Privacy Policy

1. Information to be collected and method of collection

(1) Personal information items to be collected

Personal information items to be collected by Keyin are as follows:

• • Information provided by the users

  Keyin may collect the information directly provided by the users.

  Information provided by the users

  Title of service	Items to be collected(examples)
  Internet membership service	- Name, email address, ID, telephone number, address, national information, encoded identification information (CI), identification information of overlapped membership (DI) - For minors, information of legal representatives (name, birth date, CI and DI of legal representatives)
  Online payment service	- Name, address, telephone number, and email address - Payment information including account number and card number - Delivery information including delivery address, name and contact information of recipient - Information of bid, purchase and sales
  Social network service	- Name, email address, ID, telephone number, address, national information, address list (acquaintance) - Information of place of taking pictures and date of creation of files - Information of service use of members such as the type of contents watched or used by members, the persons interacting or sharing contents with members, frequencies and period of activities of members

• • Information collected while the users use services

  Besides of information directly provided by the users, Keyin may collect information in the course that the users use the service provided by Keyin.

  Information collected while the users use services

  Lists	Items to be collected(examples)
  Equipment information	- Equipment identifier, operation system, hardware version, equipment set-up, type and set-up of browser, use information of website or application and telephone number
  Log information	- IP address, log data, use time, search word input by users, internet protocol address, cookie and web beacon
  Location information	- Information of device location including specific geographical location detected through GPS , Bluetooth or Wifi (limited to the region permissible under the laws)
  Other information	- Preference, advertisement environment, visited pages regarding service use of users

• • Collection through Location, Device and Application Operation
  • - Keyin uses collected information from Keyin's products to allow users (and Keyin) to operate and monitor user's devices and Keyin Services. If users enable Smart Features, the Keyin application will request user's consent in order to track user's location and to determine when user's application nears Keyin devices that users have permission to access.
  • - Information about the guests that users invite in order to allow guests to have access to user's smart lock and Services. Guests should be aware that the person(s) providing access to a specific device may be able to see information about the guest's usage of the device or Keyin's Service and may revoke or limit access rights in their discretion without notice. In connection with the guest invitation process, Keyin may ask for access to user's contact list. Keyin will only store information for contacts that users add as guests.
  • - Information associated with use of Keyin smart lock products such as device status, logs of those who lock/unlock the devices, the guests that users invite, and those people who may invite users as a guest, to use the device and application. Keyin may store this data along with user's personal data and other information about user's use of Keyin Service.
• • Guest Access
  • - As part of Keyin Services, users may give others ('guests') permission levels to access user's Keyin lock – e.g. to unlock and lock user's door (and possibly even to pass this access along to others). Needless to say, users must be careful of the guests that users invite and the access that users give them. Users are responsible for all uses of their account, so they must be careful to secure this information and only give access to people users trust. Additionally, certain portions of users personal data, device and Service information may be shared with the people that users invite, such as user's name and lock location, and the status of the lock (e.g. locked or unlocked). Keyin may also collect personal (as required to use the Service as set forth in this Privacy Policy) about the guests that users invite in order to allow them to have access to user's Keyin device and Service. All such information (including user's Service usage information) is subject to and will be used and disclosed as set forth in, this Privacy Policy. All guests must be informed and expressly consent to such use and disclosure as a user of the Service. If you are a guest and do not consent to such use, you should stop using the Service. Guests should be aware that the person(s) providing access to a specific device may be able to see information about the guest's usage of the device and Keyin Service and may revoke or limit access rights in their discretion without notice. Guests should also be aware that their personal data and usage information may be shared with third-party service providers as set forth in this Privacy Policy, including those service providers selected by the person(s) that invited you to use their lock (see 'Your Third Party Service Providers' below).

(2) Method of collection

Keyin collects the information of users in a way of the followings:

• • webpage, written form, fax, telephone calling, e-mailing, tools for collection of created information
• • provided by partner companies

2. Use of collected information

Keyin uses the collected information of users for the following purposes:

• • Member management and identification
• • To detect and deter unauthorized or fraudulent use of or abuse of the Service
• • Performance of contract, service fee payment and service fee settlement regarding provision of services demanded by the users
• • Improvement of existing services and development of new services
• • Making notice of function of company sites or applications or matters on policy change
• • To help you connect with other users you already know and, with your permission, allow other users to connect with you
• • To make statistics on member's service usage, to provide services and place advertisements based on statistical characteristics
• • To provide information on promotional events as well as opportunity to participate
• • To comply with applicable laws or legal obligation
• • Use of information with prior consent of the users (for example, utilization of marketing advertisement)

Keyin agrees that it will obtain a consent from the users, if Keyin desires to use the information other than those expressly stated in this Policy.

[Option to select 'Lawful Processing of Personal Information under GDPR' in Appendix <1> of Personal Privacy Policy]

3. Disclosure of collected information

Except for the following cases, Keyin will not disclose personal information with a 3rd party:

• • when Keyin disclosing the information with its affiliates, partners and service providers;

  - When Keyin's affiliates, partners and service providers carry out services such as bill payment, execution of orders, products delivery and dispute resolution (including disputes on payment and delivery) for and on behalf of Keyin

• • when the users consent to disclose in advance;
  • - when the user selects to be provided by the information of products and services of certain companies by sharing his or her personal information with those companies
  • - when the user selects to allow his or her personal information to be shared with the sites or platform of other companies such as social networking sites
  • - other cases where the user gives prior consent for sharing his or her personal information
• • when disclosure is required by the laws:
  • - if required to be disclosed by the laws and regulations; or
  • - if required to be disclosed by the investigative agencies for detecting crimes in accordance with the procedure and method as prescribed in the laws and regulations

4. Cookies, Beacons and Similar Technologies

Keyin may collect collective and impersonal information through 'cookies' or 'web beacons'.

Cookies are very small text files to be sent to the browser of the users by the server used for operation of the websites of Keyin and will be stored in hard-disks of the users' computer.

Web beacon is a small quantity of code which exists on the websites and e-mails. By using web beacons, we may know whether a user has interacted with certain webs or the contents of email.

These functions are used for evaluating, improving services and setting-up users' experiences so that much improved services can be provided by Keyin to the users

The items of cookies to be collected by Keyin and the purpose of such collection are as follows:

Cookies, Beacons and Similar Technologies

Category	Reasons for using cookies and additional information
strictly necessary cookies	This cookie is a kind of indispensable cookie for the users to use the functions of website of Keyin . Unless the users allow this cookie, the services such as shopping cart or electronic bill payment cannot be provided. This cookie does not collect any information which may be used for marketing or memorizing the sites visited by the users (Examples of necessary cookies) -Memorize the information entered in an order form while searching other pages during web browser session - For the page of products and check-out, memorize ordered services - Check whether login is made on website - Check whether the users are connected with correct services of the website of KeyinwhileKeyin changes the way of operating its website ∘ Connect the users with certain application or server of the services
performance cookies	This cookie collects information how the users use the website of Keyin such as the information of the pages which are visited by the users most. This data helps Keyin to optimize its website so that the users can search that website more comfortably. This cookie does not collect any information who are the users. Any and all the information collected by this cookie will be processed collectively and the anonymity will be guaranteed. (Examples of performance cookies) - Web analysis: provide statistical data on the ways of using website - Advertisement response fee: check the effect of advertisement of Keyin - Tracing affiliated companies; one of visitors of Keyin provides anonymously feedback to the affiliated companies - Management of error: measure an error which may occur so as to give a help for improving website - Design testing: test other design of the website of Company
functionality cookies	This cookie is used for memorizing the set-ups so that Keyin provides services and improves visit of users. Any information collected by this cookie do not identify the users individually. (Examples of functionality cookies) - Memorize set-ups applied such as layout, text size, basic set-up and colors - Memorize when the customer respond to a survey conducted by Keyin
targeting cookies or advertising cookies	This cookie is connected with the services provided by a 3rd party such as the buttons of 'good' and 'share'. The 3rd party provides these services by recognizing that the users visits the website of Keyin. (Examples of targeting cookies or advertising cookies) - carry out PR to the users as targets in other websites by connecting through social networks and these networks use the information of users' visit - provide the information of users' visit to ad agencies so that they can suggest an ad which may attract the interest of the users

The users have an option for cookie installation. So, they may either allow all cookies by setting option in web browser, make each cookie checked whenever it is saved, or refuses all cookies to be saved: Provided that, if the user rejects the installation of cookies, it may be difficult for that user to use the parts of services provided by Keyin.

5. User's right

The users or their legal representatives, as main agents of the information, may exercise the following rights regarding the collection, use and sharing of personal information by Keyin:

• • exercise right to access to personal information;
• • make corrections or deletion;
• • make temporary suspension of treatment of personal information; or
• • request the withdrawal of their consent provided before

If, in order to exercise the above rights, you, as an user, use the menu of 'amendment of member information of webpage or contact Keyin by sending a document or e-mails, or using telephone to Keyin(or person in charge of management of personal information or a deputy), Keyin will take measures without delay: Provided that Keyin may reject
the request of you only to the extent that there exists either proper cause as prescribed in the laws or equivalent cause.

[Option to select 'User's right when applying GDPR' in Appendix <2>of Personal Privacy Policy]

6. Security

Keyin regard the security of personal information of uses as very important. Keyin constructs the following security measures to protect the users' personal information from any unauthorized access, release, use or modification

• • Encryption of personal information
  • - Transmit users' personal information by using encrypted communication zone
  • - Store important information such as passwords after encrypting it
• • Countermeasures against hacking

  - Install a system in the zone the external access to which is controlled so as to prevent leakage or damage of users' personal information by hacking or computer virus

• • Establish and execute internal management plan
• • Install and operate access control system
• • Take measures to prevent forging or alteration of access record

7. Protection of personal information of children

In principle, Keyin does not collect any information from the children under 13 or equivalent minimum age as prescribed in the laws in relevant jurisdiction. The website, products and services of Keyin are the ones to be provided to ordinary people, in principle. The website or application of Keyin has function to do age limit so that children cannot use it and Keyin does not intentionally collect any personal information from children through that function.

(Additional procedure for collecting personal information from children) However, if Keyin collects any personal information from children under 13 or equivalent minimum age as prescribed in the laws in relevant jurisdiction for the services for unavoidable reason, Keyin will go through the additional procedure of the followings for protecting that personal information of children:• verify, to the extent that efforts are reasonably made, whether they are children of the age at which consent from their guardian is required and the consenting person is an authorized one.

• • obtain consent from the parents or guardian of children so as to collect personal information of children or directly send the information of products and services of Keyin
• • give the parents or guardian of children a notice of Company's policy of privacy protection for children including the items, purpose and sharing of personal information collected
• • grant to legal representatives of children a right to access to personal information of that children/correction or deletion of personal information/temporary suspension of treatment of personal information/ and request for withdrawal of their consent provided before
• • limit the amount of personal information exceeding those necessary for participation in online activities

8. Modification of Privacy Protection Policy

Keyin has the right to amend or modify this Policy from time to time and, in such case, Keyin will make a public notice of it through bulletin board of its website (or through individual notice such as written document, fax or e-mail) and obtain consent from the users if required by relevant laws.

9. Others

[Option to select 'data transfer to other countries ' in Appendix <3> of Personal Privacy Policy]

[Option to select 'sites and service of 3rd party' in Appendix <4> of Personal Privacy Policy]

[Option to select 'guidelines for residents in California' in Appendix <5> of Personal Privacy Policy]

[Option to select 'guidelines for residents in Korea' in Appendix <6> of Personal Privacy Policy]

10. Contact information of Company

Please use one of the following methods to contact Keyin, should you have any queries in respect to this policy or wish to update your information:

• • Company name :
• Name : Yun Hyeong Jo
• Tel. : 82-2-6952-4434
• E-mali : admin@raonark.com

(Add the following if designated of data protection officer) Keyin designates the following Data Protection Officer (DPO) in order to protect personal information of customers and deal with complaints from customers.

• • DPO of Keyin
• Name : Yun Hyeong Jo
• Tel. : 82-2-6952-4434
• E-mali : admin@raonark.com

(Add the following if the controller operating outside of the EU designates its deputy in the EU) Keyin designates a deputy in the EU in order to protect personal information of customers and deal with complaints from customers.

• • Deputy of Keyin Adress:
• Name : Yun Hyeong Jo
• Tel. : 82-2-6952-4434
• E-mali : admin@raonark.com

The latest update date: 1st August, 2021.