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[Adapter Wallet Personal Information Processing Policy]

It is about the management and operation of personal information of users who agree to the personal information processing policy provided by Sinest Co., Ltd. (hereinafter referred to as "company") and use the adapter wallet service (hereinafter referred to as "service").
The company considers users' personal information very important, complies with the relevant laws and regulations of information and communication service providers, such as the Information and Communication Network Promotion and Information Protection Act, and does its best to protect users' rights and interests. The company's service privacy policy is as follows.
The company discloses this personal information processing policy on the site so that users can easily check it at any time.
This personal information processing policy may be changed in accordance with relevant laws and internal policies of the company, and when revised, the revision can be easily checked through version management.
Article 1 (Personal information collected by the company)
A. Items of personal information to be collected
(1) Membership registration and management
- [Required] : Email, encrypted password
- [Collection target]: Member, Contact Service Inquirer
(2) Information automatically generated and collected during service use
- [Required]: Encrypted wallet address, encrypted PIN number, service usage record, access log, transaction record, IP information, cookies, OS information, language and country information
- [Selections] : Notification (push app, etc.)
- [Collection target]: All users (members, non-members)
B. How to collect personal information
- Enter user's information through membership registration and inquiry
C. How to keep personal information
- The company stores and stores the user's personal information on the o cloud server located in o.

Article 2 (Purpose of Collection and Use of Personal Information)
The company collects only the minimum personal information of users for the following purposes, and the collected personal information is not used for any purpose other than the following purposes. If the purpose of use is changed, necessary measures will be implemented, such as obtaining separate consent under Article 18 of the Personal Information Protection Act.
A. Membership registration and management
1) Member identification, customer identification, member information management, and delivery of various notices
2) Withdrawal Processing through Non-face-to-face Self-Authentication
B. Provision of Services
C. Handling of grievances
1) Identification of the complainant and confirmation of complaints
2) Contact/notification for fact-finding, notification of processing results, etc

Article 3 (Period of retention and use of personal information)
In principle, personal information is destroyed without delay after the purpose of collecting and using personal information is achieved. However, the following information will be retained for the period specified for the following reasons:
Act on Consumer Protection in Electronic Commerce, etc
- Records of contract or withdrawal of subscription, etc.: 5 years
- Records of consumer complaints or disputes: 3 years
Electronic Financial Transactions Act
Records on electronic financial transactions: 5 years
Communications Secrets Protection
Login History: 3 Months

Article 4 (Separate storage of personal information of long-term unused members)
A. The company considers a member who has not used the adapter wallet service for more than one year as a dormant member, and separately stores the personal information of the dormant member in a separate storage device in accordance with Article 39-6 of the Personal Information Protection Act and Article 48-5 of the Enforcement Decree of the same Act.
B. The company notifies members of the fact that personal information is separately stored one month before the dormant transition, the scheduled dormant date, and the items of personal information stored separately through registered e-mail.

Article 5 (Procedure and method of destruction of personal information)
In principle, after the purpose of collecting and using personal information is achieved, the company destroys the information without delay. Destruction procedures and methods are as follows.
A. Destruction procedure
Information collected for service use is transferred to a separate database (DB for paper), stored for a certain period of time according to internal policy and other relevant laws (see retention and use period), and personal information transferred to a separate DB is not used for any purpose other than prescribed by law.
B. Method of destruction
1) Personal information stored in the form of electronic files is deleted using a technical method that cannot be played back.
2) The personal information printed on the paper is destroyed by grinding or incineration.

Article 6 (Provision of personal information processing)
In principle, the company does not provide users' personal information to the outside world. However, exceptions are made in the following cases.
A. In case of prior consent
B. Where a request is made by an investigative agency in accordance with the provisions of laws and regulations or in accordance with the procedures and methods prescribed by

Article 7 (Rights and obligations of users and legal representatives and methods of exercise)
A. The user or the legal representative of the user may exercise the right to view, correct, delete, or suspend processing of personal information to the company at any time. The user or legal representative may request withdrawal of consent or withdrawal of membership if he or she does not agree to the company's personal information processing. However, in this case, some or all of the services may be difficult to use.
B. Only if it is difficult for the user to exercise his/her rights (correcting or deleting personal information (withdrawing membership) due to unavoidable reasons, he/she may request correction or deletion through e-mail, and the company will take action without delay.
C. If a user or his legal representative requests access, certification, or correction of personal information, respond sincerely to the user's request, and if it is deemed necessary to correct or delete personal information, such as an error or a lapse of preservation period, take action without delay.
D. The exercise of the user's rights can be done through the user's legal representative or delegated person.
In this case, you must submit a power of attorney delegated to you.
E. When requesting correction or deletion of personal information, it cannot be requested to delete personal information if it is specified in other laws and regulations.
F. The company checks whether the person who made the request for perusal, correction, or deletion according to the user's right to use or suspension of processing is the person who made the request for perusal, etc.
G. Personal information terminated, deleted, or corrected at the request of a user or legal representative is processed in accordance with Article 4 "Personal Information Retention and Use Period" and cannot be viewed or used for other purposes.

Article 8 (Technical and administrative protection measures for personal information)
The company is taking the following technical and management measures to ensure safety so that personal information is not lost, stolen, leaked, tampered with or damaged in processing the user's personal information.
A. Encryption of personal information
User's personal information is encrypted, stored, and managed. Passwords, PIN numbers, and wallet addresses are not kept by the company, and only you can know, and the environment and change of personal information are possible only by the person who knows the password.
B. Countermeasures against hacking, etc
The company is doing its best to prevent users' personal information from being leaked or damaged by hacking or computer viruses.
In preparation for personal information damage, data are backed up from time to time, the latest vaccine program is used to prevent leakage or damage of users' personal information, and personal information can be safely transmitted on the network through encrypted communication. In addition, we use intrusion prevention systems to control unauthorized access from outside, and we strive to have all possible technical devices to ensure system security.C. Minimize and train processing staff
The company's personal information processing staff is limited to the person in charge, and a separate password is assigned to the person in charge and updated regularly, and compliance with the personal information processing policy is always emphasized through frequent training.
D. Restrictions on access to personal information processing systems
The company establishes standards for granting, changing, and cancelling access rights to the systematic database system to process personal information, regulates and operates password generation methods and frequency of changes, and takes necessary measures to control access to personal information.
E. Personal e-mail and password management
In principle, the e-mail and password used by members are only used by members. The company is not responsible for the problems caused by the leakage of personal information such as e-mail and password due to the member's personal carelessness and the basic dangers of the Internet. Please change your password frequently with a sense of security for your password and pay special attention to prevent personal information from being leaked.

Article 9 (Personal Information Protection Officer and Personal Information Protection Officer)
In order to protect the user's personal information and handle complaints related to personal information, the company designates the person in charge of personal information and the person in charge of personal information as follows.
a person in charge of privacy
- Name: Lucas Kim
- Position: CPO
- Email: help@adappterwallet.io

Article 10 (Method of remedy for infringement of rights)
Please refer to the institution below if you need damage relief or counseling for personal information infringement.
Personal Information Infringement Report Center (operated by the Korea Internet & Security Agency)
- Home page: privacy.kisa.or.kr
- Phone number: 118
Personal Information Dispute Mediation Committee (run by the Korea Internet Agency)
- Home page: kopico.go.kr
- Phone number: 1833-6972
Supreme Prosecutors' Office Cyber Crime Investigation Team
- Home page: spo.go.kr
- Phone number: 1301
the National Police Agency's Cyber Crime Investigation Unit
- Home page: cyberbureau.police.go.kr
- Phone number: (without number) 182

Article 11 (Change of Personal Information Processing Policy)
The personal information processing policy will be applied from the date of enforcement, and if there is an addition, deletion, or correction in accordance with laws and policies, changes will be notified seven days before the enforcement.

Supplementary Provisions
This personal information processing policy will take effect from ####.