of Communications Secrets Act, Act on Information and Communication Network Retention period: 1 years 8) Retention items: Fraudulent uses Relevant laws and policies: In-house rules Retention period: 1 years 4. Procedures for destruction of personal information In principle, personal information of users is destroyed immediately after the purpose of collecting and use of such information is achieved. The information a user has entered to sign up for subscription is transferred to separate DB (a separate filing cabinet in case of hard copies) and stored for a certain period of time before being destroyed in accordance with in-house rules and other relevant laws (refer to 3. Period of retention and use of collected personal information). 5. Consignment of personal information The following businesses which has entered a contract with Nespresso handles personal information on consignment. Nespresso specifies requirements to ensure safe handling of personal information on consignment in accordance with relevant laws. Consignee Consignment Work Gaeasoft Corp. Digital marketing ValuePoint Corp. DM mailing for online and offline members Jconcompany Co., Ltd. Sending SMS or E-mail to online/offline members NHN KCP Corp. Settlement via credit card, mobile phone or real-time wire transfer Taeeun Inc. Product packing Ubase, Inc. Customer services Valex Storage of documents of offline members CJ Logistics Product shipping Ilyang Logistics Product shipping In order to provide useful information such as promotion of a new product or an event, the company may consign the handling of personal information, and in such a case, a separate consent is required. A user may not consent to the handling of personal information on consignment, which will not result in the provision of services on consignment such as personal identification, analysis of customer data, shipping of products, etc. 6. Rights of users and legal representatives, and methods of exercise of the rights Users and legal representatives may check or revise their personal information or that of children under 14 years old, or request for cancellation of subscription on the brand website at any time. Personal information of users or children under 14 years old can be accessed or revised by clicking “Personal Information” in my account and their subscription can be cancelled by clicking “Contact Preferences.” Or the above requests will be immediately taken care of if you contact the Chief Privacy Officer in writing, by telephone or email. When users request correction of their personal information where they believe there is an error or omission, the information will not be used or provided to any one before the correction is complete. In addition, when wrong personal information has already been provided to a third party, the corrected information will be notified to the third party without delay. The company ensures that the personal information cancelled or deleted upon the request of users or legal representatives is handled as specified in "3. Period of retention and use of collected personal information" and is not accessed or used for any other purposes. 7. Technical and administrative protection of personal information Nespresso acts for or on behalf of Nespresso and has been taken all reasonable measures to prevent any parties from acquiring your personal information except the third parties who have agreed to protect the confidentiality of your personal information. A. Administrative protection Nespresso strives to protect your personal information by establishing an in-house personal information management plan and conducting regular trainings for its employees. Any access to such data is allowed only when necessary and limited to some of Nespresso’s employees which have been trained to comply with its strict standards for confidentiality while dealing with your personal information. B. Technical protection In order to ensure the confidentiality of the collected data, Nespresso uses a data network protected by industrial standard firewall and password protection systems. While Nespresso strives to build a website which is safe and reliable for its visitors, the Internet is generally not a secure environment. Therefore, you need to be noted that Nespresso does not guarantee the confidentiality of personal information you have provided or such information you have sent via the Nespresso website or email. In this respect, Nespresso is not responsible for the security of your personal information during the process of delivery to Nespresso online. C. Physical protection Nespresso takes protective measures to prevent physical access to personal information through the physical locking mechanism for personal information processing system and access control of a data processing center, archives, etc. 8. Installation/operation and refusal of cookies Service use log, access log, cookies, access IP information, membership information process for the purpose of marketing, etc. may be created and collected during the process of service use or business operation. Anonymous data is processed to improve contents of the Nespresso website, to optimize the website for the benefit of its visitors, and to figure out the current status of website visitors and their activities. While carrying out such activities, Nespresso uses a tracking mechanism (“cookie”) to collect anonymous data including the type of browser, OS, the access date and time. The cookie itself cannot be used for the purpose of disclosing the identity of a user. A cookie a piece of information that is transmitted to your browser and stored on your computer’s hard drive. Users have an option to enable or disable cookies. In other words, users may set the options on their web browsers to allow all cookies, to ask whenever cookies are stored, or to decline storing of all cookies. When users decline storing of cookies, however, they may not be able to access some of the online shop services which require them to log on. 9. Transfer of personal information to third parties In principle, Nespresso never discloses the personal information of its users to third parties except the following cases: - When its users have given a prior consent to the disclosure; or - When there is a request of the investigative authorities in accordance with the provisions of laws or the investigative procedures and methods stipulated in laws. 10. Cross-border transfer of personal information As a multinational brand, Nespresso has its database centers in different jurisdictions. Nespresso can transfer your personal information to any destination outside of your residing country (i.e. one of the database centers), affiliates of the Nespresso group, or its partners which have signed a confidentiality agreement. If the level of private information security in a specific country fails to meet the international certification standards, Nespresso will ensure that the data transferred to its database center in the country concerned is protected sufficiently, and that no data is transferred to third parties in such a country. Your submission of your personal information will be deemed you accept that the information may be transferred to affiliates or partners of the Nespresso group and that with the purpose, a cross-border transfer of such information may take place. Details are as follow: Personal Information Items to be Transferred Transferee’s Country Date of Transfer Method of Transfer Transferee Corp. CPO of Transferee Corp. Purpose of Use Period of Possession and Use Name, email, phone number, address Switzerland Upon sign-up for membership Electronic transfer Nestle Nespresso S.A Robert Lineke, Information Security Program Manager Implementation of a contract for providing services to Nespresso Club members; charging upon the provision of services; membership management; and handling of client complaints Until withdrawal of Nespresso Club membership and accomplishment of purpose of personal information collection and use 11. CPO and relevant department To protect personal information of its users and deal with related complaints, Nespresso has assigned a Chief Privacy Officer (CPO) and a relevant department as below: [Chief Privacy Officer of Nespresso Business Unit] Name: Manager, Min, Jaeyong Contact: 080-734-1111 [Nespresso Club] Contact: 080-734-1111 If reporting or consultation regarding personal information infringement is required, please contact the agencies below: - Personal Information Infringement Reporting Center of Korea Internet & Security Agency (privacy.kisa.or.kr / 02-405-5118) - ePRIVACY Accreditation Committee (www.eprivacy.or.kr / 02-550-9531~2) - Cyber Bureau of Korea National Police Agency (www.ctrc.go.kr / 182) - High-tech Criminal Investigation Department of Supreme Prosecutors’ Office (http://www.spo.go.kr / 02-3480-2000) - Cyber Terror Response Center of Korea National Police Agency (www.ctrc.go.kr / 02-392-0330) 12. Obligation of notification upon revision of the Privacy Policy The Privacy Policy of Nespresso was established on September 1, 2013. Any addition, deletion or revision of this policy due to changes in laws, policies or technologies will be notified on the brand website. Date of last revision: November 26, 2018 Date of enforcement: June 1, 2014 Nestlé Korea Nespresso business unit 2003 Nestlé Korea Nespresso S.A. All rights reserved.
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