1. Definition

In this Privacy Policy, the following terms shall have the following meanings

1. Foreign country” shall mean a foreign country as defined in Article 28, Paragraph 1 of the Act on the Protection of Personal Information (hereinafter referred to as the “Personal Information Protection Act”). Defined in Article 28, Paragraph 1 of the Act on the Protection of Personal Information (hereinafter referred to as the “Personal Information Protection Act”).
2. Personal Information” shall mean personal information as defined in Article 2.1 of the Personal Information Protection Law.
3. Personal Data” shall mean personal data as defined in Article 16.3 of the Personal Data Protection Law.
4. Third Party Provision Record” shall mean the Third Party Provision Record as defined in Article 33, Paragraph 5 of the Personal Information Protection Law.
5. Retained Personal Data” shall mean retained personal data as defined in Article 16, Paragraph 4 of the Personal Information Protection Law.
6. The “principal” shall mean the person as defined in Article 2.4 of the Personal Information Protection Law.
7. The “principal” shall mean the person as defined in Article 2.4 of the Personal Information Protection Law.

2. Purpose of use of personal information

Unless otherwise permitted by law, we will use personal information only for the following purposes or within the scope of the purposes of use separately notified or announced.

1. Personal information obtained in connection with our services
   • Personal information obtained through platforms provided by the Company
     •  For administrative communication
     • To provide services operated by the Company (hereinafter referred to as the “Company’s Services”) (hereinafter referred to as the “Company’s Services”)
     • To provide information to businesses or companies that have partnered with the Company
     • To operate and manage seminars and various events operated by the Company
     • To distribute e-mail newsletters and other information regarding our services
     • To request or contact you for surveys, campaigns, etc.
     •  To respond to inquiries and questions from users of our services
     • To provide information on services and seminars offered by the Company
     • To perform maintenance and servicing of services provided by the Company
     • For other purposes incidental to the above
   • Personal information obtained by means other than the platform
     • For administrative communication
     • To provide our services
     • To provide information to businesses or companies that have partnered with the Company
     • To operate and manage seminars and various events operated by the Company
     • To distribute e-mail newsletters and other information regarding our services
     • To request or contact you for surveys, campaigns, etc.
     • To respond to inquiries and questions from users of our services
     • To provide information on services and seminars offered by the Company
     • For other purposes incidental to the above
2. Our provision of information (including invitations to such opportunities) Information obtained in connection with
   • To operate and manage seminars and various events operated by the Company
   • To distribute e-mail newsletters and other information regarding our services
   • To request or contact you for surveys, campaigns, etc.
   • To respond to inquiries and questions from users
   • To provide information on services and seminars offered by the Company
3.  Information obtained in connection with our recruitment activities for employees or trainees
   • To provide information on recruitment or to receive applications or inquiries
   • To provide ongoing communication and information about the Company to applicants or job offers
   • For personnel management and training after employment decisions are made
   • For other purposes incidental to recruitment activities
4. Information obtained in connection with our shareholders
   • To continuously communicate with shareholders and provide information about the Company as required by law
   •  For stock management
   • For other purposes incidental to the above

3. Change of purpose of use of personal information

We may change the purpose of use of personal information to the extent that it is reasonably deemed to be relevant, and we will notify the individual or publicly announce any changes.

4. Restrictions on the use of personal information

We will not handle personal information beyond the scope necessary to achieve the purposes of use stipulated in each clause of Article 2 without obtaining the consent of the individual, except as permitted under the Personal Information Protection Law or other laws and regulations. However, this does not apply to cases falling under Article 18, Paragraph 3 of the Personal Information Protection Law.

5. Appropriate acquisition of personal information

1. We shall specify the purpose for which personal information is to be used, obtain personal information to the extent necessary and in an appropriate manner, and shall not acquire personal information through deception or other wrongful means.
2. When we receive personal information from a third party, we will confirm the following items in accordance with the rules of the Personal Information Protection Committee. However, this excludes cases in which the provision of personal information falls under any of the items of Article 27, Paragraph 1 or Paragraph 5 of the Personal Information Protection Law and is not considered to constitute provision to a third party.
   • The name and address of said third party, and in the case of a juridical person, the name of its representative (in the case of an unincorporated association with a designated representative or administrator, the name of its representative or administrator)
   • History of acquisition of said personal information by said third party

6. Secure Management of Personal Information

We will exercise necessary and appropriate supervision over our employees to ensure that personal information is managed safely against risks such as loss, destruction, falsification, and leakage of personal information. In addition, when we outsource all or part of the handling of personal information, we will provide necessary and appropriate supervision to ensure that the outsourced company manages the personal information safely.

7. Provision to third parties

1. We will not provide personal information to third parties without obtaining the prior consent of the individual, except in cases falling under any of the items of Article 27, Paragraph 1 of the Personal Information Protection Law.
2. Notwithstanding the provisions of the preceding paragraph, we will not disclose personal information to any third party (excluding those who have established a system that conforms to the standards designated by the Rules of the Personal Information Protection Commission under Article 28, Paragraph 1 of the Personal Information Protection Act) located in a foreign country (excluding countries designated by the Rules of the Personal Information Protection Commission under Article 28, Paragraph 1 of the Act). (excluding those who have established a system that conforms to the standards designated by the Rules of the Personal Information Protection Commission pursuant to Article 28, Paragraph 1 of the Personal Information Protection Law). When providing personal information to a third party (excluding those who have established a system that conforms to the standards specified in the Personal Information Protection Commission Regulations under Article 28, Paragraph 1 of the Personal Information Protection Law), except in cases falling under any of the items of Article 27, Paragraph 1 of the Personal Information Protection Law, the Company shall obtain the prior consent of the individual to the effect that the information may be provided to the foreign third party.
3. When we provide personal information to a third party, we will create and preserve a record of the provision of the information to the third party in accordance with Article 29 of the Personal Information Protection Law.
4. When receiving personal information from a third party, the Company shall perform the necessary confirmation in accordance with Article 30 of the Personal Information Protection Law, and shall create and store a record of such confirmation (hereinafter referred to as “record of receipt of provision to a third party”). The Company shall create and preserve a record of such confirmation (“Record of Receipt of Provision to Third Party”) in accordance with Article 30 of the Act.

8. Requests regarding retained personal data, etc.

If we are requested by an individual to respond to any of the following matters concerning retained personal data in accordance with the provisions of the Personal Information Protection Law, we will respond to the individual without delay after confirming that the request is made by the individual himself/herself. However, this does not apply to cases in which we are under no obligation to respond due to the Personal Information Protection Law or other laws and regulations.

1. Purpose of use of all retained personal data
2. Procedures for responding to a request for notification of the purpose of use of retained personal data that identifies the requesting individual (details are set forth in Article 9).
3. Procedures for responding to a request for disclosure of retained personal data that identifies the requesting individual (details are set forth in Article 10).
4. Procedures for responding to requests for disclosure of records of provision to third parties and records of receipt of provision to third parties pertaining to retained personal data that identifies the individual making the request (5) Procedures for responding to requests for correction, addition, or deletion of retained personal data that identifies the individual making the request (hereinafter referred to as “correction, etc.”) (6) Procedures for responding to requests for correction, addition, or deletion (hereinafter referred to as “Correction, etc.”) of retained personal data that identifies the requesting individual (details are set forth in Article 11)
5. Suspension of use or deletion of retained personal data that identifies the individual making the request (hereinafter referred to as “Suspension of Use, etc.”) Procedures for responding to the request (details are set forth in Article 12)
6. Procedures for responding to a request regarding the cessation of provision to a third party of retained personal data that identifies the requesting individual (hereinafter referred to as “cessation of provision”) (details are set forth in Article 12). Procedures for responding to requests regarding the provision of retained personal data that identifies the individual making the request (details are set forth in Article 12).
7. (2) If a fee for the procedure set forth in item (ii) or (iii) of this paragraph is specified, such fee
8. Measures taken for the safe management of personal data in accordance with Article 23 of the Personal Information Protection Law

9. Notification of Purpose of Use of Retained Personal Data

1. When we receive a request from an individual to notify the purpose of use of retained personal data in accordance with the provisions of the Personal Information Protection Law, we will notify the individual without delay after confirming that the request is made by the individual himself/herself. However, this does not apply to cases in which we are not obligated to notify the individual in accordance with the Personal Information Protection Law or other laws and regulations.
2. If we decide not to notify the purpose of use of retained personal data requested in accordance with Paragraph 1, we will notify the individual to that effect without delay.

10. Disclosure of Retained Personal Data, etc.

1. When we receive a request for disclosure of retained personal data or records of provision to a third party from an individual in accordance with the provisions of the Personal Information Protection Law, we will, after confirming that the request is made by the individual himself/herself, disclose the information to the individual without delay by the method requested by the individual (or, if disclosure by such a method would require a large amount of money or be difficult to accomplish by other means, by delivery of documents). If the disclosure by such a method requires a large amount of money or is difficult, the Company will disclose the information to the person in writing) without delay. However, this shall not apply in cases where the Company is not obligated to disclose the information under the Personal Information Protection Law or other laws and regulations.
2. When we have decided not to disclose all or part of the retained personal data requested in accordance with Paragraph 1, or when such retained personal data does not exist, or when it is difficult to disclose such data in the manner requested by the individual, we will notify the individual to that effect without delay.

11. Correction, etc. of Retained Personal Data

1. In the event that the Company receives a request from an individual for correction, etc. of the content of retained personal data on the grounds that such data is untrue, in accordance with the provisions of the Personal Information Protection Law, the Company will, after confirming that the request is made by the individual himself/herself, conduct the necessary investigation without delay to the extent necessary to achieve the purpose of use and, based on the results of the investigation, correct, etc. the content of the retained personal data, and notify the individual to that effect, Based on the results, we will correct the content of the retained personal data and notify the individual to that effect. However, this shall not apply to cases in which we are not obligated to make such corrections, etc. under the Personal Information Protection Law or other laws and regulations.
2. If we decide not to correct the retained personal data requested in Paragraph 1, or if the retained personal data in question does not exist, we will notify the individual to that effect without delay.

12. Suspension of Use of Retained Personal Data, etc.

1. In the event that the Company receives a request from the person in question to cease the use of his/her retained personal data in accordance with the provisions of the Personal Information Protection Law on the grounds that such data has been obtained in violation of Article 18 or 19 of the Personal Information Protection Law or Article 20 of the Personal Information Protection Law, or on the grounds that the retained personal data (hereinafter referred to as “Suspension of Provision”) in accordance with the provisions of the Personal Information Protection Law on the grounds that the Retained Personal Data has been provided to a third party in violation of Article 27, Paragraph 1 or Article 28 of the Personal Information Protection Law. In such cases, if it is found that there is a reason for the request, we will, without delay, upon confirming that the request is made by the individual himself/herself, suspend the use or provision of the retained personal data, and notify the individual of such suspension or provision. However, this shall not apply in cases where the Company is not obligated to suspend the use or provision of the retained personal data under the Personal Information Protection Law or other laws and regulations. If we decide not to discontinue the use or provision of personal information, we will notify the individual to that effect without delay.
2. In the event that we are requested by an individual to cease use, etc. or cease provision of his/her retained personal data in accordance with the provisions of the Personal Information Protection Law for the reason that we no longer need to use his/her retained personal data, for the reason that a situation prescribed in the main clause of Article 26, Paragraph 1 of the Personal Information Protection Law concerning retained personal data in which the individual is identified has occurred, or for other reasons that the rights or legitimate interests of the individual are likely to be impaired by handling retained personal data in which the individual is identified. In the event that a request is made pursuant to the provisions of the Personal Information Protection Law to cease the use or cease the provision of retained personal data that identifies the Individual Concerned, and it is found that there is a reason for such request, the Personal Information Protection Council will, after confirming that the request is made by the Individual Concerned, cease the use or provision of the retained personal data without delay to the extent necessary to prevent the infringement of the rights and interests of the Individual Concerned. If the Company finds out that there is a reason for such a request, the Company will, without delay, suspend use, etc. or suspend provision of the retained personal data and notify the person to that effect. However, this shall not apply in cases where the Company is not obligated to suspend the use or provision of the retained personal data under the Personal Information Protection Law or other laws and regulations. If we decide not to discontinue the use or provision of personal information, we will notify the individual to that effect without delay.

13. Contact us

Please contact the following for notification, disclosure, correction, etc., suspension of use, etc., suspension of provision, other requests, opinions, questions, complaints, and other inquiries regarding the handling of personal information.

WellBear Inc.

E-mail：info@wellbearma.com

14. Continuous Improvement

We will comply with the Personal Information Protection Law, other related laws, guidelines, and this Privacy Policy in the acquisition, use, and other handling of personal information. We will also review the status of our operations regarding the handling of personal information from time to time and strive for continuous improvement, and may change this Privacy Policy as necessary.