California Transparency in Supply Chains Act

Storyhenge is committed to making sure that working conditions throughout our supply chain are safe and that employees are treated with dignity. We require that our products comply with all applicable local and international laws, including laws related to labor, human rights, public health, and workplace safety.

Research by the International Labor Organization shows that there are nearly 21 million victims of forced labor around the world, and that women and children are particularly vulnerable to this type of abuse. This issue is not new, but legislation in California has given companies like ours an opportunity to explain how they address the risk of human rights violations in their supply chains. Our disclosure for the California Transparency in Supply Chains Act (SB657) outlines the steps we’re taking to make sure that all our direct suppliers (i.e., the manufacturers who take raw materials and turn them into Storyhenge products) meet internationally recognized labor standards and also adhere to our own Vendor Code of Conduct.

These steps include:

1. Verifying our supply chain to evaluate and address the risk of human trafficking and slavery

Our efforts to make sure that our supply chain is free of human trafficking and slavery begin with thoroughly mapping out our direct suppliers, and the secondary suppliers with whom they work. We then regularly work with independent organizations and other brands to assess the risk of forced labor throughout our supply chain (looking at various factors such as each supplier’s location and employee demographics) and tailor our efforts to prevent it accordingly.

Our primary safeguard against human trafficking is simple: We work only with manufacturing partners who share our commitment to ethical labor practices. Compliance with our Vendor Code of Conduct is a non-negotiable precondition to start and maintain any direct business relationship with us. The Code, which you can read below, outlines our requirements for the fair treatment and compensation of all workers, and expressly prohibits specific abusive labor practices. We work with the independent fair-labor monitoring group Verité to ensure that these standards are being met, and members of our own Supply Chain, Social Innovation, and Design teams regularly visit our suppliers’ factories to supplement Verité’s work.

2. Auditing our direct suppliers on a regular basis

To ensure that our vendors uphold the requirements set out in our Code of Conduct, we partner with Verité to regularly audit our direct suppliers’ facilities. These scheduled audits are an opportunity for us to strengthen our relationship with vendors throughout our supply chain and work together on preventing any substandard work conditions. We audit all of our direct suppliers’ factories at least once a year, and each audit is conducted over two or more days, depending on the size of the facility. During an audit and any follow-up visits, Verité’s independent auditors meet with the management of each facility, tour every part of the site, review any pertinent documents, and interview employees at all levels of the organization. These audits give us a clear and comprehensive picture of employees’ working conditions and allow us to hold our direct suppliers accountable to the specific labor standards outlined in our Vendor Code of Conduct.

3. Certifying that the raw materials used by our suppliers have not been produced with forced labor

Our Vendor Code of Conduct applies to all of our direct suppliers. Of course, these suppliers have their own suppliers, who provide them with the various materials and components needed to manufacture our products. As an added safeguard against the threat of human trafficking and slavery, we audit many of those suppliers as well. This allows us to know whom those suppliers employ and to ensure that they’re also being employed per the labor standards set out in our Code of Conduct.

To maintain a complete picture of our supply chain and the labor involved in it, we have a zero-tolerance policy toward unapproved subcontractors, facilities, and homework, and we do not work with vendors who are not transparent and cooperative on the matter. Every one of our direct suppliers must be able to prove that its supply chain and all the materials incorporated into our products comply with national and international laws prohibiting slavery and human trafficking. And whenever there’s a difference between the requirements of local law, international law, and our Vendor Code of Conduct, the most stringent standard always applies.

4. Holding ourselves and our suppliers accountable

Our policy against forced labor is one of zero tolerance. If one of our suppliers were found to be complicit in any form of forced labor whatsoever, we would require the supplier to address and correct the problem immediately, and we would launch an extensive investigation into the issue.

We reserve the right to terminate our business relationship with any supplier who violates these terms.

5. Training and education

To further protect the integrity of our supply chain and the safety of the people working in it, we make a concerted effort to educate our vendors, auditors, and internal teams on the realities of human trafficking and modern-day slavery. We also regularly engage with industry organizations and other companies to stay abreast of the latest developments and regulations surrounding the issue. This makes everyone involved in our supply chain better able to identify and effectively address any potential infractions.

Our Vendor Code of Conduct

Below, in full, is the Code of Conduct that we require all of our direct suppliers to comply with. Every expectation outlined in it is intended to make sure that employees are treated fairly, provided a safe work environment, and legally compensated for their work.

Vendor Code of Conduct

Storyhenge has established the general principles below, which represent our minimum expectations and serve only as a starting point for our direct suppliers to evaluate their practices and working conditions, and those of any subcontractors. Failure to do so may result in Storyhenge’s suspension of all production and the termination of any business relationship.

Child Labor

Factories will not employ anyone under the age of 15, and/or younger than the age of completing compulsory education, or under the minimum age for employment established by applicable laws in the countries of manufacture, if higher than the age of 15. Furthermore, factories of any kind will not expose anyone under the age of 18 to a working environment that is hazardous, unsafe, or unhealthy, and will provide necessary and adequate health checks and personal protection to juvenile workers as per law.

Forced Labor

Storyhenge will not conduct business with any factory that uses involuntary labor of any kind—including prison labor, indentured labor, bonded labor, or labor obtained through human trafficking or slavery. Upon commencing employment with a factory, employees shall not be required to lodge “deposits” in any forms, or personal identity documents unless it is required by law.

Discrimination

Storyhenge firmly believes people are entitled to equal opportunity in employment. Although the company recognizes cultural differences exist, Storyhenge will not pursue business relationships with factories who discriminate in employment, including hiring, salary, benefits, advancement, discipline, termination, or retirement on the basis of gender, race, religion, age, disability, sexual orientation, nationality, marital or maternity status, work or personal affiliations, political opinion, or social or ethnic origin.

Harassment and Abuse

Storyhenge expects our factories to treat every employee with respect and dignity. No employee will be subject to any physical, sexual, psychological, or verbal harassment or abuse. Factories will not use monetary fines as a disciplinary practice. Furthermore, workers must be free to voice their concerns to Storyhenge or Storyhenge-appointed staff without fear of retaliation by factory management.

Wages and Benefits

Factories shall set wages, overtime pay and legally mandated benefits and allowances in compliance with all applicable laws. Workers shall be paid at least the minimum legal wage or a wage that meets local industry standards, whichever is greater.

Working Hours/Overtime

While permitting flexibility in scheduling, we will identify local legal limits on work hours and seek factories that do not exceed them. Working time should not exceed 60 hours per week, including overtime, or legal limits set by applicable local law, whichever is lower except in emergency or unusual situations. Employees should be allowed at least one day off in every seven days.

Housing

In the event that dormitory housing and meals are provided as a part of the employment agreement, all housing and sanitation conditions must comply with the applicable laws and regulations. Each dormitory resident is to be provided a locker where he/she can store his/her personal belongings with necessary privacy. Dormitory quarters are to be segregated by gender. Sufficient toilet and washing facilities segregated by gender are to be provided.

Freedom of Association

Each factory must allow employees to associate with, form, and join employees' organizations of their choosing, bargain collectively and seek adequate representation.

Subcontracting

Each factory must receive Storyhenge’s prior written approval in each instance for use of subcontractors and ensure that all of its subcontractors comply with this Code of Conduct. Subcontractors are subject to the same oversight, inspection, and auditing as factories. Each factory must keep an account of all records concerning any violations of this Code of Conduct by its subcontractors. No homework is allowed to be assigned to employees unless agreed upon by Storyhenge.

Local Laws

It is essential that each factory abide by all local laws in all aspects of their operations. In the event that there is a conflict between any local law and this Code of Conduct, the factory must abide by whichever rules are more protective for the employees and environment.

Employee Feedback

Each factory is required to develop a process to obtain continuous employee feedback concerning the implementation of this Code of Conduct in order to cooperatively develop and document best practices. This feedback system must include a fair, transparent, and anonymous method of reporting any observed violation of this code by any employees.

Health and Safety

Storyhenge seeks factories which provide written standards for safe and healthy work environments for their workers, including adequate facilities and protections from exposure to hazardous conditions or materials. These provisions must include safe and healthy conditions for dormitories and residential facilities, and they must comply with local health and safety laws and standards.

Environment

Factories must demonstrate a regard for the environment, as well as compliance with applicable environmental laws. Further, Storyhenge actively seeks factories that demonstrate a commitment to progressive environmental practices and to preserving the earth’s resources.

Bribery

Storyhenge expects its factories to have programs, policies, and training in place to comply with its local and/or applicable international or United States anti-bribery regulations, including without limitation the Foreign Corruption Practices Act (FCPA), and to prevent payments made for the purpose of obtaining or retaining business.

Notice of Privacy Practices

Effective Date: April 30, 2024

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED, AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

Storyhenge takes the confidentiality of your health information very seriously. We are required by law to provide you with this Notice of Privacy Practices (“Notice”) and follow the terms of this Notice while it is in effect. This Notice is intended to cover Storyhenge Inc., which does business as Storyhenge, as health care provider covered by HIPAA (“Storyhenge”), and its affiliate eye practices as health care providers covered by HIPAA (“We,” “Us,” or “Our”). Although these affiliate eye practices are separate corporations from Storyhenge, We may work together to provide you with Services.

This Notice is a summary of your privacy rights, and your use of Our Services evidences your acceptance of the terms of this Notice. “Services” means any of the services Storyhenge or We offer, including eye exams, refraction testing through our Prescription Check mobile application and/or in-store service (collectively, “Prescription Check”), and the prescribing and dispensing of prescription eyeglasses. Storyhenge also operates the website olabyalo.com, an e-commerce mobile application, and other related websites and mobile applications that contain links to this Notice. In this Notice, “health information”, “protected health information”, and “PHI” refer to individually identifiable health information that We obtain from you in connection with the Services. Individual information that We receive from you which is not covered by HIPAA is covered by Our Terms of Use and Privacy Policy.

1. Our use and Disclosure of PHI

Generally, We use and disclose your PHI for the normal business activities that fall in the categories of treatment, payment, and healthcare operations, in accordance with the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). Below are a few examples of those activities (but note that not every use or disclosure that falls within each category is included!).

Treatment. Treatment includes providing, coordinating, and managing your care. We keep record of the PHI you provide to us in the course of using the Services. This record may include the results of your eye exam, information We receive in connection with your use of Prescription Check, your prescription information, the prescription products that you purchase, information related to your vision insurance plan, and other information We learn about your health or vision through our provision of the Services. We may disclose this information so that doctors, nurses, other optical dispensers, and other entities like laboratories can meet your healthcare needs.

Payment. Payment includes billing, coverage, and claims activities. We document the Services that you receive when We provide care to you so that you (or, if applicable, your vision insurance plan or another third party) can pay Us for the Services. If applicable, We may share information with your vision insurance plan about upcoming treatment or Services that require prior approval by the plan.

Healthcare Operations. We use PHI to improve the Services and train staff, and for case management, care coordination, business management, quality improvement, performance evaluation, marketing activities permitted under HIPAA, customer service activities, and other internal business purposes.

Consistent with HIPAA, We may also use or disclose your PHI to:

• Comply with requirements of federal, state, or local laws
• Assist in public health and safety activities, such as tracking diseases or medical devices
• Inform authorities in order to protect victims of abuse, neglect, or domestic violence
• Comply with federal and state health oversight activities, audits, inspections and investigations
• Respond to law enforcement officials, report crimes or emergencies, or pursuant to judicial or administrative orders, subpoenas, or other lawful process (such as lawsuits or legal actions)
• Work with coroners, medical examiners, and funeral directors of information necessary for them to fulfill their duties or as authorized by law
• Facilitate organ, eye, or tissue donation or procurement
• Conduct research or research-related purposes (following internal review protocols to balance privacy and research needs)
• Prevent or reduce a serious threat to anyone’s health or safety
• Assist in specialized government functions, such as national security, intelligence, and protective services
• Perform military and veteran activities, if you are an armed forces member or veteran
• Inform a correctional institution or in custodial situations, such as if you are an inmate
• Serve workers’ compensation purposes, such as to carriers or your employer if you are injured at work, as authorized by and as necessary to comply with relevant laws
• Tell you about health-related products and services
• Tell you about alternative treatments, therapies, health care providers, or care settings
• Conduct case management, care coordination, or related functions
• Send appointment confirmations and reminders
• Communicate with individuals, such as friends and family, who are involved in your care or involved in the payment for that care
• Communicate for notice or disaster relief purposes, included regarding decedents
• Communicate within Our organization for treatment, payment, or healthcare operations.
• Communicate with other providers, health plans, or their related entities for their treatment, payment, or healthcare operations activities
• Provide services to affiliated eye practices to assist them in providing Services to you
• Provide information to other third parties with whom We do business in order to allow those third parties to provide services to Us or on Our behalf (Don’t worry—in these situations, We require third parties to provide Us with assurances that they will safeguard your PHI.)

Any other uses or disclosures not set forth in this Notice may only be performed with your written permission. Consistent with HIPAA, We will also obtain your written permission (also called an “authorization”) before We use or disclose your PHI for purposes which require an authorization, such as for certain types of marketing or sale of PHI. You may revoke your permission, in writing, at any time. If you do so, We will no longer use or disclose your PHI for the reasons covered by your written permission, but note that We are unable to take back any disclosures We have already made with your permission, and that We are required to retain Our records of the care that We’ve provided to you.

2. Our Responsibilities with Respect to your PHI

We're required by HIPAA to:

• Maintain the privacy and security of your PHI
• Provide this Notice setting forth Our legal duties and privacy practices regarding PHI
• Abide by the terms of the version of this Notice currently in effect
• Tell you if there has been a security breach that compromises the privacy or security of your PHI

Please note that some states have laws that may require that we apply extra protections to some of your health information.

3. Your HIPAA Rights with Respect to your PHI

You have the following rights with respect to your PHI maintained by Us.

• Inspect and copy. You have the right to ask to inspect and copy certain portions of your PHI, whether electronic or in paper. We may, in certain limited circumstances, deny your request to inspect or copy your PHI. If We do so, We will inform you of the reason for the denial. We will provide a copy or a summary of your PHI, usually within 30 days of receiving your request. We may charge a reasonable fee.
• Amend. You have the right to ask Us to amend your PHI if you feel that it is incorrect or incomplete. We may, in certain limited circumstances, deny your request to amend your PHI. If We do so, we will tell you why in writing within 60 days and about your right to submit a statement of disagreement for inclusion in your records.
• Accounting of disclosures. You have the right to request a list (an accounting) of Our disclosures of your PHI made over the past six years, who We shared your PHI with, and why. This right does not apply to disclosures made for treatment, payment, or healthcare operations; disclosures made to you about your treatment; disclosures made pursuant to an authorization (disclosures you asked Us to make); and certain other disclosures. We’ll provide one accounting a year for free but will charge a reasonable cost-based fee if you ask for another one within 12 months.
• Restrictions on disclosure. You have the right to request restrictions on how We use or disclose your PHI for treatment, payment or Our operations. We’re not required to comply with such requests, and We may say “no” if it would affect your care. If you pay for a Service or health care item out of pocket in full, you can ask Us not to share that information for the purpose of payment or Our operations with your health insurer. We will say “yes” unless a law requires us to share that information, such as in certain emergency situations.
• Confidential Communication. You have the right to request that we communicate with you in a specific way, such as at a specific telephone number, or to send mail to a different address. We will say “yes” to all reasonable requests.
• Paper copy. You have the right to obtain a paper copy of this Notice at any time (even if you’re currently reading it electronically!). We will provide you with a paper copy promptly.
• Choose someone to act for you. If you have given someone medical power of attorney or if someone is your legal guardian, that person can exercise your HIPAA rights and make choices about your PHI. We will make sure the person has this authority and can act for you before We take any action.

4. Changes to this Notice

We occasionally review this Notice to make sure it complies with applicable laws and conforms to changes in Our business. We may need to update this Notice, and we reserve the right to do so at any time. If We change the terms of this Notice, the new terms will apply to all PHI that We maintain about you, including PHI that was created or received before such changes were made. We will post the new Notice on Our websites and mobile applications, and will update the “Effective Date” at the top of this page so you can tell if it has changed since your last visit. We will make the new Notice available upon request. Your continued use of the Services constitutes your acceptance of the terms of such revised Notice.

5. Complaints

If you believe that your privacy rights have been violated or that We have not followed Our obligations under HIPAA, you may file a complaint with Us and with the Secretary of Health and Human Services. We will not retaliate against you or penalize you for filing any such complaint.

To file a complaint with us, email youthdrum@storyhenge.com.

6. Contacting Storyhenge

To exercise any of your rights set forth in this Notice, or for more information about Our privacy practices, email youthdrum@storyhenge.com.

Personal Information Treatment Policies

STORYHENGE (hereinafter referred to as “Company”) very seriously takes into consideration protection of customers’ personal information, and complies with the Act Relating to Promotion of Information Communications Network and Personal Information Protection. The Company hereby notifies customers for what uses and in what ways we use the personal information provided by customers and what measures we take to protect the personal information. When the personal information treatment policies are amended, the Company will notify customers thereof through the website notifications (or individual notifications). 

■ Items of Personal Information to be Collected and Collection Methods

The Company collects the following personal information for purposes of providing membership services, including membership subscriptions, consultations, prevention of wrongful uses:

* Required items : names, IDs, passwords, e-mail addresses, addresses, mobile phone numbers, IP addresses, payment records,

* Selective items : Information required by the Company to provide customized services, eye prescription data.

■ Purpose of Collection and Use of Personal Information

The Company uses the collected personal information for the following purposes:

- Payment of costs incurred as a result of performing agreements on provisions of services or providing services, Provisions of the contents, purchases or cost payments, deliveries of goods or sending bills, etc., verifying identifications for financial transactions, and financial services

- Control of Members

To verify identifications for uses of membership services, to identify individuals, to prevent wrongful uses of bad members or unauthorized uses, to verify intents for subscriptions, to verify ages, to verify the consent of a legal representative for collecting personal information of children of not more than fourteen (14) years old, to handle civil complaints including handling grievances, to convey notifications

- Use for Marketing and Advertisements

To convey information for advertisements including events, to figure out contact frequencies, to obtain statistics on service uses by members

- Use for Making personalized product

To make customized optical frame, sunglass frame.

■ Retention and Use Period for Personal Information

- Members who are subscribing ALO Eyewear : The Company shall destroy relevant personal information in 5 business days after a customer cancel subscription when the purposes of collecting and using personal information have been fulfilled,

- Non-Members : the Company shall destroy relevant personal information in 5 business days when the purposes of collecting and using personal information have been fulfilled

However, the Company shall retain personal information for a certain period of time where it is required to do so for purposes of confirming transactions related management and rights under the provisions of relevant laws including the Commercial Code and the Act Relating to Consumer Protection in Electronic Commercial Transactions as follows: 

- Records on agreements or withdrawals of offers : five (5) years (the Act Relating to Consumer Protection in Electronic Commercial Transactions, etc.)

- Records on payments and supplies of goods : five (5) years (the Act Relating to Consumer Protection in Electronic Commercial Transactions, etc.)

- Records on complaints of consumers or dispute resolutions : three (3) years (the Act Relating to Protection of Consumers in Electronic Commercial Transactions, etc.)

- Where personal information has been collected for temporary purposes, such as questionnaires, events : at the time of completion of a particular questionnaire or event

- Records on verification of identification: six (6) months (the Act Relating to Information Communication Network Promotion and Personal Information Protection)

- Records on visits (log-ins) : three (3) months (the Communication Secret Protection Act)

■ Destruction Procedures and Methods for Personal Information

The Company in principle shall without delay destroy relevant information after the purposes of collecting or using personal information have been fulfilled. The destruction procedures and methods shall be as follows:

- Destruction Procedures

The information entered by users for use of the services is moved to a separate database after the purposes have been fulfilled (a separate document in the case of a sheet), and destroyed after the information has been saved for a certain period of time according to the information protection reasons under the internal policies or other relevant laws (for your reference, see the retention and use period for personal information).  The personal information separately moved to a database is not used for purposes other than the purpose of being preserved unless it is so required by laws.

- Destruction Methods

* The personal information printed out in sheets shall be shredded by paper shredders or destroyed by way of incineration.

* The personal information saved in an electronic file format shall be deleted with the use of technical methods in which records cannot be regenerated

■ Provisions of Personal Information to Third Parties

The Company uses the personal information of users within the scope that users have consented to the “Purpose of Collecting and Using Personal Information,” but does not use the personal information of users in excess of the scope without prior consent of users or in principle does not disclose the personal information of users to the outside; provided, however, that exceptions are made in the following cases: 

- Where users have given a prior consent thereto; or
- Where there is required under the provisions of laws or requested by investigating agencies according to the procedures and methods prescribed under the laws for investigation purposes.

■ Delegation of Handling Personal Information

In the event that the Company handles the personal information of users by delegation to ensure smooth handling of duties, it must give users a prior notice of the persons delegated to handle the personal information (hereinafter referred to as “Delegatees”) and the content of duties delegated to handle the personal information. Currently, the Company’s delegatees to handle personal information and the content of duties shall be as follows:

■ Rights of Users and Legal Representatives and the Exercise Methods

- Users and their legal representatives may at any time inquire or change their registered personal information, and also may request terminations of applications (withdrawals of consents).

- Users may read, correct personal information or withdraw by clicking on the “My account à Account information”. in order to inquire or change the personal information of users or children of no more than fourteen (14) years old, or by clicking on the “Membership withdrawal” in order to terminate their membership (withdraw their consents).

- Otherwise, if a user contacts the personal information control manager in writing, by phone or e-mail, the Company shall take measures without delay.

- Where a user has requested corrections of errors in the personal information, the Company does not use or provide the personal information until the corrections are completed. Also when the wrong personal information has been previously provided to a third party, the Company will make corrections by notifying a third party without delay.

- The Company handles the personal information terminated or deleted upon request of users or their legal representatives as specified in the “Retention and Use Period of Personal Information,” and take measures to ensure that the personal information is not read or used for any other purposes.

■ Matters on Operation of Cookies

The Company operates cookies, etc. that frequently save and find out information of users (persons who get access). Cookies are very small text files sent to your browser by the server used to operate the website, which are saved to your computer hard disk. The Company uses cookies for the following purposes. 

- The purpose of using cookies, etc.

Performing target marketing activities and providing customized services by analyzing the access frequencies or visit hours, etc. of members and nonmembers who intend to use cookies, etc., figuring out users’ preferences and interested fields and following traces, figuring out various event participations and the number of visits, etc.

You have the option to install cookies. Therefore, by selecting an option in your web browser, you may allow all cookies, pass confirmations whenever cookies are saved, or otherwise refuse the savings of all cookies.

- How to Refuse Installation of Cookies

By selecting options in your web browser, you may allow all cookies, pass through confirmations whenever cookies are saved, or otherwise refuse the savings of all cookies.

- How to Install Cookies (In case of the Internet Explorer) : Tool on the top of the web browser > Internet Option > Personal Information
- Provided, however, that if you has refused the installation of cookies, it may be difficult to provide the services.

■ Contact Information of Personal Information Control Manager and Authorized Person

The company has designated the authorized relevant department and the personal information control manager in order to protect personal information of customers and handle personal information related complaints as follows:

- You may report to the personal information control manager or the relevant department any complaints regarding all personal information protection incurred in using the Services of the Company. 

- The Company will promptly give sufficient answers as to the reports of users.

- If you need other reports or consultations for personal information infringements, please ask inquiries to the following institutions.

* Personal Information Dispute Mediation Committee (www.1336.or.kr)

* Information Protection Mark Certification Committee (www.eprivacy.or.kr / +82-2-580-0533~4)

* Internet Crime Investigation Center of Supreme Prosecutors’ office (http://icic.sppo.go.kr / +82-2-3480-3600)

* Cyber Crime Investigative Service of National Police Agency (www.ctrc.go.kr / +82-2-392-0330)

■ Duty to Notify

The current personal information treatment policies shall be applicable from [2024.07.01] before the amendment. Also the Company has made it easy to check amendments by giving the version numbers and the date of amendment to the personal information treatment policies.

These policies shall be implemented from [2024.07.01].

Terms and Conditions for Service Use for [ALO Eyewear]

Article 1 (Purpose)

The purpose of these Terms and Conditions is with respect to the use of the Internet related services (hereinafter referred to as “Services”) provided by the cyber shopping mall [ALO Eyewear] (hereinafter referred to as “Mall”) operated by [STORYHENGE] (hereinafter referred to as “Company”), to set forth the rights, obligations, and duties between the Company and users.

Article 2 (Definitions)

① “Mall” shall refer to a virtual business place established in order for users to make transactions for goods, etc. by using information communication facilities including computers to ensure that the Company provides users with goods or services (hereinafter referred to as “Goods, etc.”), and shall also refer to an enterpriser who operates a cyber mall.

② “Users” shall refer to members and non-members who get access to the “Mall” and receive the Services provided by the “Mall” under these Terms and Conditions.

③ “Members” shall refer to persons who have provided their personal information to the Company and registered their membership for the Services, and who can be continuously provided with information of the Services and continue to use the Services provided by the Company.

Article 3 (Posting and Modification of Terms and Conditions)

① The Company shall post the content of these Terms and Conditions, the Company’s trade name, the name of its representative director, the address where its business place is located (including the address where complaints of consumers can be handled), telephone numbers, e-mail addresses, business registration numbers, the declaration number of communication sales business, the personal information manager, etc. on the start-up screen (the entire page) of the Services in order to ensure that users can easily see the information; provided, however, that the content of these Terms and Conditions may be made for users to see the content through the connected screens.

② The Company may request users of confirmation by providing a separate connection screen or pop-up screen to ensure that users can understand the important content, such as Withdrawal of Offer, Liability for Shipping, Conditions for Return, among the content set forth in these Terms and Conditions before users consent to these Terms and Conditions.

③ The Company may modify these Terms and Conditions to the extent that it does not violate relevant laws, including the Act Relating to Consumer Protection in Electronic Commercial Transactions, the Act Relating to Regulation of Contractual Terms and Conditions, the Electronic Transaction Basic Act, the Electronic Signature Act, the Act Relating to Information Protection for Information Communication Network Use Promotion, etc., the Act Relating to Door-to-Door Sales, the Consumer Protection Act.

④ In the event that the Company modifies these Terms and Conditions, it shall specify and post on the start-up screen for the Services the date of application and the reasons for modification together with the current Terms and Conditions from seven (7) days before the date of application; provided, however, that where these Terms and Conditions are modified unfavorably against the users, the content shall be notified with a prior grace period of at least no less than thirty (30) days. In this case, the Company shall specify the content before and after the modifications by clear comparison to ensure that users can easily see the content.

⑤ In the event that a user does not consent to the modified Terms and Conditions, the Company may block the use of the Services. If the user continues to use the Services, the user shall be deemed to have consented to the modifications of these Terms and Conditions.

Article 4 (Applicable Rules Other Than These Terms and Conditions)

Any matter that is not provided in these Terms and Conditions or any interpretation of this agreement shall follow the Act Relating to Consumer Protection in Electronic Commercial Transactions, the Act Relating to Regulation of Contractual Terms and Conditions, the Guidelines for Consumer Protection in Electronic Commercial Transactions set forth by the Korea Fair Trade Commission, and relevant laws or commercial practices.

Article 5 (Provisions and Changes of Services)

① The Company shall provide the following services:

1. To provide information on goods or services and enter into purchase agreements;

2. To ship the goods or services for which a purchase agreement is entered into; and

3. To provide any other services set forth by the Company.

② In the event that the qualities or technical specifications of the goods or services are changed, the Company may change the content of goods or services to be provided under an agreement to be entered into in the future. In this case, the Company shall post on the Services and notify the content of the changed goods or services, the date of provisions, etc.

③ In the event that it is unavoidable for the Company to change the content of the Services to be provided under agreements with users because of the qualities of goods, etc. or a change in technical specifications, etc., the Company shall forthwith notify users of the reasons.

④ In case of the prior Section, the Company shall compensate for damages incurred to users as a result; provided, however, that it shall not be the case where the absence of willfulness or negligence of the Company is proven.

Article 6 (Suspension of Services)

① In the event that there are reasons including the repairs, checking, exchanges, and failures of information communications equipment including computers, or stoppage of communications, etc., the Company may temporarily suspend the provisions of the Services.

② The Company shall compensate for damages incurred to users as a result of the temporary suspension of the provisions of the Services for the reasons of Section ①; provided, however, that it shall not be the case where the absence of willfulness or negligence of the Company is proven.

③ In the event that the Company has become unable to provide the Services for the reasons of conversion of business items, renunciation of businesses, or integration between companies, etc., it shall give users a notice thereof in the manner set forth in Article 3.

Article 7 (Membership Subscription)

① A user shall apply for membership subscription by giving his or her manifestation of intention to consent to these Terms and Conditions after entering the membership information according to the subscription form prescribed by the Company.

② The Company shall register users who have applied for membership subscription under Section ① unless a user falls under each of the following items:

1. In the event that a subscription applicant has ever lost his or her prior membership qualifications under Article 7 Section ③ of these Terms and Conditions (provided, however, that exceptions shall be made where three (3) years has lapsed after a user has lost his or her membership qualifications under Article 7 Section ③ and the user has obtained approval of re-subscription from the Company.);

2. In the event that there are false information, omitted information, or mistaken entries in the registered matters; or

3. In the event that a user’s membership registration is found to seriously affect the Company’s technologies.

③ An agreement for membership subscription shall be formed at the time when approval by the Company arrives at a User.

④ In the event that there is a change in the registered matters provided to the Company at the time when a Member has applied for membership or applied for a purchase agreement, the Member shall forthwith notify the Company of the change(s) by e-mail or in any other way.

Article 8 (Withdrawal from Membership and Disqualifications, etc.)

① Members may at any time request the Company of their withdrawal from membership, and the Company shall forthwith handle the withdrawals from membership.

② In the event that a Member falls under each of the following reasons, the Company may restrict or discontinue his or her membership qualifications:

1. In the event that a Member has registered false information at the time of applying for membership;

2. In the event that a Member has not paid amounts for goods, etc. purchased by use of the Services, or any other liabilities payable by the Member with respect to use of the Services;

3. In the event that a Member threatens the order of electronic commercial transactions by obstructing third parties’ uses of the Services or misappropriating the information; or

4. In the event that a Member engages in activities that are prohibited under the laws or these Terms and Conditions, or are against the public orders and good morals by using the Services; or

③ In the event that after the Company has restricted or suspended the membership qualifications for a Member, the Member repeats the same activity no less than twice or the reason is not corrected within thirty (30) days, the Company may forfeit he membership.

④ In the event that the Company has forfeited the membership qualifications, it shall cancel the membership registration. In this case, the Company shall notify the Member thereof and provide an opportunity to explain away by specifying a period of at least no less than thirty (30) days before cancellation of the membership registration.

Article 9 (Notifications for Members)

1. In the event that the Company gives a notice to users, it may do so with the e-mail addresses provided to the Company by the users.

2. In the event that the Company gives a notice to unspecified and many users, it may replace individual notifications with posting the notifications on the service bulletin board for no less than one (1) week; provided, however, that individual notifications shall be given with respect to the matters that seriously affect a Member’s own transactions.  

Article 10 (Application for Purchase)

Users shall apply for purchase of the goods, etc. in the manner prescribed in the Services. When users apply for purchases, the Company shall provide each of the following content to ensure that users can easily see the content:

1. To search and select the goods, etc.;

2. To enter names, addresses, telephone numbers, e-mail addresses (or mobile phone numbers), etc.;

3. To confirm the content related to the content of these Term and Conditions, the services for which the right to withdraw offers is restricted, payments of cost, including shipping fees, installation fees;

4. To apply for, confirm the purchase of the goods, etc., or consent to confirmation by the Company; and

5. To select a payment method and specify an agency for payment.

Article 11 (Formation of Agreement)

① The Company may not accept an application for purchase in Article 10 if it falls under each of the following items (provided, however, that the Company shall notify that where it enters into an agreement with a minor, the minor or his/her legal representative may cancel the agreement if consent by a legal representative is not obtained):

1. In the event that the registrations have false, omitted, or mistaken information; 

2. In the event that a minor purchases goods or services prohibited under the Juvenile Protection Act, such as cigarettes, alcohols; or

3. In the event that the Company’s acceptance of a purchase order is found to seriously affect the Company’s technologies.

② An agreement shall be deemed formed at the time when acceptance by the Company arrives at a user in the notification form of receipt confirmation in Article 13 Section ①.

④ The Company’s manifestation of intent to accept shall include such information as the Company’s verification of a user’s purchase application and the possibility when the goods or services may be sold, the Company’s correction or cancellation of a purchase application.

Article 12 (Payment Method)

The payment methods for the goods or services purchased through the Services shall be as described in each of the following items. The Company shall not add to the amounts for services, etc. and request fees in whatever names according to the payment methods.

1. Various payments by cards including debit cards, credit cards

2. Payments with points given by the Company, including mileages;

3. Payments with gift certificates for which the Company has entered an agreement, or with those found acceptable by the Company; and

4. Payments in any other electronic payment method such as Paypal, Wechat pay.

Article 13 (Notification of Receipt Confirmation, Change or Cancellation of Application for Purchase)

① In the event that a user applies for purchase, the Company shall give the user a notification of receipt confirmation.

② In the event that there is a discrepancy of the manifestation of intent, etc., immediately after a user has received a notification of receipt confirmation, the user may request a change or cancellation of the purchase application. In the event that there is a request by a user before shipping of the goods, etc., the Company shall without delay handle the request; provided, however, that where the user has previously made payments, the rule for withdrawal of offer in Article 16 shall apply.

Article 14 (Provisions of Goods, etc.)

① The Company shall manufacture, pack, the ordered goods, etc. or take any other necessary measures to ensure that the goods, etc. can be shipped within seven (7) days from the date when a user has given his or her offer unless there is a separate agreement otherwise between the Company and the user as to the time for supply of the goods, etc.  In this case, the Company shall take appropriate measures to ensure that the user can verify the supply procedures for the goods, etc. and the progresses.

② The Company shall specify the shipping means, payers of shipping costs by means, the shipping period by means, etc. with respect to the goods purchased by users.  In the event that the Company has exceeded the agreed shipping period, it shall compensate for damages incurred to users as a result; provided, however, that it shall not be the case where the absence of willfulness or negligence of the Company is proven.

Article 15 (Refund)

In the event that the Company is unable to provide the goods, etc. requested by a user for purchase because the goods, etc. are sold out, it shall without delay notify the user of the reasons. In the event that the Company has received payments for the goods, etc., it shall refund the payments or take measures for refund within two (2) business days from the date when it has previously received the payments.

Article 16 (Withdrawal of Offers, etc.)

① A user who has entered into an agreement for purchase of goods, etc. with the Company may withdraw his or her offer within (24) hours from the time when he or she has received a notice of receipt confirmation,

② A user may not return or exchange the goods, etc. where the user has received the goods, etc. purchased through the Services but falls under each of the following items:

1. In the event that the goods, etc. has been lost or damaged because of the reasons attributable to the user (provided, however, that the user may withdraw his or her offer where the packing, etc. has been damaged to verify the content of the goods, etc.);

2. In the event that the Company already customized goods, etc. according to the user’s request or data and the goods, etc. can’t be returned to the original condition

3. In the event that the value of the goods, etc. has seriously decreased because of the use or partial consumption by the user;

4. In the event that the value of the goods, etc. has seriously decreased to the extent that it is difficult to resell the goods, etc. because of the lapse of time; or

5. In the event that where the goods, etc. may be duplicated with goods, etc. of the same functionality, the packing of the original goods, etc. has been damaged.

③ In case of Section ② No. 3 or Section ④, if the Company fails to take measures to specify in advance the restrictions on withdrawal of offer, etc. at a place easily seen by consumers or provide sample images of goods, the user’s withdrawal of offer, etc. shall not be restricted.

④ Notwithstanding the provisions of Sections ① and ②, in the event that the content of the goods, etc. is different from the labeled or advertised content or has been performed differently from the agreements, a user may withdraw his or her offer within three (3) months from the date when the user has been provided with the goods, etc. or within thirty (30) days from the date when the user has known or should have known the fact.

Article 17 (Consequences of Withdrawal of Offer, etc.)

① In the event that a user has returned the goods, etc. to the Company, the Company shall refund the payments for the goods, etc. previously provided within three (3) business days.

② In this case, when the Company has delayed in refunding to the user payments for the goods, etc., it shall pay an interest for delay calculated by multiplying the period of delay by the interest rate for delay prescribed and publicly announced by the Korea Fair Trade Commission.

③ In the event that a user has made payments for the goods, etc. by payment means of credit cards or electronic currencies, when the Company refunds the payments, it shall without delay request an enterpriser who has provided the payment means to suspend or cancel the request of payments for the goods, etc.

④ In case of withdrawal of offer, etc., costs required to return the goods, etc. provided shall be borne by users. The Company shall not request users of penalties for violations or compensation for damages because of their withdrawal of offer, etc.; provided, however, that where a user withdraws his or her offer as the content of the goods, etc. is different from the labeled or advertised content or has been performed differently from the agreements, costs required to return the goods, etc. shall be borne by the Company.

⑤ In the event that a user has paid shipping costs when the user has received the goods, etc., the Company shall clearly specify who should pay the costs in a way easily understandable by users at the time of the user’s withdrawal of offer.

Article 18 (Protection of Personal Information)

① The Company shall collect the minimum information required to perform a purchase agreement in collecting information of users. The following information shall be required items, and other information shall be selective items:

1. Names

2. IDs

3. Passwords

4. E-mail addresses

5. Addresses

6. Mobile phone numbers

7. IP Addresses

8. Payment records.

② The Company must obtain consent of the users when collecting the personal information with which users can be personally identified.

③ The personal information provided by a user shall not be used for purposes other than the purpose of the provisions or provided to third parties without consent of the user; provided, however, that exceptions shall be made in the following events:

1. In the event that the Company notifies a shipping company of the minimum information of users (names, addresses, telephone numbers) required to ship the goods or services for shipping businesses;

2. In the event that the Company provides information in a way that specific individuals cannot be identified, as required to prepare statistics, do academic research works, or investigate markets;

3. In the event that it is necessary to make payments for transactions of goods, etc.;

4. In the event that it is necessary to identify oneself to prevent information from being misappropriated; or

5. In the event that there is an unavoidable reason required under the provisions of laws or the laws.

④ In the event that the Company is required to obtain consent from a user pursuant to Section ② or ③, it shall specify or notify in advance the matters set forth in Article 22 Section ② of the Act Relating to Information Communication Network Use Promotion and Information Protection, including the identity of personal information manager (name, telephone number, or other contract information), the purpose of collecting or using information, matters related to provisions of information to third parties (persons provided with information, the purpose of provisions, the content of information to be provided), the consent to which may be withdrawn at any time by users.

⑤ Users may at any time request reading or correction of their personal information that the Company has, as to which the Company shall have the obligation to take necessary measures without delay. In the event that a user has requested corrections of errors, the Company shall not use the personal information until it corrects the errors.

⑥ The Company shall keep the number of personal information manager to a minimum in order to protect personal information. The Company shall take all responsibilities for damages incurred to users as a result of users’ losing, being stolen of, disclosing, or altering their personal information including credit cards, bank accounts.

⑦ A third party that has received the Services or the personal information from the Services shall without delay destroy the personal information when the purpose of its collecting or being provided with the personal information has been fulfilled. 

Article 19 (Duties of Company)

① The Company shall not engage in any activity that is prohibited under the laws or these Terms and Conditions or against the public orders and good morals, and shall use its best efforts to provide the goods or services continuously and securely as set forth under these Terms and Conditions.

② The Company shall have a security system for personal information protection for users (including credit information) to ensure that users can safely use the Services.

③ In the event that the Company has caused damages to users by its engaging in unreasonable labeling or advertising activities prescribed in Article 3 of the Fair Labeling and Advertisement Act with respect to its goods or services, it shall compensate for the damages.

④ The Company shall not send advertising e-mails for profitable purposes unwanted by users.

Article 20 (Duties of Members for IDs and Passwords)

① Members shall have the obligation to have IDs and passwords under control from third parties except for the case of Article 18.

② Members shall not cause a third party to use their own IDs or passwords.

③ In the event that a Member has been aware that his or her ID or password has been stolen or is being used by a third party, the Member shall forthwith notify the Company thereof, and follow the directions of the Company, if any.

Article 21 (Duties of Users) Users shall not engage in the following activities:

1. To register false information at the time of applying for or changing the content of membership;

2. To misappropriate third parties’ information;

3. To change information posted in the Services;

4. To transmit or post information other than the information set forth by the Services (including computer software);

5. To infringe upon intellectual properties, including the Services, any other third party’s copyrights;

6. To undermine the reputation of or obstruct businesses of the Services or third parties; or

7. To disclose or post on the Services obscene or violent messages, videos, voices, and any other information that is against the public orders and good morals.

Article 22 (The Relationship between Connecting “Mall” and Connected “Mall”)

① In the event that the upper “Mall” and the lower “Mall” are connected by hyperlink, etc. (e.g., the subject for hyperlinks shall include letters, photos, or video pictures), the former shall be referred to as the connecting “Mall” (Website) whereas the latter shall be referred to as the connected “Mall” (Website).

② Where the fact that the Company shall not be responsible for providing guarantees for transactions made with users by the goods or services independently provided by the connecting “Mall” and the connected “Mall,” is specified on the start-up screen of the connecting “Mall” or the pop-up screen at the time of being connected, it shall not be responsible for providing guarantees for the transactions.

Article 23 (Reversion of Copyrights, Use Restrictions)

① The copyrights and other intellectual property rights to the works prepared by the Company shall revert to the Company.

② Without the prior permission of the Company, users shall not duplicate, transmit, publish, distribute, broadcast, use by other means for profitable purposes, or cause a third party to use any information acquired in using the Services..

③ In the event that the Company uses any copyright reverted to a user under these Terms and Conditions, it shall notify the user thereof.

Article 24 (Dispute Resolution)

① The Company shall establish and operate a damages compensation department to ensure that it reflects reasonable opinions or complaints raised by users and compensate for the damages. 

② The Company shall first handle complaints or opinions given by a user; provided, however, that where it is difficult to handle them promptly, the Company shall forthwith notify the user of the reasons and action schedules.

③ In the event that a user files an application for remedy of damages with respect to electronic commercial transaction disputes incurred between the Company and the user, the Company may be subject to settlements rendered by the Korea Fair Trade Commission or a dispute settlement authority requested by governors of cities or provinces.

Article 25 (Jurisdiction and Governing Laws)

① Any lawsuit relating to electronic commercial transactions incurred between the Company and users shall be brought to a competent court of jurisdiction under the Civil Procedural Code.

② Any lawsuit for electronic commercial transactions brought between the Company and users shall be governed by the Korean laws.

These Terms and Conditions shall be applicable from [2024.07.01].