Culture Capital (hereinafter "the Company") establishes and discloses the following personal information processing guidelines in accordance with Article 30 of the Personal Information Protection Act, in order to protect the personal information of data subjects and to handle related grievances promptly and smoothly.

Article 1 (Purpose of Processing Personal Information)
The Company processes personal information for the following purposes. The personal information processed will not be used for any purpose other than the following, and if the purpose of use changes, the Company will take necessary measures, such as obtaining separate consent pursuant to Article 18 of the Personal Information Protection Act.

1. Account Opening Consultation and Service Provision
Personal information is processed for the purpose of receiving account opening applications, assigning and contacting consultation staff, providing service guidance, and handling grievances.

2. Handling Grievances
Personal information is processed for the purpose of verifying the identity of complainants, confirming the details of complaints, contacting and notifying for fact-finding, and notifying the results of processing.

Article 2 (Retention and Use Period of Personal Information)
① The Company processes and retains personal information within the personal information retention and use period stipulated by law or the personal information retention and use period agreed upon when collecting personal information from data subjects.
② The retention and use period for each category of personal information is as follows.

Account Opening Consultation and Service Provision: Retained during the period of service use, until membership withdrawal or service termination.
However, in the following cases, until the end of the relevant reason:
1. If an investigation or inquiry is in progress due to a violation of relevant laws and regulations, until the end of the relevant investigation or inquiry.
2. If a creditor-debtor relationship remains due to service use, until the settlement of the relevant creditor-debtor relationship.

Article 3 (Provision of Personal Information to Third Parties)
① The Company processes personal information of data subjects only within the scope specified in Article 1 (Purpose of Processing Personal Information), and provides personal information to third parties only in cases falling under Articles 17 and 18 of the Personal Information Protection Act, such as the consent of the data subject or special provisions of the law. Otherwise, the Company does not provide personal information of data subjects to third parties.
② The Company may provide personal information to third parties only to the minimum extent necessary, with the consent of the data subject in accordance with Article 17, Paragraph 1, Item 1 of the Personal Information Protection Act, when necessary for smooth service provision.
- Recipient of personal information: Partner companies required for service provision and operation (separately notified upon provision)
- Purpose of use of personal information by the recipient: Account opening support, service guidance, and marketing cooperation
- Items of personal information provided: Name, contact number, email
- Retention and use period of the recipient: Until the purpose of provision is achieved or consent is withdrawn

Article 5 (Rights of Data Subjects and Legal Representatives, and How to Exercise Them)
① Data subjects may exercise the following personal information protection rights against the Company at any time.
1. Request to view personal information
2. Request for correction in the event of errors, etc.
3. Request for deletion
4. Request to suspend processing
② Rights under Paragraph 1 may be exercised against the Company in writing, by telephone, or by e-mail, and the Company will take action without delay.
③ If a data subject requests correction or deletion of an error in their personal information, the Company will not use or provide the personal information in question until the correction or deletion is complete.
④ Rights under Paragraph 1 may be exercised through a legal representative of the data subject or a person delegated by the data subject. In this case, a power of attorney must be submitted in accordance with Attached Form No. 11 of the Enforcement Rules of the Personal Information Protection Act.
⑤ Data subjects must not infringe upon their own or others' personal information and privacy that is being processed by the Company, in violation of the Personal Information Protection Act or other relevant laws.

Article 6 (Items of Personal Information Processed)
The Company processes the following items of personal information.

Account Opening Consultation and Service Provision
Required items: Name, email, contact number, preferred consultation time, CFD investment experience, information source
Optional items: None

Article 7 (Destruction of Personal Information)
① The Company destroys personal information without delay once the retention period has elapsed, the processing purpose has been achieved, or the personal information otherwise becomes unnecessary.
② If personal information must continue to be preserved under other laws even though the retention period agreed to by the data subject has elapsed or the processing purpose has been achieved, the Company transfers the personal information to a separate database (DB) or preserves it in a different storage location.
③ The procedures and methods for destroying personal information are as follows.
Destruction Procedure: The Company selects personal information for which grounds for destruction have arisen and destroys the personal information upon approval from the Company's Personal Information Protection Officer.
Destruction Method: The Company destroys personal information recorded and stored in electronic file form in a manner that makes the records unrecoverable, and destroys personal information recorded and stored on paper documents by shredding or incineration.

Article 8 (Technical and Administrative Measures to Secure Personal Information)
The Company takes the following measures to secure personal information.
1. Administrative measures: Establishment and implementation of an internal management plan, regular staff training, etc.
2. Technical measures: Management of access rights to personal information processing systems, installation of access control systems, encryption of unique identification information, installation of security programs
3. Physical measures: Access control for computer rooms, data storage rooms, etc.

Article 9 (Installation, Operation, and Refusal of Automatic Personal Information Collection Devices)
① The Company uses "cookies" that store and periodically retrieve user information in order to provide individually customized services to users.
② A cookie is a small amount of information that the server used to operate the website sends to the user's computer browser, and it is stored on the user's PC or mobile device.
③ Data subjects may configure their web browser options to allow all cookies, to be prompted for confirmation each time a cookie is saved, or to refuse the storage of all cookies. However, refusing to save cookies may cause difficulty in using customized services.

▸ Allowing/Blocking Cookies in Web Browsers
- Chrome: Browser settings > Privacy and security > Clear browsing data
- Edge: Browser settings > Cookies and site permissions > Manage and delete cookies and site data

▸ Allowing/Blocking Cookies in Mobile Browsers
- Chrome: Mobile browser settings > Privacy and security > Clear browsing data
- Safari: Mobile device settings > Safari > Advanced > Block All Cookies
- Samsung Internet: Mobile browser settings > Browsing data > Delete browsing data

Article 10 (Personal Information Protection Officer)
① The Company has designated a Personal Information Protection Officer as follows, who is responsible for overseeing personal information processing and handling data subjects' complaints and remedies related to personal information processing.

Department: Customer Support Team
Email: support@culturecapitalllc.com

② Data subjects may inquire about all matters related to personal information protection, complaint handling, and damage relief arising from the use of the Company's services to the personal information protection officer and the department in charge. The Company will respond and process data subjects' inquiries without delay.

Article 11 (Request for Access to Personal Information)
Data subjects may request access to personal information pursuant to Article 35 of the Personal Information Protection Act from the department below. The Company will endeavor to process data subjects' requests for access to personal information promptly.

Department: Customer Support Team
Email: support@culturecapitalllc.com

Article 12 (Methods for Remedy of Rights Infringement)
Data subjects may direct inquiries regarding remedy and consultation for personal information infringement to the following organizations.
1. Personal Information Dispute Mediation Committee: 1833-6972 (no area code) (www.kopico.go.kr)
2. Personal Information Infringement Report Center: 118 (no area code) (privacy.kisa.or.kr)
3. Supreme Prosecutors' Office: 1301 (no area code) (www.spo.go.kr)
4. National Police Agency: 182 (no area code) (ecrm.police.go.kr/minwon/main)

Article 13 (Effective Date and Revision of the Personal Information Processing Policy)
This personal information processing policy is effective as of May 9, 2022.