ARCHES. PTE.LTD (the “Company”) shall use confidential information of the customer based on this policy.

1.Information received by the Company

Information received by the Company to achieve the specified purpose in 【4. Purpose of using the received information】 includes the information below (Section (1) and (2) below, hereinafter collectively referred to as “Received information”).
(1) Information received by Company from the customer
Personal information is information of individuals defined in Article 3, Clause 15 of Law on Cyber-information Security, and especially the information below shall be considered as personal information.
① Address, name, date of birth, gender, occupation and other information that can distinguish specific individuals.
② Address, phone number, account information (email address and password, etc.) which are used for connection with specific personal information.
③ Bank account information and credit card information.
④ Hobbies, family structure, age associated with personal information and other attribute information related to individuals.
⑤ Information related to customer self-certification.
(2) Information received by the Company related to the customer’s use of this service
The Company receives the following information regarding the use of the service, regardless of whether or not this information belongs to personal information.
① Information related to the use and review of this service by the customer (which includes information related to usage situation such as cookie information and access logs; terminal information, location information, and customer communication related information including IP address, browser information and browser language) as well as the service content used by the customer, the date and time, number of turns, and the customers’ behavior when using this service.
② Information related to the settlement situation through the use of this service by the customer.

2.Information collection methodology

The Company collects the information received by the customer using this service in the following ways.
① Ask the customer to fill in information directly on this service.
② Ask the customer to provide information to the Company via email, post office, text, phone, etc. (When reciprocating through phone with the customer, the Company records the conversation to improve the reciprocal quality).
③ Collect information when the customer uses and browses this service.

3.Management of received information

At the Company, the person in charge of managing and using the received information shall strictly manage the information received by the customer, paying close attention to the processing of the Received information and performing such operation so that there is no case of unauthorized access to personal information, loss, leak or tampering of information.

4.Purpose of use of received information

The Company uses the received information for the purpose of use, the purpose of its intended use defined in the terms of use, and the following purposes that notify the customer when obtaining and collecting such information.
(1) To provide services of the Company. This purpose also includes providing corporate information (hidden names and contact information) to the customer who wants to use our services to set up customer matching.
(2) Guide and provide different types of products and services, including products and services of the Company and partner companies; and manage the contract maintenance.
(3) Provide information, manage operation for the Company’s businesses, and diversify products and services.
(4) Make contact and provide information about items related to this service.
(5) Simplify the entry of necessary information when registering users for this service.
(6) Send confirmation and send email to register for e-mail delivery service.
(7) Survey and analyze the situation of using this service.
(8) Innovate and improve customer satisfaction with the content of this service or develop new services.
(9) Customize this service content to suit the customer.
(10) Investigate the level of satisfaction with this service.
(11) Gather information after statistically processing the received information and publicize that information as a survey result.
(12) Send instructions or announcements about this service, new services and other types of services.
(13) Request a joint investigation, ask to participate in the event and announce the result.
(14) Submit or display Company’s or third party’s ads.
(15) Solve problems during operation of this service.

5.Provision of received information to a third party

The Company provides the received information to a third party in the following cases. In addition, in the event that the Company determines that it is necessary to provide the received information, it may provide such information after obtaining the consent of the customer.
(1) Where information is provided on this service when the Company considers it necessary to provide such service.
(2) Where the Company considers it necessary to operate and provide services.
(3) Where providing to the operation entrustor or other third party to resolve customers’ inquiries, company’s inquiries to the customer, related after-sales service, etc.
(4) Where required by the court, administrative agency, supervisory agency and other public agencies to provide the received information in accordance with the law.
(5) Where the Company considers it necessary to provide information to resolve a dispute with a third party, or to ensure the rights and interests of the customer or the third party.
(6) Where providing to the third party that the Company entrusts the survey and analysis to conduct surveys and analyze the situation of using this service.
(7) Where providing to the third party to send or display Company’s or third party’s ads.

6.Delegation to a third party for processing received information

The company may delegate all or part of the processing of received information to the authorized entrustor within the scope necessary to achieve 【4. Purpose of using received information】. In this case, the Company thoroughly verifies whether the Transferee of the operation is the person who satisfies the criteria for selecting the entrusted party as defined by the Company and ensures the received information is managed appropriately during the contract implementation.

7.Use of “Cookies”

The customer may install whether to allow Cookie use or not. In many web browsers, the use of Cookies is automatically allowed, but browser settings can also be changed to prevent the use of Cookies.
(1) When blocking Cookie use, it is not possible to use this service normally, and advertising settings that need to use Cookie may not be displayed.
(2) The Company receives the customer’s Cookie information, advertising information and websites that visitors have viewed, or the environment used by the customer from the client’s browser automatically. This is then recorded on the server to use that information in order to enhance the convenience of automatically entering the email address when logging in to this service, ensuring security for maintaining and protecting sessions, in addition to considering new services and improving advertising services or content more relevant to the customer.

8.Use of “Log” and use of “Device Information”

(1) Log
The Company collects IP addresses, browser types and browser languages which are automatically formed when users visit this service.
Later, this information will be used to analyze the user environment in order to provide better service, and prevent unauthorized behavior that prevents the provision of normal services. Furthermore, records related to search will be stored and preserved in a state that cannot be identified individually and used for the purpose of making statistical data.
(2) Device information
The Company may collect device information such as individual identification information of the terminal.
This information is used to provide better services and to prevent unauthorized acts from obstructing the provision of normal services.

9.Behavior Targeting Advertisement

(1) When providing this service or affiliate service, the Company uses the module to collect the information below, then accumulate and use this information to us or a third party as an advertising unit that advertises a target audience (an advertising method that sends advertisements tailored to the customer’s needs or interests).
① Behavioral history information (This is a kind of information that can provide an analysis of customer needs, interests, and concerns through the accumulation of this service history, but cannot be used to identify specific individuals.)
② Terminal information
③ Location information
(2) The Company will provide the information collected in the foregoing section to the Targeted Advertising Agency according to the user’s behavior (hereinafter referred to as “Advertising Media”) for the purpose of sending useful information to the customer by sending the most relevant ads that have been adjusted according to the needs, interests or concerns of the customer.
(3) The company will store behavioral history information collected from the customer in a legal time and deemed legitimate in business.
(4) When providing behavioral history information for the Advertising Communications Unit, the Company strives to establish the following measures to prevent leakage, loss or damage to the corresponding information and to manage information security.
① Do not publicize mechanisms such as encryption algorithm behavior history information, etc.
② Provide behavioral history information for the Advertising Communication Unit, provided that it is only used within the scope of use specified in Clause 2.
③ Where the Advertising Communication Unit provides behavioral information to another third party, the Advertising Communication Unit is obliged to provide the conditions attached to the preceding paragraph to that third party.

10.Correction of personal information by the Company

In the event of a change in personal information that interferes with the provision of this service or payment request such as a postal code, a financial institution name or a credit card validity period, the Company may change the registered personal information.

11.Management and privacy of personal information

The company securely stores all the collected information in the server in an environment that ordinary users cannot access, and makes effort to prevent unauthorized access, loss, destruction, tampering or leaking information.

12.Improvement and update of the Privacy Policy

The company strives to improve this Privacy Policy appropriately.
(1) The privacy policy may be changed to be compatible with changes in legislation or requirements during the business operation. The company will notify the customer in case of changes in the Privacy Policy.
(2) Before accessing this service or using the Company’s services, please confirm the latest Privacy Policy.

13.Procedures for disclosing, modifying and terminating personal information use

The customer may check and edit registered information at any time on this service.
In the case that the customer requests the Company to disclose the personal information that cannot be checked on this service, the customer may comply with the procedures that we specifically require to disclose such information, except in the following cases:
(1) If the disclosure is at risk of damaging your life, body, property or other rights and interests of the customer or a third party.
(2) If the disclosure is at risk of causing significant negative impact on the implementation of appropriate business activities of the Company.
(3) If the disclosure is illegal.
(4) If it is impossible to confirm that the request is revealed from the customer.
If the customer, after being disclosed, finds that the content of personal information held by the Company is not true, the customer may request to modify, supplement or delete personal information in accordance with procedures specified by the Company. In this case, the Company will immediately conduct a review to the extent necessary to achieve the purpose of use and rely on that result to make corrections, additions or deletions of personal information.

In addition, if the customer requests the disclosure of personal information that cannot be checked on this service, the customer may be required to pay a disclosure fee according to the procedures specified by the Company.

14.Management department and contact address

For any questions regarding this Privacy Policy, please contact the following department of the Company.
Legal Department ARCHES PTE LTD
150 Beach Road, Level 35, The Gateway West, Singapore 189720
TEL: +84-869-594-175 (9:00 to 17:00 except weekends and holidays)

Updated on 1st May 2019.

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