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PRIVACY POLICY

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TOPRANK Co., Ltd. is engaged in business in the areas of car (automobile) sales, car trade-in, car maintenance and repair, HR Solutions, and ancillary services (hereinafter, this business shall be collectively referred to as "service/s"). As a company handling personal information for the promotion of our business, we remain fully aware of the importance of handling and managing such information, and observe the Act on the Protection of Personal Information and other related laws and regulations. In addition, for rigorous assurance of proper handling and management of personal information, we have formulated the following policy on its protection, which all of our employees shall observe.

1) When obtaining personal information, we shall indicate the purpose of its use and obtain it through both legal and appropriate means.
2) We shall use personal information only within the scope of the indicated purpose, and shall take measures to prevent its use for other purposes.
3) We shall not provide personal information to any third party without the permission of the person in question.
4) In managing personal information, we shall take measures required for safe management to prevent leakage, loss, damage, tampering, etc.
5) We shall determine in-house rules for observance of laws related to protection of personal information. We shall also make reviews of observance on a continuous basis and strive to ensure observance.
6) We shall prepare a system for response to complaints and consultation regarding protection of personal information, and shall properly respond to any such inquiries.

The term "personal information" refers to information about service users (hereinafter referred to as "individual/s") that enables their identification, such as name, address, telephone number, email address, and SNS account data. Information that is not sufficient for identification of individuals by itself also constitutes personal information if it enables identification when used in combination with other information.

The purpose of personal information use shall be as determined in the following items.

- To confirm individual identity, address & contact information, and car information as needed for service provision
- To confirm the actuality, accuracy, etc. of the personal information obtained
- To make contact and provide notifications and information necessary for service provision
- To settle accounts, deliver and receive cars, and send products, bills, etc.
- To respond to comments, inquiries, complaints, etc.
- To distribute/send information for service provision, email magazines, direct mail, and other types of notifications etc.
- To send presents, rewards, etc.
- To distribute URL information to senders of blank emails

- To obtain information on individuals needed for hiring activities
- To make contact and provide notifications and information necessary for hiring activities

We may request the supply of personal information, addresses, and other information items for persons other than the individual, for the purpose of service provision. We shall use the information received only for the purpose of service provision and properly manage it as personal information.

As a general rule, we shall not provide personal information to any third party without the permission of the individual. If we intend to provide personal information to a third party, we shall indicate the provision purpose, receiving party, and information content and scope of provision, and provide the information only if the individual permits it.
However, in any of the following cases, we may provide personal information to a third party without the permission of the individual.

1) If we are requested to disclose personal information by a court, public prosecutors office, police, or institution with an authority corresponding to these.
2) If the individual clearly gives permission for disclosure of personal information in advance, in use of our services
3) If it is necessary in order to resolve conflict or dispute arising between the individual and TOPRANK in connection with service provision or other matters
4) If the disclosure or provision is permitted by laws, regulations, etc.

Within the scope required for achievement of the purpose of use, we may consign operations handling personal information, in part or in whole, to an external party. TOPRANK shall assume the responsibility for the handling of personal information at the consignee.

We may compile statistical data that is based on personal information but processed in a way that does not enable specification of individuals. We shall be able to use statistical data not enabling specification of individuals without any limitations.

As a general rule, the individual alone may seek the disclosure, correction, addition, use cessation, and deletion of personal information obtained by TOPRANK. If you desire the revision or disclosure of personal information, please contact the office in charge of personal information management noted below. However, we may not accept requests for disclosure or revision in any of the following cases. In addition, subsequent to the deletion of personal information, we shall not bear any responsibility for inability to provide services or to make notifications concerning service provision.

1) If there is a risk of harm to the life, limb, assets, or any other rights etc. of the individual or a third party
2) If there is a risk of significant hindrance to service provision
3) If disclosure would violate laws, regulations, etc.
4) If it cannot be confirmed that the request is from the individual

We shall strive to assure accuracy in our handling of personal information after obtaining it. However, the individual shall bear responsibility for ensuring that the personal information is both accurate and the latest information when it is supplied by the individual to TOPRANK.

Revised November 1, 2020