BANYAN TREE

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.

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.

• 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.

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

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 servicesa

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

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
   4. Request 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.
3. The exercise of rights under paragraph (1) may be carried out through an agent, such as a legal representative of the information subject or a delegated person. In this case, you must submit a power of attorney in attached Form 11 of the Enforcement Rules of the Personal Information Protection Act.
4. Requests for personal information access and suspension of processing may be restricted to the right of the information subject pursuant to Articles 35 (5) and 37 (2) of the Personal Information Protection Act.
5. A request for correction or deletion of personal information shall not be requested if the personal information is specified as the subject of collection in other statutes.
6. Banyan Tree Seoul confirms that the person who made the request, such as a request for perusal, correction or deletion, or a request for suspension of processing, is the person who made the request or a legitimate agent.v

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.

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. Administrative measure
   1. In order to protect personal information, we minimize the authorization of personal information processors.
   2. Regular training is provided to raise awareness of privacy.
   3. We regularly conduct self-inspection to ensure the stability of personal information processing.
2. Technical measures
   1. We establish and manage internal management plans for safe handling and management of personal information.
   2. The personal information and password of the information subject are stored and managed by encryption, and the information subject is safely managed using a separate security function.
   3. In order to prevent personal information leakage or damage caused by hacking or computer viruses, security programs are installed, and systems are installed in areas where access from outside is controlled through regular updates and inspections, and systems are monitored and blocked technically and physically.In order to prevent personal information leakage or damage caused by hacking or computer viruses, security programs are installed, and systems are installed in areas where access from outside is controlled through regular updates and inspections, and systems are monitored and blocked technically and physically.
   4. We take necessary measures to control access to personal information through granting, changing, and revoking access to the database system that processes personal information, and using the intrusion prevention system, we control unauthorized access from outside.
3. Physical measure
   1. Documents including personal information, auxiliary storage media, etc. are stored in a safe place with a lock.
   2. We have a separate physical storage area for personal information and establish and operate access control procedures.v
   3. In preparation for disasters such as natural disasters and disasters, we prepare and inspect procedures such as crisis response manuals.

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.

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
   Jingyu Baek	Management	Director of HR & Finance	+82-2-2250-8031	Jingyu.baek@hyundai-hotel.co.kr

2. 2. Personal information Department

   Name	Department	Position	Phone	Email
   Jingyu Baek	Management	Director of HR & Finance	+82-2-2250-8031	Jingyu.baek@hyundai-hotel.co.kr
   Sanggyun Jeon	Club Team	Head of Department	+82-2-2250-8281	Sanggyun.Jon@hyndai-hotel.co.kr
   Jungyu Song	Business Management	Head of Department	+82-2-2250-8223	Jungyu.Song@hyndai-hotel.co.kr
   Joonyong Park	Sales & Marketing	Head of Department	+82-2-2250-8050	younggil.hong@hyundaimovex.com
   Younggil Hong	Business Management	Manager	+82-2-2250-8032	ICTMgr-Seoul@banyantree.com

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

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. 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. 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. 3. Cyber Criminal Investigation Team of Supreme Prosecutors Office
   • Phone: 02-3480-3573
   • Website: www.spo.go.kr
4. 4. Cyber Terror Response Center of National Police Agency
   • Phone: (without area code) 182
   • Website: http://cyberbureau.police.go.kr

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

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.

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