Private Policy

Banyan Tree Club & Spa Seoul (hereafter, “Banyan Tree Seoul”) operated by Able Hyundai Hotel & Resort Co., Ltd. has established a Personal Data Protection Policy disclosed below to protect data of information providers and swiftly and professionally manage relevant difficulties pursuant to Article 30 of the Personal Information Protection Act.
Please review this privacy policy regularly as its contents may change according to enactment(s) and/or revision(s) of the act, changes of government regulations, and internal company policies.

Privacy Statement of website contains the following.

1. Scope of personal information collected

Banyan Tree Club & Spa Seoul shall collect guests' personal information by lawful and fair means.

Personal information collected by Banyan Tree Club & Spa Seoul shall be limited to the minimum amount necessary to provide services. Sensitive personal information (e.g., race, religion, ideology, place of birth, permanent domicile, political inclination and criminal record, and health condition and sexuality) whose collection could violate a guest's basic human rights shall not be collected.

2. Purpose of collecting and using personal information

Banyan Tree Club & Spa Seoul shall collect personal information for the following purposes. Your personal information collected by the hotel is not used for other purposes unless stated in the following. When the purpose is revised or the data is used for other purposes other than originally notified, Banyan Tree Seoul will seek consent from the information provider in accordance with Article 18 of the Personal Information Protection Act.

Classification		Collection item	Purpose of use	Collection method	Retention period
Member Registration	Mandatory	Name, date of birth, sex, nationality, passport number, e-mail, phone number, cellphone number, credit card information	Confirm user's identity, guest service, complaint handling, civil complaint, communication path, room booking guarantee	Website, email, phone call, fax, member registraion card	5 years after stay
	Selective	Nationality, company name, title, address	Providing services according to demographic characteristics
	Selective	E-mail, cellphone number	Information on goods and service, provide event and promotion information
Reservation	Mandatory	Name, cellphone number	Reservation and consultation service	Website, phone call	1 year
Banquet	Mandatory	Name (company name),phone number, cellphone number, e-mail, etc,	Confirm user's identity, contact and guidance for service implementation, forward notice, communication path	Estimate, banquet agreement	3 years after event
	Selective	Address	Billing
	Selective	Credit card information	Payment of the down payment and guarantee for cancellation and postponement of the event
BTWIN Membership	Mandatory	Name, date of birth, sex, cellphone number	identification of the applicant according to the provision of membership service, communication path	Application form	Until termination
	Selective	Credit card information	Annual fee payment
	Selective	Company name, title, phone number, address, anniversary date	Utilizing statistics on service provision and membership service usage according to demographic characteristics
The Club Membership	Mandatory	Name, family name, employee's name of corporation, ID card number, nationality, occupation, address, e-mail, phone number, etc.	Judging whether the transaction relation such as the membership contract is established, identification of the applicant according to the provision of membership service, establishment, maintenance, implementation, management of membership, civil complaint	Application for admission	5 years after membership expires
	Selective	Date of birth, anniversary, marital status, family matters, vehicle number, hobby, etc.	Utilizing statistics on service provision and membership service usage according to demographic characteristics	Application for admission, phone call, e-mail
Recruitment and training program	Mandatory	Name, photo, date of birth, phone number, cellphone number, e-mail, address, academic background, work experience, foreign language ability and certicification, military service, self-introduction	Employee recruitment process, proof of eligibility, check the applicant's test score, aptitude test, medical examination	Website, e-mail, letter, recruitment website	3 years after recruitment
	Selective	family matters, national veterinary status, veterinary number, disabilities, etc.

※ Under Article 24, Clause 2 of the Personal Information Protection Act, revised and enacted on Aug 7, 2014, the collection and use of a resident registration number is limited. However, the number can be obtained and processed in specific cases when requested and permitted by law. We, therefore, would like to inform you that the hotel collects, uses and provides resident registration numbers to third parties in the process of member card issuance, in accordance with Article 28 of the enforcement regulations of the Tourism Promotion Act.
※ You may refuse to consent to collect, use and provide your information to third parties. However, please note that your refusal to provide essential information, including identification, may prevent us from providing or continuing our services.
※ You may refuse to give consent to collect and process your optional information, however, there may be some restrictions in services and conveniences provided to you.

3. Period of processing personal information

1. In cases when hotel guests or members request their personal data to be deleted, Banyan Tree Club & Spa Seoul shall take immediate action to prevent the collected data from being accessed or used.
2. At the time of termination, if applicable laws such as the Commercial Act require a longer period of keeping personal information, then Banyan Tree Club & Spa Seoul may keep transaction details and minimum basic information for the period prescribed by the law. Banyan Tree Club & Spa Seoul may also keep personal information for a longer period if notified in advance or obtained individual consent or agreement. In which case, Banyan Tree Club & Spa Seoul may only use that information for the relevant purpose. The periods of keeping personal information are as follows.
① Records on contract or offer withdrawal, etc.: 5 years
② Records on payment and supply of the Goods: 5 years
③ Records on handling of consumer's complaints or disputes: 3 years

4. Provision of personal information to a third party

1. Under no circumstances does Banyan Tree Club & Spa Seoul use or provide personal information of members to third parties or any other company/agency beyond the scope notified in the 『purpose of collecting and using personal information』, except with members' consent or under relevant laws or regulations.
2. Banyan Tree Seoul may provide personal information to third parties without prior consent from the information provider in the following cases.
① If Banyan Tree Seoul obtained prior consent from the information provider
② If specific clauses are stipulated in relevant laws, including the Protection of Communications Secrets Act, Act on Promotion of Information and Communications Network Utilization and Information Protection, Act on Real Name Financial Transactions and Confidentiality, Credit Information Use and Protection Act, Framework Act on Telecommunications, Telecommunications Business Act, Consumer Protection Act, and Criminal Procedure Act. Also in cases when there is a request from investigating authorities in accordance with the procedures and methods prescribed in the law for the purpose of investigation
③ If information of individuals is provided in an unidentifiable form for purposes of statistical reports, academic studies, or market research
3. In order to provide better quality services, personal information of the information provider may be provided to or shared with affiliates. In such cases, Banyan Tree Seoul will seek consent regarding the recipient end, purpose of use, items of provision, and period of retention and use by individually contacting guests via email, website, phone or writing. Without the consent of the information provider, the information will not be handed over to or shared with affiliates. Such provision of personal information is for Banyan Tree Seoul to provide its signature services, and therefore without consent to the provision, there may be limitations in using our services.

5. Personal information handling contractors and the service scope

Banyan Tree Club & Spa Seoul consigns personal information to the contractor as follows for the implementation of service and stipulates the matters necessary for the safe management of personal information in the consignment contract in accordance with the related statutes.
The contractors may not use the personal information outside of the purpose of contracting. To prevent illegal use of the personal information, Banyan Tree Club & Spa Seoul regularly monitors and supervises these contractors. When appointing any specialized contractor to perform some part of its job, Banyan Tree Club & Spa Seoul shall notify in advance. Personal information handling contractors are as follows

Contractors	Service Scope
Banyan Tree Hotels & Resorts Pte. Ltd	Hotel management
Troon Golf, LLC	Troon Golf management and operation
Oracle	Operation and maintenance of room and banquet reservation system
Korea Hotel Association	Membership registration
Infinity Consulting	BTWIN Membership TM and management
KICC Co. ltd	Approving and charging credit card transactions
KICA, Inc.	Personal authentication through mobile phone
Amano Korea Co. Ltd.	Checking the parking information

6. Information owner's rights and method of exercising them

1. An information-owner may at any time exercise the following rights related to personal information protection against Banyan Tree Club & Spa Seoul.
① Request viewing of personal information
② Request correction of personal information if there is any change, error, etc
③ Request deletion of personal information
④Request suspension in the processing of personal information
2. Exercise of rights under Section 1 may be made against Banyan Tree Club & Spa Seoul in writing, by email, by facsimile, etc., under Form No. 8 and No. 10 of the Personal Information Protection Act Enforcement Rule, and Banyan Tree Club & Spa Seoul shall promptly take relevant measures. If an information-owner requests that personal information error be corrected or deleted, then Banyan Tree Club & Spa Seoul may not use or provide the relevant personal information until the correction or deletion is completed.

7. Destruction procedure and method of personal information

1. The Hotels retain personal information for a set period of time and destroy it when the purpose of the collection is fulfilled in accordance with the internal policies and applicable laws. Upon expiry of retention period or fulfillment of the purpose of collection or any other cases where the retention of personal information is no longer required, the Hotels destroy personal information immediately.
2. In the event that other laws require that personal information be stored even after the retention period is expired or the purpose of collection is fulfilled, the Hotels transfer such personal information to a separate database or store it in a different place.
3. The process and method of personal information destruction are as follows.
① Disposal process: Banyan Tree Seoul will select personal information which has been designated for destruction and discard such personal information with approval of our personal information protection manager.
② Banyan Tree Seoul will destroy personal information printed on paper by shredding or incineration. For any personal information stored in an electronic file format, Banyan Tree Seoul will permanently delete such information by using technical methods that will prevent data recovery.

8. Measures to secure stability of personal information

Banyan Tree Club & Spa Seoul takes the following technical/administrative and physical measures necessary to secure stability under Article 29 of the Personal Information Protection Act.
① To protect personal information, Banyan Tree Club & Spa Seoul minimizes the authority of personal information processing personnel.
② To enhance awareness of personal information protection, Banyan Tree Club & Spa Seoul performs periodic education.
③ To secure the stability of personal information processing, Banyan Tree Club & Spa Seoul performs periodic self-checkups.
④ For safe processing and management of personal information, Banyan Tree Club & Spa Seoul has formulated and is implementing an internal control plan.
⑤ A member's personal information and password are encoded, stored, and managed. This information is safely managed by use of a separate security function, even during transmission.
⑥ To prevent personal information leakage or violation due to hacking, computer virus, etc., , Banyan Tree Club & Spa Seoul has installed a security program and conducts periodic upgrade/checkups. , Banyan Tree Club & Spa Seoul has installed a system in outside access-controlled areas through which it conducts technical and physical monitoring and blocking.
⑦ Measures necessary to control access to personal information are being taken by granting, modifying, and canceling access authority to the personal information processing database system. Unauthorized access from the outside is controlled by use of an anti-intrusion system.
⑧ Walkerhill keeps documents, auxiliary storage device, etc. containing personal information in a safe place with a locking device.
⑨ Walkerhill has a separate physical location keeping personal information and has established and is operating a control procedure for access to it.

9. Use of Cookies

1. Use of Cookies
Banyan Tree Seoul may employ cookies for user convenience, and the data collected by cookies are used in providing customized marketing by analyzing the frequency and the time of visits, and more.
2. Setting Options and Refusal of Cookies
Customers have a right to choose whether or not to allow the installation of cookies. You may change settings in your web-browser to allow all cookies, allow cookies after confirmation, or refuse all cookies. Please be aware, when you block use of cookies, you may have some limitations in services that require log-ins.

10. Chief personal information officer

To protect members' personal information and handle personal information-related complaints, Banyan Tree Club & Spa Seoul has designated a chief personal information officer. Any member with inquiries on personal information may contact the below-mentioned chief personal information officer/personal information manager, who shall speedily answer any inquiries to the best of his or her ability.

1. Chief personal information officer

Name	Department	Position	Phone	Email
Jaemin Lee	Management	Director of Finance	02-2250-8031	jaemin.lee@hyundai-hotel.co.kr

2. Personal information Department

Name	Department	Position	Phone	Email
Jaemin Lee	Management	Director of Finance	02-2250-8031	jaemin.lee@hyundai-hotel.co.kr
Minyoung Chun	Club Team	Head of Department	02-2250-8281	MinYoung.Chun@hyundai-hotel.co.kr
Minyoung Lee	Business Management	Head of Department	02-2250-8245	Minyoung.Lee@hyundai-hotel.co.kr
Sujin Oh	HR	Head of Department	02-2250-8021	Sujin.Oh@hyundai-hotel.co.kr
Joonyong Park	Sales & Marketing	Head of Department	02-2250-8050	Joonyong.Park@hyndai-hotel.co.kr
Seunghyun Park	Business Management	Digital Manager	02-2250-8049	sh.park@hyundai-hotel.co.kr

For general inquiries, please call Banyan Tree Club & Spa Seoul at +82-2-2250-8000.

11. Response to Infringement of Rights

The guests may request the settlement of dispute or consultation to the Personal Information Arbitration Committee and Personal Information Infringement Notification Center of Korea Internet Security Agency in addition to the following organizations:

1. Privacy Breach Report Center (operated by Korean Internet Security Agency)
 Responsibilities: consultation and report privacy breaches
 Website: privacy.kisa.or.kr
 Phone: (without area code) 118
 Address: Privacy Breach Report Center, 3F, 9, Jinheung-gil, Naju-si, Jeonnam, 58324
2. Personal Information Arbitration Committee
 Responsibilities: arbitration and group dispute resolution regarding personal information (civil resolution)
 Website: www.kopico.go.kr
 Phone: (without area code) 1833-6972
 Address: 4F, Government Complex Seoul, 209, Sejongdae-ro, Jongno-gu, Seoul, 03171
3. Cyber Criminal Investigation Team of Supreme Prosecutors Office
 Phone: 02-3480-3573
 Website: www.spo.go.kr
4. Cyber Terror Response Center of National Police Agency
 Phone: (without area code) 182
 Website: http://cyberbureau.police.go.kr

12. Revision History

Any addition to, deletion of, and modification to the Policy made in accordance with changes to laws, regulations, policies or security technologies will be announced on the website.
This Privacy Policy is effective from 1 November, 2018

1. Grounds and purpose of installing image information processing equipment
- Facility safety and fire prevention
- Crime prevention for customer safety
- Prevent vehicle theft and damage
* If the number of parking spaces exceeds 30, it can be installed and operated based on Article 6, Paragraph 1 of the 「Parking Law Enforcement Rules」
2. Number of installation, installation location and shooting range

Classification	Number of installation	Installation Location and Filming Range
The Hotel	92 vehicles	inside and outside of a building, corridors, elevators, parking lots, etc. on each floor
The Club	111 vehicles	inside and outside of a building, corridors, elevators, parking lots, etc. on each floor
Festa	37 vehicles	inside and outside of a building, corridors, elevators, parking lots, etc. on each floor
Other	103 vehicles	parking lots, outdoor facilities, etc

3. Management officer and access authority
In order to protect your video information and handle complaints regarding personal video information, we have a person in charge of personal video information protection as shown below.

Classification	Name	Affiliation	Position/Position	Contact Us
Management Officer	The person in charge	SangGyun Jon	Club Team	Head of Department	+82-2-2250-8281
	The deputy person in charge	Nam Hoon,Lee	Security & Valet Part	Leader of the part	+82-2-2250-8111
Access authority		Tae Ho,Kim	Security&valet part (partner)	Team leader	+82-2-2250-8112

4. Recording time, storage period, storage location and processing method of video information
- Shooting time: 24 hours
- Storage period: 40 days from the time of shooting
- Storage place and processing method: Stored in a secure room, automatically deleted after the storage period has elapsed
5. Matters concerning consignment such as installation and management of video information processing equipment
Banyan Tree Seoul entrusts the handling of video information processing devices as follows, and in accordance with relevant laws and regulations, the consignment agreement stipulates the necessary information so that personal information can be safely managed.

An entrusted company	The person in charge	Contact Us
J&L Humans Co., Ltd.	Team Leader, Kim Tae-ho	+82-2-2250-8112
The deputy person in charge	Nam Hoon,Lee	Security & Valet Part	Leader of the part	+82-2-2250-8111
Access authority		Tae Ho,Kim	Security&valet part (partner)	Team leader	+82-2-2250-8112

6. Matters concerning the method and place of checking personal video information
If you want to view or confirm the existence or deletion of personal video information, you can check it by contacting the manager in charge of Section 3 above and visiting the department in charge.
7. Measures to respond to requests for information subject, such as viewing video information
You must apply for a request to confirm the existence of personal video information, and only the personal video information required for the benefit of the information subject's imminent life, body, or property is permitted. Banyan Tree Seoul will take necessary measures without delay when requesting viewing, confirmation or deletion of personal video information.
8. Measures to secure the safety of video information
The video information processed by Banyan Tree Seoul is safely managed through encryption measures. By establishing an internal management plan, access control and access rights are restricted. In order to prevent forgery and alteration of personal video information, the date and time of creation of personal video information, the purpose of browsing at the time of browsing, and the date and time of browsing, are recorded and managed. In addition, locks are installed for safe physical storage of personal video information.

13. Change of personal information processing policy

1. When there are additions, deletions, or modifications of contents in accordance with legislation/revision, government policy changes, company internal policy changes, or security technology changes, we will notify the changes through the website without delay. The contents of this Privacy Policy may change from time to time, so please check this each time you visit the “homepage”.
This Privacy Policy applies from November 1, 2018.
2. You can check the previous privacy policy below.
① 2016. 10. 10. ~ 2018. 6. 30. apply
② 2018. 6. 31. ~ 2018. 10. 31. apply