NAVER ranks the protection of personal information as top priority value among several managerial components.
NAVER Corporation (“NAVER” or “Company”) strictly complies with all domestic laws and regulations, including the Personal Information Protection Act, in all stages from service planning to termination. Furthermore, NAVER provides services in compliance with international standards, including the OECD Privacy Guidelines.
1. What Privacy Policy Means for Our Users NAVER has made efforts to describe the current status of processing personal information within NAVER as detailed and easy as possible, while creating this Privacy Policy based on the Personal information protection Act.
This is because NAVER has adopted the “Plain Language Privacy Policy,” as its principle in writing Privacy Policy with concise and easy-to-understand terms.
Privacy Policy has the following important implications.
Users may access the majority of NAVER services in a manner equivalent to members, such as information searches and viewing news articles without any need to subscribe as members.
When a user subscribes to use personalized or membership services such as e-mail, calendar, cafe, blog, and more, NAVER collects the minimum amount of personal information needed for him/her to use such services.
The personal information that NAVER collects from users at the time they sign up for membership is as follows.
Personal information collected from users during their service use is as follows.
The IP address, cookies, service usage records, device information, and location information may be generated and collected during service use.
In addition, images or voice data may also be collected from search services using images and voice data.
To be specific, 1) information about users is generated in an automated manner or information that users entered is stored (collected) during their service use or 2) the unique device information of users is safely converted to prevent the original values from being identified and such converted information is then collected. Location information may be collected during the service use, and the location-based service provided by NAVER is regulated in details in the “Terms of Location-Based Service”
The collected information may correspond to personal information or not, depending on whether it is linked to personal information.
NAVER collects personal information under the following methods.
Personal information is used only to manage members of NAVER and all other related services (including mobile web/app), develop, provide, and improve services, and establish a safe Internet environment.
After pseudonymizing the collected personal information to make it impossible to identify a particular individual, NAVER can process the information for purposes such as statistical, scientific research, and archiving for the public interest. At this time, the pseudonymized information shall be stored and managed separately from additional information to prevent re-identification, and necessary technical and managerial safeguards shall be taken.
In principle, NAVER does not provide personal information to the outside without the consent of users.
NAVER does not provide personal information to the outside without prior consent from users. However, personal information is provided in limited circumstances if a user personally agrees to provide his/her personal information in order to use the service of an outside partner, if NAVER becomes obliged to submit personal information under the relevant laws and regulations, or if an urgent risk to life or safety of users is identified.
NAVER entrusts part of its work to the outside to provide convenient and better services.
NAVER entrusts part of its work necessary to provide services to outside companies, stipulates the matters necessary for the entrusted party to safely process personal information, and carries out management or supervision to ensure such safe processing, in accordance with the Personal Information Protection Act. If a user does not use the service related to the work entrusted to the entrusted party, his/her personal information will not be provided to the said entrusted party.
Information regarding the consignment of the company's consignment Entrusted Company Entrusted Operations Retention and Usage Period of Personal InformationNAVER Cloud Corp., the entrusted company, stores personal information outside of Korea in the following way.
The following are cases where the outsourcing of personal information processing is necessary for the conclusion and performance of a contract with the data subject (Article 28-8, Paragraph 1, Item 3 of the Personal Information Protection Act):
NAVER safely stores data within and outside of Korea to continue providing the company's services even in the event of natural disasters and catastrophes. "NAVER Cloud Corp." is an affiliate of NAVER and is subject to the same data protection policy as NAVER. Furthermore, the company performs data management tasks under NAVER's strict control, which includes blocking data access from abroad. In the event of a loss due to natural disasters or catastrophes, a full data backup is conducted to recover data. Refusal to comply may result in inability to use the service. If you don't want to relocate, you can either proceed with membership withdrawal or request assistance through our customer service center.
Some services use external software development kits (SDKs) and solutions, which may involve the overseas processing and outsourcing of personal information for service provision. This outsourcing of personal data processing is necessary for providing the service; if you do not wish for your personal data to be transferred overseas, you can refuse the overseas transfer by not using the related services.
In principle, the company destroys users' personal information without any delay either when they withdraw from membership or the company achieves its purpose of use.
However, if the Company has obtained separate consent from users regarding the retention period of personal information or if the laws and regulations impose duties to retain information for a certain period, personal information may be stored safely during the designated period.
NAVER will obtain consent from users for the retention period of personal information at the time of their member or service subscription for the following purposes.
Relevant statutes, including the Act on the Consumer Protection, in Electronic Commerce, Etc., the Framework Act on Electronic Documents and Transactions, and the Protection of Communications Secrets Act, require NAVER to store the information for a certain period of time under the following circumstances. NAVER stores personal information during the set period under the provisions of the statutes and in no case will it ever store this information for any other purposes.
Personal information that fully serve its purpose of collection and use, by means such as membership cancellation, service termination, and/or expiration of the retention period of personal information approved by the user, is destroyed to an irreversible state.
Information required to be retained under the statutes is also destroyed to an irreversible state without delay after the expiration of the relevant period.
Personal information stored in electronic form is securely deleted by technical means to prevent its recovery or restoration, while written information is shredded or incinerated.
NAVER makes every effort to securely manage users' personal information(including pseudonymous information) and protects personal information beyond the degree required by the Personal Information protection Act.
NAVER has established and implemented an internal privacy management plan.
NAVER has established an internal personal information management plan, containing matters in relation to the composition and operation of the privacy organization, such as the designation of privacy personnel, and inspect whether the internal management plan is implemented effectively each year.
Actions are undertaken to control access to and restrict the right to access personal information.
In order to prevent illegal access to personal information, NAVER has established the standards for granting, modifying, and canceling access rights to the personal information processing system, and runs an intrusion prevention system and intrusion detection system. Employees that handle personal information are kept to a minimum and Intranet is completely cut off from external Internet for the work computers of employees that are permitted to download personal information from the personal information processing system, thereby reducing the risk of personal information leakage.
Personal information is being encrypted for safe storage and transmission.
In addition to the passwords, unique identifiable information, account numbers, and credit card numbers that are encrypted for storage as required by law, email addresses and mobile phone numbers are also encrypted and stored. NAVER also safely sends and receives personal information over the network via encrypted communication.
Actions are taken to store personal information access records and prevent any forgery and tampering.
The personal information handler stores and manages access records for the personal information processing system, periodically inspects access records to prevent any misuse, abuse, loss, forgery, and tampering of personal information, and safely stores the relevant access records so that they are not forged, stolen, or lost.
NAVER installs and renews security programs for personal information.
NAVER frequently backs up data to offset risk of any damage to personal information, and uses the latest antivirus software to prevent leakage or damage of users' personal information.
NAVER enforces physical actions to keep personal information safe.
In order to prevent leakage or damage of members' personal information caused by hacking or computer viruses, NAVER installs systems in areas with restricted access from the outside, and establishes and operates access control procedures.
NAVER establishes and operates detailed plans that must be executed in crisis due to disasters and calamities.
Detailed plans, including crisis response guidelines, are prepared, and response systems are in place to minimize inconvenience to users during such situations.
NAVER operates a separate organization that only deals with the protection of personal information.
In 2007, NAVER became the first company in Korea to create the Privacy Team. Even to this day, the Privacy Department continues to enforce technical/administrative protective measures at all times to ensure that all executive and employees of NAVER fully comply with their duties to protect the personal information of users.
NAVER is the first company in Korea to run a blog and website entirely dedicated to the protection of personal information.
NAVER has launched Korea's first blog entirely dedicated to the protection of personal information to communicate with users. NAVER also provides Privacy as a Service to protect the privacy of users through its NAVER Privacy Center.
NAVER audited by domestic and international certification authorities for its privacy activities.
NAVER is regularly audited by external authorities for its information protection activities through the international information security standard ISO/IEC 27001 and the Korean information security standard ISMS-P·ISMS. NAVER is audited for the level of its internal service control under the auditing standards of the American Institute of Certified Public Accountants (AICPA) and the results are published in SOC reports.
NAVER has designated the following persons as the Chief Privacy Officer and Personal Information Manager to remain responsible for responding to user inquiries regarding personal information and resolving any related complaints.
If you need to report or consult on other privacy infringements, please contact the following institutions.
NAVER safely manages users' personal location information in accordance with the Act on the Protection and Use of Location Information.
Purpose of processing and period of use of personal location information
NAVER destroys personal location information without delay after one-time or temporary use from most location-based services. However, when a user posts or stores personal location information along with posts and content on NAVER’s service, such as in the ‘GeoTagging’ service, the personal location information is stored together during the retention period of the posts and content.
The purpose of processing personal location information to provide NAVER's location-based services is as follows.
Grounds for and period of retaining data verifying the collection, usage and provision of location information
In accordance with Article 16 (2) of the Act on the Protection and Use of Location Information, NAVER automatically records data verifying the collection, use, and provision of location information in a location information system, and preserves the data for 6 months or longer.
Procedure and method for the destruction of personal location information
When the purpose of processing personal location information has been attained, NAVER safely destroys personal location information in an unrecoverable way. Electronic files are destroyed using a technical method that cannot be recovered or regenerated, and documents are shredded or incinerated.
Matters on providing personal location information to third parties and notification of such provision
NAVER does not provide personal location information to a third party without prior consent from the user. In case NAVER provides personal location information to a third party designated by the user, NAVER immediately notifies the subject of personal location information of the designated recipient of such information, the date and time, and the purpose of such provision on each occasion.
NAVER only provides personal location information to a third party when a user directly consents to the provision of personal location information in order to use the services of an outside partner, when NAVER is obligated to provide personal location information in accordance with relevant laws, and when an imminent risk to the life or safety of a user is confirmed and such risk needs to be addressed.
Rights and responsibilities held by the legal guardian of children of eight years old or younger, etc., and how to exercise them
Where the legal guardian of any of the following users (hereinafter referred to as "child of eight years old or younger, etc.") gives consent to the use or provision of personal location information regarding the child of eight years old or younger, etc. for the protection of their health or safety, NAVER deems that the user him/herself has given his/her consent.
For the protection of the health or safety of a child of eight years old or younger, etc., the legal guardian who intends to consent to the use or provision of personal location information must submit a written consent to NAVER along with a document proving that he/she is the legal guardian.
The legal guardian can exercise all of the rights of the subject of personal location information if he/she agrees to the use or provision of personal location information for a child of eight years old or younger, etc.
Person responsible for managing location information
The above person responsible for protecting personal information at NAVER is also in charge of managing location information.
Users will be notified of any addition, deletion, and/or modification in this Privacy Policy through ‘Notice’ at least 7 days prior to the scheduled amendment.
However, if an important modification is made to the rights of users, such as the modification to the collected items of personal information and the purposes of their use, the notification will be sent at least 30 days prior to any such modification, and if necessary, NAVER may obtain users’ consent again.
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