Privacy Policy

This Policy (the "Policy") explains the way of treatment of the information which is provided or collected on the websites on which this Policy is posted. In addition, the Policy also explains the information which is provided or collected in the course of using the applications of the Company which exist on the websites or platforms of other companies.

The Company is the controller of the information provided or collected on the websites on which this Policy is posted and in the course of using the applications of the Company which exist on the websites or platforms of other companies.

Through this Policy, the Company regards the personal information of users as important and informs them of the purpose and method of the Company's using the personal information provided by the users and the measures taken by the Company for the protection of that personal information.

This Policy covers all domains related to makecoin.io including sub-domains.

1. Information to be collected and method of collection

(1) Personal information items to be collected

Personal information items to be collected by the Company are as follows:

Information collected while the users use services

Besides the information directly provided by the users, the Company may collect information in the course that the users use the service provided by the Company.

Lists	Items to be collected (examples)
Equipment information	Equipment identifier, operation system, hardware version, equipment set-up, type and set-up of browser, use information of website or application and telephone number
Log information	IP address, log data, use time, search word input by users, internet protocol address, cookie and web beacon
Location information	Information of device location including specific geographical location detected through GPS, Bluetooth or Wifi (limited to the region permissible under the laws)
Other information	Preference, advertisement environment, visited pages regarding service use of users

(2) Method of collection

The Company collects the information of users in the following ways:

webpage, written form, fax, telephone calling, e-mailing, tools for collection of created information
provided by partner companies

(3) Period for retention and use of personal information

In principle, the Company destructs personal information of users without delay when: the purpose of its collection and use has been achieved; the legal or management needs are satisfied; or users request. Provided that, if it is required to retain the information by relevant laws and regulations, the Company will retain member information for a certain period as designated by relevant laws and regulations.

(4) Procedure and method of destruction of personal information

In principle, the Company destructs the information immediately after the purposes of its collection and use have been achieved without delay. Provided that, if any information is to be retained as required by relevant laws and regulations, the Company retains it for the period required by those laws and regulations before destruction and, in such event, the personal information which is stored and managed separately will never be used for other purposes. The Company destructs hard copies of personal information by shredding with a pulverizer or incinerating it, and deletes personal information stored in the form of electronic files by using a technological method making that information not restorable.

2. Use of collected information

The Company uses the collected information of users for the following purposes:

Member management and identification
To detect and deter unauthorized or fraudulent use of or abuse of the Service
Performance of contract, service fee payment and service fee settlement regarding provision of services demanded by the users
Improvement of existing services and development of new services
Making notice of function of company sites or applications or matters on policy change
To help you connect with other users you already know and, with your permission, allow other users to connect with you
To make statistics on member's service usage, to provide services and place advertisements based on statistical characteristics
To provide information on promotional events as well as the opportunity to participate
To comply with applicable laws or legal obligation
Use of information with prior consent of the users (for example, utilization of marketing advertisement)

The Company agrees that it will obtain a consent from the users, if the Company desires to use the information other than those expressly stated in this Policy.

3. Disclosure of collected information

Except for the following cases, the Company will not disclose personal information with a 3rd party:

when the Company is disclosing the information with its affiliates, partners and service providers;
- When the Company's affiliates, partners and service providers carry out services such as bill payment, execution of orders, products delivery and dispute resolution (including disputes on payment and delivery) for and on behalf of the Company
when the users consent to disclose in advance;
- when the user selects to be provided the information of products and services of certain companies by sharing his or her personal information with those companies
- when the user selects to allow his or her personal information to be shared with the sites or platforms of other companies such as social networking sites
- other cases where the user gives prior consent for sharing his or her personal information
when disclosure is required by the laws:
- if required to be disclosed by the laws and regulations; or
- if required to be disclosed by the investigative agencies for detecting crimes in accordance with the procedure and method as prescribed in the laws and regulations

4. Cookies, Beacons and Similar Technologies

The Company may collect collective and impersonal information through 'cookies' or 'web beacons'.

Cookies are very small text files to be sent to the browser of the users by the server used for operation of the websites of the Company and will be stored in hard-disks of the users' computer.

Web beacon is a small quantity of code which exists on the websites and e-mails. By using web beacons, we may know whether a user has interacted with certain webs or the contents of email.

These functions are used for evaluating and improving services and setting up users' experiences so that much improved services can be provided by the Company to the users.

The items of cookies to be collected by the Company and the purpose of such collection are as follows:

Category	Reasons for using cookies and additional information
strictly necessary cookies	This cookie is a kind of indispensable cookie for the users to use the functions of the website of the Company. Unless the users allow this cookie, the services such as shopping cart or electronic bill payment cannot be provided. This cookie does not collect any information which may be used for marketing or memorizing the sites visited by the users. Check whether login is made on website Connect the users with a certain application or server of the services
performance cookies	This cookie collects information on how the users use the website of the Company such as the information of the pages which are visited by the users most. This data helps the Company to optimize its website so that the users can search that website more comfortably. This cookie does not collect any information on who the users are. Any and all the information collected by this cookie will be processed collectively and the anonymity will be guaranteed. Web analysis: provide statistical data on the ways of using website Advertisement response fee: check the effect of advertisement of the Company Tracing affiliated companies: one of the visitors of the Company provides anonymously feedback to the affiliated companies Management of error: measure an error which may occur so as to give help for improving website Design testing: test other design of the website of the Company
functionality cookies	This cookie is used for memorizing the set-ups so that the Company provides services and improves visit of users. Any information collected by this cookie does not identify the users individually. Memorize set-ups applied such as layout, text size, basic set-up and colors Memorize when the customer responds to a survey conducted by the Company

The users have an option for cookie installation. So, they may either allow all cookies by setting the option in the web browser, make each cookie checked whenever it is saved, or refuse all cookies to be saved. Provided that, if the user rejects the installation of cookies, it may be difficult for that user to use parts of the services provided by the Company.

5. User's right

The users or their legal representatives, as main agents of the information, may exercise the following rights regarding the collection, use and sharing of personal information by the Company:

exercise the right to access to personal information;
make corrections or deletion;
make temporary suspension of treatment of personal information; or
request the withdrawal of their consent provided before

If, in order to exercise the above rights, you, as a user, use the menu of 'amendment of member information' of the webpage or contact the Company by sending a document or e-mails, or by using telephone to the Company (or the person in charge of management of personal information or a deputy), the Company will take measures without delay. Provided that the Company may reject the request of you only to the extent that there exists either proper cause as prescribed in the laws or an equivalent cause.

6. Security

The Company regards the security of personal information of users as very important. The Company constructs the following security measures to protect the users' personal information from any unauthorized access, release, use or modification:

Encryption of personal information
- Transmit users' personal information by using an encrypted communication zone
- Store important information such as passwords after encrypting it
Countermeasures against hacking
- Install a system in the zone the external access to which is controlled so as to prevent leakage or damage of users' personal information by hacking or computer virus
Establish and execute internal management plan
Install and operate access control system
Take measures to prevent forging or alteration of access record

7. Modification of Privacy Protection Policy

The Company has the right to amend or modify this Policy from time to time and, in such case, the Company will make a public notice of it through the bulletin board of its website (or through individual notice such as written document, fax or e-mail) and obtain consent from the users if required by relevant laws.

8. Others

The following appendices may apply depending on the user's region and applicable law.

Appendix of Privacy Protection Policy

<1> Lawful processing of personal information under GDPR

Processing personal information by the Company shall be lawful only if and to the extent that at least one of the following applies:

A user has given consent to the processing of his or her personal information.
Processing is necessary for the performance of a contract to which a user is party or in order to take steps at the request of a user prior to entering into a contract:
- Member management, identification, etc.
- Performance of a contract in relation to providing the services required by users, payment and settlement of fees, etc.
Processing is necessary for compliance with a legal obligation to which the Company is subject
- Compliance with relevant law, regulations, legal proceedings, requests by the government
Processing is necessary in order to protect the vital interests of users, or other natural persons
- Detection of, prevention of, and response to fraud, abuse, security risks, and technical issues that may harm users or other natural persons
Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Company
Processing is necessary for the purposes of the legitimate interests pursued by the Company or by a third party (except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child).

<2> User's right when applying GDPR

The users or their legal representatives, as main agents of the information, may exercise the following rights regarding the collection, use and sharing of personal information by the Company:

The right to access to personal information;
- The users or their legal representatives may access the information and check the records of the collection, use and sharing of the information under the applicable law.
The right to rectification;
- The users or their legal representatives may request to correct inaccurate or incomplete information.
The right to erasure;
- The users or their legal representatives may request the deletion of the information after the achievement of their purpose and the withdrawal of their consent.
The right to restriction of processing;
- The users or their legal representatives may make temporary suspension of treatment of personal information in case of disputes over the accuracy of information and the legality of information treatment, or if necessary to retain the information.
The right to data portability;
- The users or their legal representatives may request to provide or transfer the information.
The right to object;
- The users or their legal representatives may suspend the treatment of personal information if the information is used for the purpose of direct marketing, reasonable interests, the exercise of official duties and authority, and research and statistics.
The right to automated individual decision-making, including profiling;
- The users or their legal representatives may request to cease the automated treatment of personal information, including profiling, which has critical impact or causes legal effect on them.

If, in order to exercise the above rights, you, as a user, use the menu of 'amendment of member information' of the webpage or contact the Company by sending a document or e-mails, or by using telephone to the Company (the person in charge of management of personal information or a deputy), the Company will take measures without delay. Provided that the Company may reject the request of you only to the extent that there exists either proper cause as prescribed in the laws or an equivalent cause.

<3> Data transfer to other countries

Considering it engages in global businesses, the Company may provide the users' personal information to companies located in other countries for the purpose as expressly stated in this Policy. For the places where the personal information is transmitted, retained or processed, the Company takes reasonable measures for protecting that personal information.

In addition, when the personal information obtained from the European Union or Switzerland is used or disclosed, the Company may have to comply with the US-EU Privacy Shield and Swiss-US Privacy Shield, take other measures or obtain consent from users so far as that complies with the regulations of the EU so as to use a standardized agreement provision approved by executing organizations of the EU or securing proper safe measures.

<4> 3rd party's sites and services

The website, product or service of the Company may include the links to those of a 3rd party and the privacy protection policy of the site of the 3rd party may be different. Thus, it is required for the users to check additionally the policy of a 3rd party site linked to the site of the Company.

<5> Guide for users residing in California

If the user resides in California, certain rights may be given. The Company prepares preventive measures necessary for protecting personal information of members so that the Company can comply with online privacy protection laws of California.

In case of leakage of personal information, a user may request the Company to check the leakage. In addition, all the users in the website of the Company can modify their information at any time by using the menu for changing information by connecting to their personal account.

Moreover, the Company does not trace the visitors of its website nor use any signals for 'tracing prevent'. The Company will not collect and provide any personal identification information through ad services without consent of users.