CENTRAL Privacy Policy

Central, Co, Ltd., 551, Gongdan-ro, Seongsan-gu, Changwon-si, Gyeongsangnam-do 51557, Republic of Korea, or its affiliates or subsidiaries (“CTR”, “our”, “we” or “us”) would like to help you understand our privacy practices, including what Personal Data we collect, why we collect it, what we do with it, and how we protect it, as well as your rights with regards to it.



Topics

How CTR values your privacy

What Personal Data CTR collects and processes

Purposes for which CTR processes Personal Data

Cases when CTR shares Personal Data

International transfer of Personal Data

Children

How long do we keep your Personal Data

Your rights relating to your Personal Data

How we secure your Personal Data

Changes to our Privacy Policy

How to contact us

1. How CTR values your privacy

CTR is the controller of your Personal Data as described in this Privacy Policy, unless expressly specified otherwise.
CTR appreciates your interest in our company and products, visiting our websites (www.ctr.co.kr, www.neoctr.co.kr) or related communication channels, including, but not limited to, our social media pages and/or channels (together "CTR owned pages"). This Privacy Policy applies to the Personal Data that we collect or process when you interact with CTR owned pages through sales contacts and through marketing communications. The visitors, customers, suppliers and/or business partners can make these interactions.
Whenever and wherever CTR processes Personal Data beyond CTR owned pages, a different privacy notice may apply which will be clearly stated. When services are provided by third parties, the privacy policies of the third party applies and this Privacy Policy does not apply. You are encouraged to review those third parties’ privacy practices.
Last but not least, your privacy is of the highest priority at CTR and to be protected at all times. We are committed to working with you to obtain a fair resolution of any concern about privacy. If, however, you believe that we have not been able to assist with your concern, and you are located in the EEA, you have the right to lodge a complaint with the competent supervisory authority.

2. What Personal Data CTR collects and processes

“Personal Data” in our Privacy Notice means data that allows us to identify you either directly or indirectly combined with other information we have.
The Personal Data that we collect includes the following:


1) If you express an interest in obtaining additional information about our products, using the "Contact Us", signing up for or attending a seminar or meeting, or downloading materials, we may obtain your Personal Data, such as your name, company name, phone number, email address and country.

2) If you use and interact with our websites or emails, we may automatically collect information about your device and your usage of our websites or emails through cookies or similar technologies, such as Internet Protocol (IP) addresses or other identifiers, which may qualify as Personal Data.

3) If you meet our sales representatives, you may provide us as a prospective customer with your name, email address, phone number, company name and country.

4) If you provide us or our business partners with any Personal Data of other individuals, you represent that you have the authority to do so and acknowledge that it will be used in accordance with this Privacy Policy.


If you believe that your Personal Data has been provided to us improperly, or to otherwise exercise your rights relating to your Personal Data, please contact our Data Protection Officer in the “Contacting us” section below.



We may use cookies or similar technologies when you interact with and use the CTR owned pages . The data collected is used to ensure that the digital channel functions properly, to measure and improve performance of our digital channels, to better tailor advertising to your interests, both within and beyond CTR owned pages. You can delete cookies if you wish; while certain cookies are necessary for viewing and navigating on our website, most of the features will be still accessible without cookies.

3. Purposes for which CTR processes Personal Data

1) We process your Personal Data to perform our contract with you and to fulfill our obligations under applicable terms of use/service; where we have not entered into a contract with you, we base the processing of your Personal Data to provide you with the contents you access and request (e.g., when you leave requests via emails or on our website).

2) If you fill out a “Contact Us” web form, or if you contact us by other means including via a phone call, we process your Personal Data to perform our contract with you and to the extent it is necessary for our legitimate interest in fulfilling your requests and communicating with you.

3) We process your Personal Data to plan and host events, seminars or webinars for which you have registered or that you attend, including sending related communications to you.

4) We process your Personal Data for security reasons, to register visitors to our offices or factories and to manage non-disclosure agreements that visitors may be required to sign, to the extent such processing is necessary for our legitimate interest in protecting our offices or factories and our confidential information against unauthorized access.

5) We process your Personal Data to send you marketing information, product recommendations and other non-transactional communications (e.g., marketing newsletters or push notifications) about us and our affiliates and partners, including information about our products, promotions or events as necessary for our legitimate interest in conducting direct marketing or to the extent you have provided your prior consent (please see the "Your rights relating to your Personal Data" section, below, to learn how you can control the processing of your Personal Data by CTR for marketing purposes).

6) We process your Personal Data when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws.

4. Cases when CTR shares Personal Data

We may disclose your Personal Data:


1) To our affiliates or subsidiaries for the purposes described in this Privacy Policy.

2) To our third party service providers who provide services such as website hosting, data analysis, order fulfillment, information technology and related infrastructure provision, email delivery, CRM, event management, auditing, fraud detection and other services.

3) To third parties, to permit them to send you marketing communications, consistent with your choices if you have opted into such sharing.

4) To your connections associated with your social media account, to other website users and to your social media account provider, in connection with your social sharing activity. You understand that the use of the information we share is governed by the social media provider’s privacy policy.


When you interact with CTR as a business customer, supplier or business partner, CTR may disclose Personal Data available in reports and other materials provided by you and/or your company pursuant to an engagement with another business partner and/or a supplier.


We may also use and disclose your Personal Data as we believe to be necessary or appropriate: (a) to comply with applicable law, which may include laws outside your country of residence, to respond to requests from public and government authorities, which may include authorities outside your country of residence, to cooperate with law enforcement or for other legal reasons; (b) to enforce our terms and conditions; and (c) to protect our rights, privacy, safety or property, and/or that of our affiliates or subsidiaries, you or others.


In addition, we may use, disclose or transfer your information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

5. International transfer of Personal Data

Your Personal Data may be collected and processed by us in the Republic of Korea and by our affiliates in other countries where we operate.


Therefore, your Personal Data may be processed outside the European Economic Area (EEA), and in countries which are not subject to an adequacy decision by the European Commission and which may not provide for the same level of data protection as the EEA. In this event, we will ensure that the recipient of your Personal Data offers an adequate level of protection.

6. Children

Our business does not engage children. We do not knowingly collect Personal Data from children under the age of 16. If you are a parent or guardian and believe your child has provided us with Personal Data without your consent, please immediately let our Data Protection Officer know, who will take a proper action to delete such Personal Data from our systems.

7. How long do we keep your Personal Data

We may retain your Personal Data for a period of time consistent with the original purpose of collection. We determine the appropriate retention period for Personal Data on the basis of the amount, nature and sensitivity of your Personal Data processed, the potential risk of unauthorized use or disclosure of your Personal Data and whether we can achieve the purposes of the processing through other means, as well as on the basis of applicable legal requirements (such as applicable statutes of limitation).
After expiry of the applicable retention periods, your Personal Data will be deleted. If there is any data that we are unable to delete entirely from our systems for technical reasons, we will take appropriate measures to prevent any further use of such data.

8. Your rights relating to your Personal Data

You have certain rights relating to your Personal Data, subject to local data protection laws. Depending on the applicable laws, these rights may include:


1) To access your Personal Data held by us (right to access).

2) To rectify inaccurate Personal Data and, taking into account the purpose of processing the Personal Data, ensure it is complete (right to rectification).

3) To erase/delete your Personal Data, to the extent permitted by applicable data protection laws (right to erasure; right to be forgotten.

4) To restrict our processing of your Personal Data, to the extent permitted by law (right to restriction of processing).

5) To transfer your Personal Data to another controller, to the extent possible (right to data portability).

6) To object to any processing of your Personal Data carried out on the basis of our legitimate interests (right to object).

7) Not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects ("Automated Decision-Making"). Automated Decision-Making currently does not take place on our websites or in our services.

8) To the extent we base the collection, processing and sharing of your Personal Data on your consent, to withdraw your consent at any time, without affecting the lawfulness of the processing based on such consent before its withdrawal.


Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out. If you make use of (some of) your choices and rights, you may not be able to use, in whole or in part, certain our service

9. How we secure your Personal Data

We seek to put in place organizational, technical and physical measures to safeguard against the accidental or unlawful unauthorized disclosure of, or access to, the Personal Data we process.

You are responsible for protecting your passwords, limiting access to your devices and signing out of websites after your sessions. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us.

10. Changes to our Privacy Policy

We may revise this Privacy Policy to reflect changes in our practices, technologies, legal requirements and other factors. If we do, we will update the “last updated date” at the top of this Privacy Policy. We encourage you to periodically review this Privacy Policy to stay informed about our collection, processing and sharing of your Personal Data.

11. How to contact us

To exercise your rights regarding your Personal Data, or if you have questions regarding this Privacy Notice or our privacy practices please mail us at:


CTR Data Protection Officer
Management Support Team (joonghak.ko@ctr.co.kr)
551, Gongdan-ro, Seongsan-gu, Changwon-si, Gyeongsangnam-do 51557, Republic of Korea

Last updated on 05 27 2019