Privacy PolicyThis is the Privacy Policy of Paradise City. View previous privacy policies 1.2 (Revised on 2021-07-23) 1.1 (Revised on 2020-10-29) 1.0 (Revised on 2020-02-18)

Paradise Segasammy Co., Ltd. (hereinafter “Paradise City”) greatly values its guests’ personal information, and complies with the Personal Information Protection Act.
In this Privacy Policy, Paradise City informs the purpose and method of using the guests’ personal information and the measures taken for personal information protection.

1. • Article 1 (Scope and method of collecting personal information)
2. • Article 2 (Purpose of collecting and using personal information)
3. • Article 3 (Period of keeping and using personal information, and destruction of personal information)
4. • Article 4 (Sharing personal information)
5. • Article 5 (Personal information-processing contractors)
6. • Article 6 (Viewing and correction of personal information, Membership withdrawal, and consent to withdrawal)
7. • Article 7 (Utilization of cookies)
8. • Article 8 (Personal information protection for children below 14 years of age)
9. • Article 9 (Personnel in charge of personal information)
10. • Article 10 (Technical/administrative measures to protect personal information)
11. • Article 11 (Transmission of advertising information)
12. • Article 12 (Obligation to notify)

Article 1 (Scope and method of collecting personal information)

• 1. Scope of collecting personal information
  • A. Paradise City collects personal information to the minimum extent necessary to provide service.
  • B. Paradise City does not collect sensitive personal information whose collection could violate a Member’s basic human rights (e.g., race and ethnicity, ideology and creed, place of birth and permanent address, political inclination, criminal record, health condition, and sexuality).
  • C. Paradise City may process the collected personal information for statistical purposes, scientific research, public record preservation, etc. through information that has been pseudonymized (hereinafter "pseudonymized information") so that a specific individual cannot be identified.
• 2. Method of collecting personal information Paradise City collects personal information through the following methods.
  • 1) Membership subscription (through homepage, writing, phone, or fax), message board, and promotional events participation
  • 2) Receiving from affiliated companies or business partners
  • 3) Collection of payment information and point use information created during use of Paradise City

Article 2 (Purpose of collecting and using personal information)

To provide services, Paradise City collects personal information as follows.

Division			Items collected	Purpose of using information	Period of keeping information
Online	Membership subscription	Required	ID, password, name, date of birth, phone number, email address	Verify identity for Membership service, make announcements to guests and handle complaints, deliver Membership card, provide Hotel product information	Until the termination of membership
		Optional	address, Job/school information, anniversary, area of interest
	Guest room reservation and payment	Required	Name, email address, phone number, gender, date of birth, card payment information	Guest room reservation and payment, provide service to returning guests	5 years
	Guest Comment	Required	Name, email address, phone number	Handle guests’ inquiries and provide service	2 years
	Restaurant reservation	Required	Name, email address, phone number	Make reservation and handle guests’ inquiries	2 years
	Meeting/wedding inquiries	Required	Name, email address, phone number	Make reservation and handle guests’ inquiries	2 years
Offline	Paradise Signature Membership	Required	Name, phone number, date of birth, gender, address, credit card information	Identification process for membership service, annual membership payment, membership management and delivery of the membership card, telephone consultations, etc.	Until the termination of membership
		Optional	Job/school information, anniversary, address	Product/service introduction and offer, market research and R&D, promotional activities, etc.
	Paradise Rewards	Required	Name, phone number, date of birth, gender	Identification process for membership service, Payment, points saving, membership management, product/service offers, telephone consultations, etc.	Until the termination of membership
		Optional	Job/school information, anniversary, address	Product/service introduction and offer, market research and R&D, promotional activities, etc.
	Guest room registration card	Required	Phone number, name, email address	Identification for offering revisit service, delivering customer notification.	5 years
		Optional	address, nationality
	Banquet/party contract	Required	Phone number, name, email address	Provide banquet/party consultation, booking/contracting services	3 years from the date of consultation
		Optional	Company name, nationality, address
	Guest Comment	Optional	Name, email address, phone number	Handle guests’ inquiries and provide service	2 years
	Event ticket	Required	Name, email address, phone number	Handle guests’ inquiries and provide service	Certain period after the end of event (Specified on event ticket)
Online/offline		Optional	Name, email address, phone number	Marketing/PR for goods, events, and services	2 years

• 1. During the use of services, the following personal information items may be automatically created and collected. - IP address, cookie, MAC address, service usage record, visitation record, content of inquiry phone calls, etc.
• 2. It is hereby notified that You may refuse to give consent to the collection and use of this personal information but that if You choose to refuse it, there may be restrictions in You becoming a member.
• 3. If a pseudonym is required for the personal information processed by Paradise City, it is processed in a way that it is impossible to identify a specific individual without combining additional information to restore to its original state.
• 4. Paradise City may use personal information without the consent of the Member to the extent reasonably related to the purpose of collection in accordance with laws and regulations. In this case, comprehensive considerations are made to confirm ‘whether it is related to the original purpose of collection, whether there is predictability given the circumstances of collection or processing practices, whether Member's interests are unreasonably infringed and whether measures necessary to secure safety including pseudonymization or encryption have been taken’.

Article 3 (Period of keeping and using personal information, and destruction of personal information)

• 1. When the purpose of collecting or receiving a Member’s personal information is achieved, Paradise City promptly destroys the personal information. The specific timing of destroying personal information is as follows.
  • A. Membership subscription information is kept for 1 year to provide service to returning guests after the Membership withdrawal (internal policy).
  • B. Information on the use of guest rooms is kept for 5 years to provide service to returning guests (internal policy).
  • C. Records on phone booking and membership consultation (internal policy): Shall be kept for 3 years for the provision of re-visit service and handling of complaints or opinions.
  • D. Shipping information is kept until delivery or provision of goods or services.
  • E. Personal information collected for surveys, events, etc. is kept until completion of the surveys, events, etc.
• 2. However, if personal information needs to be kept for a certain period for reasons such as checking transaction-related rights and obligations as follows under applicable laws such as the Commercial Act, Paradise City does so.
  • A. Records on contract, offer withdrawal, etc.: 5 years
  • B. Records on payment and on supply of goods and services: 5 years
  • C. Records on handling of consumers’ complaints or disputes: 3 years
• 3. Implementing the personal information usage period system
  • A. Paradise City, under Article 29 Paragraph 2 of the Act on Promotion of Information & Communications Network Utilization and Protection of Information and Article 16 of the former’s Enforcement Decree (amended), keeps the personal information of online Members that have not used its services for 1 year or more. This information is kept separate from other information.
• 4. Destroying method
  • A. Print-out personal information: Shredding (by a shredder machine) or incineration
  • B. Personal information stored in the form of an electronic file: Delete by a technical method that disallows reproduction of the records

Article 4 (Sharing personal information)

1. 1. Unless a Member gives consent or unless under applicable laws, Paradise City does not in any circumstance use a Member’s personal information or share it with another person, company, or institution outside of the scope defined in the “Purpose of collecting and using personal information.”
   To share a Member’s personal information through business partnering or alliance, Paradise City gives prior and individual notice concerning the party receiving or sharing the information and its main business, the personal information items shared, the purpose of sharing the information, etc. to the Member by email or in writing and then obtains his/her consent. Paradise City only shares personal information with third parties for its unique services. Unless the aforementioned consent is obtained, provision and use of its normal services may be impossible.
   However, Paradise City may use personal information without the consent of the Member to the extent reasonably related to the purpose of collection in accordance with laws and regulations. In this case, comprehensive considerations are made to confirm ‘whether it is related to the original purpose of collection, whether there is predictability given the circumstances of collection or processing practices, whether the Member's interests are unreasonably infringed and whether measures necessary to secure safety including pseudonymization or encryption have been taken’.
2. 2. In any of the following cases, Paradise City may share a Member’s personal information without his/her consent, pursuant to applicable laws.
   1. A. It is necessary for payment of prices (points) and shipping of products as a result of provision of service.
   2. B. Any personal information necessary for statistics, academic research, or market surveys is shared in a form in which a specific individual cannot be identified
   3. C. It is required by the law, or required by a crime investigation agency pursuant to the procedure and method of law for crime investigation purposes
3. 3. To provide guests with better services, Paradise City shares personal information with third parties as follows.

   Recipients of personal information (affiliated companies or business partners)	Items shared	Purpose of sharing	Period of sharing
   Paradise Group Paradise Global Construction Paradise Hotel Busan Paradise T&L Vino Paradise	Agreement on compulsory information collection/usage	Approve use of points Provide discount by affiliated companies PR for goods and events	Until withdrawal from Membership ※ Available only if agreeing to provide information to the third party.

Article 5 (Personal information-processing contractors)

1. To provide services, Paradise City contracts or outsources personal information processing as follows. Paradise City provides for necessary matters in the outsourcing contract pursuant to applicable laws so that personal information can be safely managed.

Contractor	Items shared	Purpose of sharing	Purpose of sharing
S-1 CORPORATION	CCTV monitoring	Operation of image data processing equipment (CCTV)	032-729-2925
G1 Soft	Operation system, in-website customer information	System development and maintenance	051-582-7820
Grid System	Customer database	Database maintenance	02-424-3560
PC Rescue Squad	In-PC personal information file	PC maintenance	032-729-3367
HCG	Information on employees	HR system maintenance	02-2194-5000
IBM Korea	In-SAP personal information, main server maintenance outsourced	Main server, SAP maintenance	02-3781-7114
Covision	Information on employees	Groupware maintenance	02-6965-3218
Kicc	Credit card information	Credit card transaction approval and invoicing	1600-1234
TA9	In-homepage customer information	Website development and maintenance	02-556-9635
MG Credit Information Service	Information on Paradise Rewards and Signature members	Membership service operation	1588-6444
UI Cosmetics	UI Cosmetics	Payment (check room occupation and apply discounts)	032-729-2440
Imperial Treasure	UI Cosmetics	Payment (check room occupation and apply discounts)	032-729-2227

2. For the safe protection of personal information, Paradise City clearly provides for strict compliance with personal information protection-related directions, prohibitions concerning personal information, and liabilities in the contracts with contractors, and keeps the contracts in writing. In case of a change in contractors, Paradise City announces the new contractor(s) in this Privacy Policy screen on its homepage.
• 3. So that the processing-outsourced personal information can safely be managed, Paradise City shall appropriately supervise whether the contractors diligently perform the aforesaid provisions within the scope of outsourcing.

Article 6 (Viewing and correction of personal information, Membership withdrawal, and consent to withdrawal)

• 1. A Member may at any time view or correct his/her personal information registered, or withdraw his/her Membership.
  1. A. An online Member may revise his/her personal information and withdraw his/her Membership on Paradise City’s homepage ([My Page] menu).
  2. B. A request made on the premises of Paradise City or by phone shall expediently be handled after identity verification.
  3. C. Phone number: 82-1833-8855
• 2. Where a Member requests correction of errors in his/her personal information, Paradise City does not use or provide the relevant personal information until the correction is completed. If the erroneous personal information has already been provided to a third party, then a notice shall promptly be given to the third party so that correction will be made.

Article 7 (Utilization of cookies)

• 1. Paradise City utilizes “cookies” that from store and retrieve a Member’s information from time to time. Cookies, tiny text files which a server used to operate Paradise City’s website, are transmitted to a Member’s browser and stored in a Member’s computer hard disk.
• 2. Paradise City utilizes cookies for the following purposes.
  A. Analyze a Member’s and non-Member’s frequency of access or hours of visit and identify a user’s preference and area of interest. The result is then used as criteria for target marketing, service reshuffling, etc.
  B. Track the information on Paradise City and services in which a Member has shown interest. The result is then used to provide customized services next time.
  C. Identify a Member’s degree of participation and number of visits in various events conducted by Paradise City. The result is then used to provide differentiated opportunities for participation and differentiated information befitting an individual’s area of interest.
  D. A Member can choose whether to install cookies. A Member, by setting options in the web browser, may permit all cookies, require confirmation whenever a cookie is stored, or refuse storage of any cookies.
• - How to designate whether cookie installation is permitted [In the case of Internet Explorer 9.0]
  1. In the [Tools] menu, choose [Internet options].
  2. Click the [personal information tab].
  3. Set the [personal information protection level].
  If a Member refuses installation of cookies, however, Paradise City will have difficulties in providing services.

Article 8 (Personal information protection for children below 14 years of age)

1. Paradise City does not collect personal information from a child below 14 years of age. To otherwise collect information from such a child in connection with hotel business, Paradise City shall comply with applicable laws and government announcements

Article 9 (Personnel in charge of personal information)

• 1. To protect Members’ personal information, Paradise City collects opinions on personal information. To handle complaints, Paradise City has designated a chief personal information officer as follows.

  Classification	Chief personal information officer	Personal information manager
  Name	DH Noh	Ilsu Choi	Jihwan Yeom
  Department	Business & Marketing Strategy	IT	Marketing Communication
  Title	Executive	Assistant Director	Manager
  Phone	+82-32-729-2875	+82-32-729-3363	+82-32-729-2345
  Email	whcdukho@paradian.com	cisside@paradian.com	jeehwan@paradian.com

• 2. For any other inquiries on personal information, please contact the following agencies.
  • Personal Information Violation Reporting Center
    TEL : Call 118 (no prefix)
    URL : http://privacy.kisa.or.kr
  • Cyber Crime Investigation Division, Supreme Public Prosecutor’s Office
    TEL : Call 1301 (no prefix)
    URL : www.spo.go.kr
  • Cyber Safety Bureau, National Police Agency
    TEL : Call 182 (no prefix)
    URL : cyberbureau.police.go.kr

Article 10 (Technical/administrative measures to protect personal information)

• 1. When processing a Member’s personal information, Paradise City takes the following technical measures to secure safety so that the personal information will not be lost, stolen, leaked, altered without authorization, or damaged.
  • A. A user’s personal information is protected by password, and important data is protected through a separate security function by use of file/data encryption or file locking.
  • B. Paradise City adopts a security device that can safely transmit personal information over the network by use of a password algorithm (Secure Socket Layer).
  • C. To prevent a user’s personal information from being leaked through hacking, etc., Paradise City uses a double firewall to block unauthorized access from the outside. It has also installed an anti-intrusion system for each server for 24-hour (24/7) intrusion monitoring.
• 2. Paradise City restricts its personal information processing personnel to a minimum, emphasizes compliance with this Policy through education—from time to time—of the relevant personnel. If Paradise City finds any related problems, it promptly makes corrections.
  • A. Paradise City shall not be liable for errors made by a Member or the inherent risks of the Internet. Each Member shall appropriately manage, and be responsible for, his/her personal information.
  • B. If any personal information is lost, leaked, altered without authorization, or damaged due to Paradise City personnel’s error or a technical/administrative problem, then Paradise City shall immediately notify the user, take appropriate measures, and make appropriate compensations.
  • C. Paradise City separates the pseudonymized information from the additional information so that they are not identified when processing the pseudonymization; stores and manages them separately and takes necessary technical and administrative protective measures.

Article 11 (Transmission of advertising information)

1. 1. Paradise City does not transmit for-profit advertising information against a guest’s express refusal to receive it.
2. 2. To transmit any advertising information by a method such as email for online marketing (e.g., provision of product information), Paradise includes the following in the email’s title and main text so that the guest can easily identify the advertising information.
   • Email title: Indicate the word “advertisement” and the transmitter’s name.
   • Email main text : Specify the name, email address, phone number, and address of the transmitter against whom the user can refuse to receive the advertising information. Specify the methods by which the user can easily refuse to receive the information.
3. 3. To transmit to a guest having consented to receiving of advertisement any for-profit advertising information by a method (e.g., fax, text message) other than email, Paradise City takes necessary measures such as indicating the transmitter’s name.

Article 12 (Obligation to notify)

Addition to, deletion from, and changes in, this Privacy Policy due to the enactment/amendment of laws, changes in government policies, changes in Paradise City’s internal policies, or changes in security technology shall promptly be announced on Paradise City’s homepage.