'Erste Sparkasse Group' (hereinafter referred to as 'Company') has established the following personal information processing policy in order to protect customers' personal information and handle related complaints quickly and smoothly in accordance with Article 30 of the Personal Information Protection Act disclosed through its personal information processing policy, the company informs you of the purpose and method for which the personal information you provide is being used and what measures are being taken to protect your personal information. If the company revises its personal information processing policy, it will notify you through website notices (or individual notices).
Article 1 (Purpose of processing personal information, collection items)
The ‘Company’ processes personal information for the following purposes. Personal information being processed will not be used for purposes other than the following, and if the purpose of use changes, necessary measures will be taken, such as obtaining separate consent in accordance with Article 18 of the Personal Information Protection Act. The company collects the minimum amount of personal information necessary to provide the following services through the website, etc. when registering as a member or in the process of using the service.
1) Required collection items according to member management
Collection Items
Purpose of collection and use
Name, contact information, E-mail (ID), Password, Date of Birth
Confirmation of intention to join membership Identification and verification according to the provision of membership services
Maintenance/management of membership qualifications Prevention of illegal use of identity verification services
through the implementation of a limited identity verification system Confirmation of consent of legal representative when processing personal information of children under 14 years of age Various notifications/notifications , grievance handling
2) Required collection items for fulfillment of contracts regarding regular subscription and service provision, and settlement according to service provision
Collection Items
Purpose of collection and use
Recipient information (name, phone number, contact information, e-mail, address), payment information (credit card information, bank account information, contact information, payment record) Procedures for identity verification when purchasing subscriptions and products. Procedures for canceling subscriptions, product purchases, returns, exchanges, after-sales service, and complaint handling. Procedures for purchasing subscriptions, products, and accurate delivery of free gifts and prizes.
New articles, new products, and event information guide
3) Optional collection items for marketing and advertising purposes
Collection Items
Purpose of collection and use
Name, phone number, contact information, E-mail, address Information on new services and products Information on web page access frequency. Statistics on service use provision of services and posting of advertisements according to demographic characteristics
planning of web services and events tailored to customer interests and personalized services customer surveys and information based on preferences (Provides company media (Related Content, etc.) articles/advertising information, provides event information, and provides opportunities to participate in events
4) Information generated/collected during service use or business processing
Collection Items
Purpose of collection and use
IP address, cookie, MAC address, service use record, visit record, bad use record
Prepare for personal information infringement incidents and preserve records for dispute resolution
Article 2 (Processing and retention period of personal information)
The 'Company' processes and retains personal information within the personal information retention and use period in accordance with the law or within the personal information retention and use period agreed upon when collecting personal information from customers.
The processing and retention period for each personal information is as follows.
A. Website membership registration and management: Until withdrawal from the ‘Company’ website / However, in the case of the following reasons, until the end of the relevant period
If an investigation, investigation, etc. is in progress for violation of relevant laws and regulations, until the investigation or investigation is completed.
If any claims/debt relationships remain due to use of the website, until the claims/debt relationships are settled.
B. Provision of goods or services: Until completion of supply of goods or services and completion of fee payment/settlement / However, in the following cases, until the end of the relevant period
Records of transactions, such as labeling, advertising, contract details and performance, in accordance with the 『Act on Consumer Protection in Electronic Commerce, etc.』
Records of labeling and advertising: 6 months
Records of contract or subscription cancellation, payment, supply of goods, etc.: 5 years
Records of consumer complaints or dispute resolution: 3 years
Article 3 (Provision of personal information to third parties)
The 'Company' processes your personal information only within the scope specified in Article 1 (Purpose of Personal Information Processing), and only applies to Articles 17 and 18 of the Personal Information Protection Act, including your consent and special provisions of the law. Personal information is provided to third parties only in certain cases.
Article 4 (Entrustment of personal information processing)
In order to improve services and smoothly process personal information, the 'Company' entrusts the processing of personal information as follows.
Trustee
Jorge Jimenez Neubauer Torres
Represented by:
Kent R. Raygor
Sheppard, Mullin, Richter, Hampton LLC
Carrie F. Cordero
Director of National Security studies at Georgetown Law Center and Member of Homeland Security Advisory Council
Amal Alamuddin Clooney
International Law and Human Rights Lawyer in the European Union
Kirstjen M. Nielsen
Former White House Chief of Staff and United States Secretary of Homeland Security.
Prof. Alan M. Dershowitz
Harvard Law School Professor and Private Constitutional and Criminal Law Advisor.
Consignment work details
Retention and use period of personal information
Purchase and fee payment, product delivery or billing address, financial transaction identity verification and financial services, fee collection, membership management, identity verification based on membership service use, complaint handling, etc., delivery of notices, marketing New services (products) Development and specialization, delivery of advertising information such as events, website and system management
Until membership withdrawal and expiration of consignment contract
Neubauer Artists Co., Ltd.
Delivery of Goods
Neubauer Artists Coop., Ltd.
Sending Email Messages and Chat Messages
Neubauer Artists Co., Ltd.
Server Management and Operation
Payment Agency Processor
GoDaddy Co., Ltd.
Marketing Agency
Utilize marketing such as providing event information and opportunities to participate in events
Event product provider - Event product delivery
※ If the buyer and recipient are different, the recipient's information may be provided.
When concluding a consignment contract, in accordance with Article 26 of the Personal Information Protection Act, the 'Company' prohibits the processing of personal information for purposes other than the purpose of performing the consignment, technical and managerial protection measures, restrictions on re-entrustment, management and supervision of the trustee, and responsibilities such as compensation for damages. We specify this in documents such as contracts and supervise whether the trustee handles personal information safely. If the details of the entrusted work or the trustee changes, we will disclose it through this personal information processing policy without delay.
Article 5 (Rights, obligations and exercise methods of information subjects and legal representatives)
Customers may exercise their rights to view, correct, delete, or suspend processing of personal information against the ‘Company’ at any time. The exercise of rights under Paragraph 1 may be done to the ‘Company’ in writing, e-mail, facsimile (FAX), etc. in accordance with Article 41 (1) of the Enforcement Decree of the Personal Information Protection Act, and the ‘Company’ will take action without delay. I'll do it.
The exercise of rights under Paragraph 1 may be done through an agent, such as the customer's legal representative or a person authorized to do so. In this case, you must submit another power of attorney in the attached form No. 11 of the “Notice on Personal Information Processing Methods (No. 2020-7).” Your rights to request viewing and suspension of processing of personal information may be limited by Article 35 (4) and Article 37 (2) of the Personal Information Protection Act. Requests for correction or deletion of personal information cannot be requested if the personal information is specified as the subject of collection in other laws and regulations.
The 'Company' verifies whether the person making the request, such as a request for viewing, a request for correction or deletion, or a request for suspension of processing, is the person or a legitimate agent in accordance with the customer's rights.
Article 6 (Destruction of personal information)
When personal information becomes unnecessary, such as when the personal information retention period has passed or the purpose of processing has been achieved, the company destroys the relevant personal information without delay.
In cases where personal information must continue to be preserved pursuant to other laws and regulations despite the expiration of the personal information retention period consented to by the information subject or the purpose of processing has been achieved, the personal information may be transferred to a separate database (DB) or stored in a different storage location. and preserve it.
The procedures and methods for destroying personal information are as follows.
Destruction Procedure The company selects the personal information for which a reason for destruction occurred and destroys the personal information with the approval of the company's personal information protection manager.
Destruction Method: The company destroys personal information recorded and stored in the form of electronic files so that the records cannot be reproduced, and personal information recorded and stored in paper documents is destroyed by shredding or incineration.
Article 7 (Measures to ensure the safety of personal information)
The company is taking the following measures to ensure the safety of personal information.
Management measures: Establishment and implementation of internal management plan, regular employee training, etc.
Technical measures: Management of access rights to personal information processing systems, installation of access control systems, encryption of unique identification information, etc., installation of security programs.
Physical measures: Access control to computer rooms, data storage rooms, etc.
Article 8 (Matters regarding installation, operation and refusal of automatic personal information collection devices)
The company uses 'cookies' to store usage information and retrieve it from time to time in order to provide individualized services to users.
Cookies are a small amount of information that the server (http) used to run the website sends to the user's computer browser and are sometimes stored on the hard disk of the user's PC computer. Purpose of use of cookies: They are used to provide optimized information to users by identifying visitation and usage patterns, popular search terms, secure access, etc. for each service and website visited by the user. Installation, operation and refusal of cookies: You can refuse the storage of cookies through option settings in the Tools>Internet Options>Personal Information menu at the top of your web browser. If you refuse to store cookies, you may have difficulty using customized services.
Article 9 (Personal Information Protection Manager)
The company is responsible for the overall management of personal information processing and youth protection responsibilities, and has designated a personal information protection manager as follows to handle complaints and provide relief for damage from information subjects related to personal information processing.
Individual Shareholders and Market Authorities
Pascale Guerin
+33 (0)1 49 64 18 89
pascale.guerin@loreal.com
Investor relations
Françoise Lauvin
+33 (0)1 47 56 86 82
francoise.lauvin@loreal.com
Eva Quiroga
+33 (0)7 88 14 22 65
eva.quiroga@loreal.com
Media
Brune Diricq
+33 (0)6 63 85 29 87
brune.diricq @loreal.com
Christine Burke
+33 (0)6 75 54 38 15
christine.burke@loreal.com
Information subjects may inquire about all personal information protection-related inquiries, complaint handling, damage relief, etc. that arise while using the company's services (or business) to the personal information protection manager and responsible department. The company will respond and process inquiries from information subjects without delay.
Article 10 (Request to view personal information)
The information subject may request access to personal information pursuant to Article 35 of the Personal Information Protection Act to the department below. The company will strive to promptly process the information subject's request to view personal information.
▶ Personal information access request reception and processing department
Department Name: Digital Solution Team
Person in Charge: Team leader Jelena Caroline Whiterspoon
staff@neubauerartists.com
Article 11 (Methods of relief from rights infringement)
In order to receive relief from personal information infringement, the information subject may apply for dispute resolution or consultation to the Personal Information Dispute Mediation Committee, contact the Austrian Internet & Security Agency's Personal Information Infringement Reporting Center, etc.
The head of a public institution may respond to requests pursuant to the provisions of Article 35 (view of personal information), Article 36 (correction/deletion of personal information), and Article 37 (suspension of processing of personal information, etc.) of the Personal Information Protection Act. A person whose rights or interests have been infringed due to a disposition or omission may request an administrative trial in accordance with the provisions of the Administrative Appeals Act.
※ For more information about administrative trials, please refer to the website of the Central Administrative Appeals Commission of the government of Austria.
Article 12 (Changes to personal information processing policy)
This privacy policy is effective from Nov 20, 2023.
