Privacy Policy | ALDER_EN

Personal Information Processing Policy

1. General Provisions

ALDER INVESTMENTS LTD. has established the following processing policy to protect the personal information and rights of data subjects (customers) and to smoothly handle any issues related to personal information, in accordance with Article 30 of the Personal Information Protection Act.

This policy may be changed according to the enactment or revision of relevant statutes or the operational policies of the government or the company, and any changes will be disclosed at the company's website.

2. Items of Personal Information Collection, Methods, and Processing Purposes

※ ALDER INVESTMENTS LTD. does not collect/store any personal customer information under any circumstances because it does not conduct direct sales or business with individual customers. However, 'cookie' information such as user access frequency and time, and service usage records are automatically collected during the process of using internet homepage services or when the company processes website user information.

※ Customer participation events, prize events, or requests for regular subscriptions to market information are conducted through the website, basic customer information (name, address, email, phone number, etc.) may be collected/stored for the purpose of the event. Even in such cases, ALDER INVESTMENTS LTD.'s website does not collect any personal information beyond basic business card-level information.

1) The items of other personal information collected and the purposes of processing are as follows.

① When it is inevitably necessary for the sale of collective investment schemes, the conclusion and execution of entrustment contracts with trust companies
a. Collection Items
- Information about the responsible officers and employees of the sales and trust companies (name, company name, department, position, company address, phone number, email)
B. Purpose of Processing
- Execution of tasks related to the entrustment sale of collective investment schemes and trust business

② When it is inevitably necessary for the conclusion and execution of an investment advisory contract
a. Collection Items
- Information about the customer's responsible employees (name, company name, department, position, company address, phone number, email)
B. Purpose of Processing
- Execution of contracts and operation of investment advisory

③ When it is inevitably necessary for the execution of other operational tasks of the collective investment scheme
a. Collection Items
- Information about the responsible employees of the investment trading/brokerage company or corporate investor (name, company name, department, position, company address, phone number, email)
B. Purpose of Processing
- Performing order tasks and providing information on requests from corporate investors

④ When 'cookie' information such as the user's access frequency and time, and service usage records is automatically collected while using internet homepage services or processing website user information .
a. Collection Items
- A cookie is a very small text file sent by the server used to operate the website to the user's browser, and it is stored on the computer or mobile device used by the user to access the website. ALDER INVESTMENTS LTD. will provide enhanced online experience to website users through cookies, particularly by analyzing users' access frequency, visit times, visit counts, and preferred technical environments, as well as assessing operation of the website.

B. Matters concerning the installation/operation and rejection of devices automatically collecting personal information
-Installation/operation and rejection of cookies:
Users can choose about installing cookies. Accordingly, users can set options in their web browser to allow all cookies, verify when a cookie is stored, or refuse the storage of all cookies. However, refusing the storage of cookies may limit the ability to receive some personalized services.

• For Internet Explorer: Tools menu at the top of the web browser > Internet Options > Privacy > Settings
• For Chrome: Settings menu on the right side of the web browser > Show advanced settings at the bottom of the screen > Content settings button under Privacy > Cookies

2) The company collects the above information by using the following methods.
- Information of employees of the selling company, investmenttrading/brokerage company and corporate investors of the collective investment scheme is specified in contracts or related documents, or provided separately by the customer.

3) The company must use the personal information provided by the customer within the scope of the above purposes. However, in the following cases, it may be used beyond the scope of the purposes as an exception.

① When separate consent is obtained from the customer
② When there are special provisions in the law
③ In cases where the customer or his/her legal representative is unable to express intent or cannot be contacted due to an unknown address, and it is deemed necessary for the urgent benefit of the customer or a third party's life, body, or property.
④ When it is necessary for purposes such as statistical compilation and academic research, and personal information is provided in a form that does not allow the identification of a specific individual.

3. Processing and Retention Period of Personal Information

The company shall destroy the relevant information without delay once it achieves the purpose of collecting and using personal information.

4. Matters Concerning the Procedures and Methods for the Destruction of Personal Information

The company, in principle, destroys the personal information without delay after the purpose of collection and use has been achieved, using the following methods.
1) Personal information printed on paper: Shred with a shredder or incinerated for disposal
2) Personal information stored in electronic file format: Permanently delete by using technical methods that make the records unrecoverable

5. Matters Concerning the Provision of Personal Information to Third Parties

1) The company cannot provide the personal information provided by the customer to a third party other than the personal information handling trustee without the customer's consent. However, in the following cases, it may be provided within the scope of the collection purpose.

① In cases where there are special provisions in the law or it is unavoidable to comply with statutory obligations
② In cases where the customer or his/her legal representative is unable to express intent or cannot obtain prior consent due to unknown address, etc., and it is deemed necessary for the urgent benefit of the customer's or third party's life, body, or property

2) When the company obtains the customer's consent according to the above 1), it must inform the customer of the following matters, and if there are any changes to these matters, it must also inform and obtain consent.

① Recipient of Personal Information
② Purpose of Use of Personal Information by the Recipient
③ Items of Personal Information Provided
④ Retention and Use Period of Personal Information by the Recipient
⑤ The fact that there is a right to refuse consent and, if there are any disadvantages due to refusal, the details of such disadvantages

3) The company may provide information to a third party beyond the purposes outlined in 1) and 2) in the following cases.

6. Matters Concerning the Delegation of Personal Information Processing

The company, in principle, does not entrust the processing of personal information to others without the consent of the data subject.

7. Matters concerning the rights, obligations of the customers, and methods of exercise

1) Right to request inspection of personal information

① The customer may request to inspect his/her personal information processed by the company.
② When the company receives a request for inspection from the customer, it must allow the customer to inspect the relevant personal information within 10 days. If there is a legitimate reason for not being able to inspect, the company must inform the customer of the reason and may postpone the inspection. Once the reason ceases to exist, the inspection must be conducted without delay.
③ The company may restrict or refuse inspection by informing the customer of the reason if it falls under any of the following circumstances.
a. When inspection is prohibited or restricted by law
B. When there is a concern that it may harm another person's life or body, or unjustly infringe on another person's property and other interests

2) Right to request correction or deletion of personal information

① The customer may request the company to correct or delete his/her personal information. However, if the personal information is required as a subject of collection by another statute, deletion cannot be requested.
② The company must promptly take necessary actions such as correction or deletion and inform the customer of the results when the customer requests correction or deletion of his/her personal information, unless a special procedure is prescribed by other statutes.
③ When the company deletes personal information, it must ensure that it cannot be recovered or reproduced.
④ The company may require the customer to submit evidence necessary to verify the correction or deletion request, if necessary.

3) Right to Request Suspension of Personal Information Processing

① The customer may request the company to suspend the processing of his/her personal information.
② If the customer requests the suspension of his/her personal information processing, the company must immediately suspend all or part of the processing of personal information. However, in the following cases, the company may refuse the customer's request for suspension of processing.
a. When there are special provisions in the law or it is unavoidable to comply with statutory obligations
B. When there is a concern that it may harm another person's life or body, or unjustly infringe on another person's property and other interests
c. When it is difficult to fulfill the contract, such as providing services agreed with the customer, if personal information is not processed, and the customer has not clearly expressed his/her intention to terminate the contract
③ The company must promptly take necessary actions, such as the destruction of the relevant personal information, for personal information whose processing has been suspended at the customer's request.

8. Matters concerning measures to ensure the security of personal information

The company is taking administrative, technical, and physical measures necessary to ensure security so that personal information is not lost, stolen, leaked, altered, or damaged.
1) Establishment and implementation of an internal management plan for the secure processing of personal information
2) Measures to control access to personal information and restrict access rights
3) Application of encryption technology or equivalent measures to securely store and transmit personal information
4) Measures to preserve access logs and prevent forgery and alteration in response to personal information breach incidents
5) Installation and updating of security programs for personal information
6) Physical measures such as preparing storage facilities or installing locking devices for the safe storage of personal information

9. Complaint services regarding personal information

The company designates and operates personal information handlers and managers as follows to protect customers' personal information and handle complaints related to personal information.

Name: Ki-Hyun Shin, Compliance Officer
Affiliation: ALDER INVESTMENTS LTD.
Contact: (Main) 02-6012-2100, (Direct) 070-4272-8226

Customers can report any personal information protection-related complaints arising from the use of the company's services to the above-mentioned personal information protection manager or person in charge. The company will promptly verify the identified issues and take actions as quickly as possible if corrections are necessary. The company will always make every effort to protect the customer's personal information.

Remedy for Infringement of Rights Regarding Personal Information

The data subject can inquire about remedies and consultations for personal information infringement with the following organizations. The following organizations are separate from the company. If you are not satisfied with the company's own handling of personal information complaints or remedy results, or if you need more detailed assistance, please contact them.

Personal Information Infringement Report Center (Operated by Korea Internet & Security Agency)

- Jurisdiction: Reporting personal information infringement, applying for consultation

- Website: privacy.kisa.or.kr

- Phone: (without area code) 118

- Address: (138-950) 135 Jungdae-ro, Songpa District, Seoul City, Korea Internet & Security Agency, Personal Information Infringement Report Center
Personal Information Dispute Mediation Committee (Operated by Korea Internet & Security Agency)

- Jurisdiction: Application for personal information dispute mediation, collective dispute mediation (civil resolution)

- Website: privacy.kisa.or.kr

- Phone: (without area code) 118

- Address: (138-950) 135 Jungdae-ro, Songpa District, Seoul City, Korea Internet & Security Agency, Personal Information Infringement Report Center
Supreme Prosecutors' Office Cyber Crime Investigation Unit: 02-3480-3581 (www.spo.go.kr)
National Police Agency Cyber Safety Bureau: Without area code 112 (emergency consultation, free) or without area code 182 (civil consultation, paid)
(http://cyberbureau.police.go.kr)

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