Keystone Agency LLC (hereinafter referred to as the "Company") recognizes the importance of protecting the personal information of users of the Company's services (hereinafter referred to as "Users"). In addition to complying with the Act on the Protection of Personal Information, guidelines for each business field set forth by the competent authorities, and other related laws and regulations, the Company will handle personal information, etc., in accordance with the policy set forth below (hereinafter referred to as the "Policy").
(Acquisition of Personal Information, etc.)
- The Company shall handle information obtained by lawful and fair means. In addition, personal information obtained from Users may be used mutually in the course of their respective services and operations. Users' personal information shall be defined as "Personal Data" as defined under Article 16, Paragraph 3 of the Act on the Protection of Personal Information (Act No. 57 of 2003, hereinafter referred to as the "Act") among the "Personal Information" as defined under Article 2, Paragraph 1 of the same Act. Although some information may not fall under the category of Personal Information depending on its content, we will give due consideration to handling even such User information. (In this Policy, Personal Information and User information that does not fall under Personal Information are collectively referred to as "Personal Details").
- Personal Details of Users who download materials from the "request information" button regarding our services shall be handled as Personal Details as defined in this Policy.
(Purpose and Scope of Using Personal Details)
We will use Personal Details in our possession for the following purposes and will not handle them beyond the scope necessary to achieve these purposes of use.
- Our service offerings (including management of customer information on a third-party CRM).
- Prevention or correction of unauthorized use
- Compilation of statistical data for the purpose of service improvement
- Service announcements (including campaigns)
- Product announcements
- Questionnaire implementation
- Inquiry response
- Personal identification
- Other purposes incidental to the preceding items
When obtaining Personal Details for purposes other than those described in the preceding paragraph, we will clearly indicate and notify the User of the purpose of use, or publicly announce such purpose, with the exception of the following cases:
- When there is a risk of harm to the life, body, property, or other rights or interests of the User or a third party by notifying the User of the purpose of use or publicly announcing it;
- When notifying the User of the purpose of use or publicly announcing the purpose of use is likely to harm the Company's rights or legitimate interests;
- When it is necessary to cooperate with a national agency or local public body in the execution of its legally prescribed duties, and notifying the User of the purpose of use or publicly announcing it is likely to impede the execution of such duties; and/or
- Cases in which the purpose of use is recognized to be clear in light of the circumstances of acquisition.
(Outsourcing of Information Management)
We may outsource the management of Personal Details to the extent necessary. When outsourcing, we will ensure that information management obligations are strictly enforced, including those of the contractor, and that the User's information is properly managed.
(Management of Personal Details)
We will take necessary and appropriate measures to control access to Personal Details, restrict the means of transporting Personal Details, prevent unauthorized access from outside, and prevent leakage, loss, or damage of Personal Details, and otherwise safely manage Personal Details, including transactions of employees and contractors.
(Notification of Purpose of Use)
When we receive a request for notification of the purpose of use from the User himself/herself or his/her representative, we will notify the User of the purpose of use. However, this shall not apply in any of the following cases:
- When the purpose of use of Personal Details is clear;
- When notifying the User of the purpose of use or publicly announcing the purpose of use is likely to harm the Company's rights or legitimate interests; and/or
- When it is necessary to cooperate with a national agency or local public body in the execution of its legally prescribed duties, and notifying the User of the purpose of use or publicly announcing it is likely to impede the execution of such duties.
(Disclosure of Personal Information)
When we receive a request for disclosure of such Personal Details and records of provision to third parties from the User himself/herself or his/her representative, we will respond, except in the following cases:
- When there is a risk of harm to the life, body, property, or other rights or interests of the User or a third party;
- When there is a risk of significant hindrance to the proper conduct of our business; and/or
- When it would violate laws and regulations.
(Corrections of Personal Details)
When we receive a request from a User or his/her representative to correct, add, or delete (hereinafter referred to as "Corrections") the content of the relevant Personal Details because the content is not true, we will investigate the request. As a result of the investigation, if the contents of the request are found to be appropriate, we will make the Corrections.
(Suspensions of Use)
- When we receive a request from a User or his/her representative to cease using or delete (hereinafter referred to as "Suspensions") Personal Details, without obtaining the prior consent of the User or his/her representative, exceeding the scope necessary to achieve the purpose of use or acquired through deception or other wrongful means, we will investigate the request and will not use or otherwise delete the Personal Details for any other purpose. As a result of the investigation, if the content of the request is deemed appropriate, the use of the relevant Personal Details will be suspended.
- When we receive a request from a User or his/her representative to stop the provision of Personal Details to a third party on the grounds that such Personal Details has been illegally provided to a third party without the consent of the User, we will conduct an investigation. As a result of the investigation, if the content of the request is found to be reasonable, the provision of the information to third parties will be suspended.
In addition to the preceding two paragraphs, the User himself/herself or his/her representative may request the Company the Suspensions of Use and to cease the provision of Personal Details to a third party if any of the following circumstances arise:
- When there is no longer a need to use the retained Personal Data;
- When leakage, etc., of retained Personal Data has occurred; and/or
- When there is a risk that the rights or legitimate interests of the individual concerned may be harmed by the handling of other retained Personal Data.
- We may collect personal preference information, history, and other information related to Users' Personal Information (hereinafter referred to as "Usage Information") from cookies, IP addresses, etc., for the purpose of improving the convenience of the service, distributing advertisements, obtaining statistical data, and for other purposes described under Article 3.
- We may use the Usage Information collected in accordance with the preceding paragraph without any restrictions as long as the information is used in a form that does not identify an individual or cannot be referred to or compared with Personal Information.
(Contact for Inquiries)
Enacted April 28, 2023