Azelis Korea Portal Privacy Statement

This privacy statement (hereinafter: “Privacy Statement”) governs the processing of your personal data by the Azelis group (hereinafter: “Azelis Group”, “Azelis”, “we”, “us”, “our”) as part of your visit to our website  https://www.azelis.com/ as part of your registration on, and the use of, our customer dedicated portal  https://explore.azelis.com/ (hereinafter: “Azelis Portal”), your communication with us via e-mail, telephone, social media channels (such as Facebook, LinkedIn, Twitter, YouTube, Pinterest and Google+) or other means of communication or when you are (a contact person or representative of) a (potential) customer, business partner, service provider or a supplier of the Azelis Group.

If you want information on how we process personal data via cookies, social media plugins and other types of tracking technology, you are kindly referred to our  Azelis Portal Cookie Statement.

IN GENERAL

The data controller of the processing of your personal data is the Azelis Group company with which you usually interact (a webpage and the contact details of the Azelis Group companies   can be found here) and Azelis Corporate Services NV/SA, Posthofbrug 12 box 6, 2600 Antwerp, Belgium, with company number 0828.239.349, RPR/RPM Antwerp, division Antwerp.

A reference in this Privacy Statement to certain laws or regulations also includes any change, replacement or annulment of these laws or regulations, including any related executive decisions.

Azelis reserves the right to, from time to time, modify, change or amend this Privacy Statement at its own discretion with prior notice to you. You can always consult the latest version of this Privacy Statement on our Azelis Portal.

TYPES OF PERSONAL DATA WE PROCESS

Whenever you use our Website, our Azelis Portal and social media channels, we collect:

• Technical information associated with the device you use, such as your IP-address, browser type, geographical location and operating system;
• Information concerning your browsing behaviour, such as how long you visit, which links you click on, which pages you visit and how many times you visit a page.

When you fill out a contact form on our Website, register on our Azelis Portal or contact us via e-mail, telephone, social media channels or other means of communication, we collect:

• The basic identity information you provide us with, such as name, e-mail address, postal address, telephone number, your country, and the company you work for;
• The content of your communication or enquiry and the technical details of the communication itself (with whom you correspond at our end, date, time, etc.);
• Your preferences regarding market areas of interest and language;
• Your login details;
• Your preferences with regard to the communication medium used;
• Publicly available information of your profile on social media channels;
• Any other personal data you choose to provide to us.

We receive all personal data mentioned above directly from you, to the extent permitted by applicable law. It may happen that we receive additional information about your preferences and surfing behaviour from partners such as Google. If you require more information about the personal data these parties process about you and make available to others, you are kindly requested to consult their respective privacy policies.

If you are, or represent, a potential customer or customer, your personal data may be obtained from (a) the company or organisation you represent as well as (b) your previous distributor or supplier, to the extent permitted by applicable law.

PURPOSES FOR WHICH WE USE YOUR PERSONAL DATA

Azelis processes your personal data to provide you, in a personalised and efficient way, the information, products and services you request via the Website, the Azelis Portal, by e-mail, telephone, social media channels or other means of communication.

==> By contacting Azelis, you provide Azelis with your freely given, specific, informed and unambiguous consent to process your personal data to give full effect to your request.

Azelis processes your personal data for marketing purposes, i.e. to provide you with targeted communications, promotions, offerings and other advertisements of Azelis and selected partners.

Azelis will only send you communications, promotions, offerings, newsletters and other advertisements via e-mail or other person-to-person electronic communication channels if you consented thereto.

==> In all cases, the legal basis for processing your personal data for sending you marketing e-mails and communications will be your consent. 

If you are (the contact person of) a potential customer, customer or supplier, Azelis will process your personal data to engage in normal business activities, such as negotiations, conclusion of contracts, order handling and management, invoicing, reporting, accommodating and/or accepting deliveries, quality management, complaint handling, dispute resolution and general customer and supplier relationship management. 

==> Such processing of your personal data shall be limited to what is inevitably necessary for the preservation of Azelis’ legitimate interest of managing its normal business relations with potential customers, customers and suppliers.

If you are, or represent, a potential customer or customer, Azelis can also process your personal data to sell or otherwise transfer part of our distribution activities or portfolio to a new distributor and/or supplier in compliance with the requirements of applicable laws and regulations. 

==> Such processing of your personal data shall be limited to what is inevitably necessary for the preservation of Azelis’ legitimate interest of being able to conclude and terminate distribution agreements.

Azelis processes your personal data to comply with legal obligations or to comply with any request from competent law enforcement agents or representatives, judicial authorities, governmental agencies or bodies, including competent data protection authorities.

Your personal data may be transferred upon Court order or warrant to the police or the judicial authorities as evidence of an unlawful act or crime committed by you through your registration with or use of the Website, the Azelis Portal, our social media channels or other communications with us.

==> Such processing of your personal data shall be limited to what is inevitably necessary for defending against harmful or criminal conduct.

Azelis processes pseudonymization your personal data to perform statistical analyses so that we may improve our Website, our Azelis Portal, advertisement, products and services or to develop new products and services.

==> Such processing of your personal data shall be limited to what is necessary for the preservation of Azelis’ legitimate interest of improving its communication channels, marketing materials, products and services or to develop new such products and services. No personal data in the individual user are use in the statistical analyses. 

Azelis processes your personal data for the preservation of the legitimate interests of Azelis, its partners or a third party, which such interest is manifestly superior to the rights of you, if your registration with or use of the Website, the Azelis Portal, social media channels or other communication channels can be considered (a) a violation of any applicable terms of use or the intellectual property rights or any other right of a third party, (b) a threat to the security or integrity of the Website, the Azelis Portal, social media channels or other communication channels, (c) a danger to the Website, the Azelis Portal, social media channels or other communication channels or any of Azelis’ or its subcontractors’ underlying systems due to viruses, Trojan horses, spyware, malware or any other form of malicious code, or (d) in any way hateful, obscene, discriminating, racist, slanderous, spiteful, hurtful or in some other way inappropriate or illegal.

Azelis processes your personal data upon your consent where such processing is necessary for the preservation of its legitimate interest of being able to explore or conduct normal corporate or M&A transactions.

TO WHOM AZELIS SENDS YOUR DATA

Azelis relies on third-party processors to provide you access to our Website and our Azelis Portal and process your personal data on our behalf. These third-party processors are only allowed to process your personal data on behalf of Azelis and upon explicit written instruction of Azelis.

Azelis warrants that all third-party processors are selected with due care and are obliged to observe the safety and integrity of your personal data.

Azelis may share your personal data with other entities within the Azelis Group upon you prior consent. However, we ensure that all Azelis entities will take due care that all processing of your personal data is in line with what is set out in this Privacy Statement and applicable laws.

Azelis does not send your personal data in an identifiable manner to any third party without your explicit permission to do so expect for the following entities or individuals, provided however that, in each case, Azelis such comply with applicable legal requirements:

• Azelis’ third-party processors;
• a new distributor or supplier when the distribution agreement with Azelis terminates; or
• a supplier to handle and administer orders you have placed.

However, Azelis may send completely anonymised data to other organisations that may use those data for improving products and services as well as to tailor the marketing, displaying and selling of those goods and services.

LOCATION AND TRANSFER

Azelis processes your personal data within the South Korea Area. However, in order to process your personal data for the purposes outlined above, we may also transfer your personal data to other entities within the Azelis Group or to third parties who process on our behalf outside the South Korea Area upon your consent and in compliance of all legal requirements. Each entity outside the South Korea Area that processes your personal data will be bound to observe adequate safeguards with regard to the processing of your personal data under applicables laws. Such safeguards will be the consequence of:

• The recipient country having legislation in place which may be considered equivalent to the protection offered within the South Korea Area; or
• A contractual arrangement between Azelis and that entity. All Azelis entities are parties to a contractual agreement based on the European Commission’s Standard Contractual Clauses (controller-to-controller) (Commission Decision C(2004)5721).

Azelis may transfer completely anonymised to organisations outside the South Korea Area. Should such transfer take place, Azelis will ensure that there are safeguards in place to ensure the safety and integrity of your data and all rights with respect to your personal data you might enjoy under applicable mandatory law.

QUALITY ASSURANCES

Azelis does its utmost to process only those personal data that is necessary to achieve the purposes mentioned above.

Your personal data is only processed for as long as needed to achieve the purposes mentioned above or up until such time where you withdraw your consent for processing them. Azelis will de-identify your personal data when they are no longer necessary for the purposes outlined above, unless there is:

• A legal or regulatory obligation that prevents Azelis from de-identifying them.

You understand that an essential aspect of our marketing efforts pertains to making our marketing materials more relevant to you. This means that, when you consent thereto, Azelis builds a profile of you based on the personal data we collect from you (see above) and then uses this profile to provide you with communications, promotions, offerings, newsletters and other advertisements about products and services that may interest you.

Azelis will take appropriate technical and organisational measures as below to keep your personal data safe from unauthorised access or theft as well as accidental loss, tampering or destruction. 

(1)  Technical Measures

• The User’s personal data are encoded and protected. The User shall not leak, lend, provide or otherwise disclose the personal data to others, and the User shall be responsible for management of his/her own personal data from unauthorized collection by social engineering hacking, such as phishing, etc. The Company shall have no responsibility for such loss, theft, leakage, phishing, or disclosure of personal data.
• The Company’s security teams are always on duty around the clock and take protective measures to prevent damage by computer viruses by using the vaccine that automatically updates new information. If a virus penetrates, an alarm informing the viral penetration will be automatically given to the staff on duty and the computer virus will be automatically cured.
• The Company adopts the security system (SSL or SET) that can transmit the personal data on the networks safely by using encryption algorithms.
• The Company operates the intrusion detection and firewall system around the clock in order to prevent leakage of the User’s personal data by intrusion into its information network system, such as hacking, etc. 

(2) Managerial Measures

• The Company conducts in-house education and externally-outsourced education on acquisition of new security technology and the obligation to protect the personal data, etc., on a regular basis, to the employees who are in charge of processing the personal data.
• The Company has the internal process prepared to prevent data leakage by humans by causing all new employees to submit a letter of pledge for security; to monitor the obligations to be performed under the Privacy Statement and whether the employees have complied with the Privacy Statement; and to correct or improve any violation, if found, and take other necessary measures. Transfer of duties and responsibilities of the staff in charge of personal data is conducted with the security being strictly maintained. The Company clarifies who is hold accountable for personal data accident that may arise after an employee joins/leaves the Company. 

(3) Physical Measures

• The personal data are separated from general data and kept in a separate server without being mingled with general data.
• IT room and data storage room, etc., are designated as specially protected areas, access to which is controlled.

Access by personnel of Azelis or its third party processors will only be on a need-to-know basis and be subject to strict confidentiality obligations.

If you are registered to receive communications, promotions, offerings, newsletter and other advertisements via e-mail or other person-to-person electronic communication channels, you can change your preferences for receiving such communications, promotions, offerings, newsletter and other advertisements by following the unsubscribe link provided in such communications.

YOUR RIGHTS

You have the right to request access to all personal data processed by Azelis pertaining to you. Azelis reserves the right to charge an administrative fee for multiple subsequent requests for access that are submitted to clearly cause nuisance or harm to Azelis. Each request will specify for which processing activity you wish to exercise your right to access and will specify to which data categories you wish to gain access to.

You have the right to ask that any personal data pertaining to you that is inaccurate, is corrected free of charge. If you submit a request for correction, your request needs to be accompanied by proof of the flawed nature of the data for which correction is asked.

You have the right to withdraw your earlier given consent for processing of your personal data.

You have the right to request that personal data pertaining to you is deleted if the data is no longer required in the light of the purposes outlined above or if you withdraw your consent for processing them. However, you need to keep in mind that a request for deletion will be evaluated by Azelis against:

• Legal or regulatory obligations which may contradict such deletion.

You have the right to oppose the processing of personal data.  However, you need to keep in mind that a request for opposition will be evaluated by Azelis against:

• Overriding interests of any other third party ;
• Legal or regulatory obligations or administrative or judicial orders   which may contradict such deletion;
• Where it is impracticable to perform a contract such as the provision of services as agreed upon with the said data subject without processing the personal information in question, and the data subject has not clearly expressed the desire to terminate the agreement.

You have the right to receive from us in a structured, commonly-used and machine-readable format all personal data you have provided to us.
If you wish to submit a request to exercise one or more of the rights listed above, you can contact us by e-mail at the Azelis Group’s general privacy e-mail address:  privacy@azelis.com.

A request to exercise a right will not be construed as consent with the processing of your personal data beyond what is required for handling your request. Such request should clearly state which right you wish to exercise and the reasons for it if such is required. It should also be dated and signed, and accompanied by a digitally scanned copy of your valid identity card proving your identity. 

Azelis will promptly inform you of having received this request. If the request proves valid, Azelis shall process it as soon as reasonably possible and at the latest ten (10) days after having received the request.

For questions or complaints regarding the processing of your personal data by Azelis, please feel free to contact us via the Azelis Group’s general privacy e-mail address:   privacy@azelis.com. You also have the right to file a complaint with the competent data protection authority.

MISCELLANEOUS 

Privacy Officer

(1) The Company has appointed the privacy officer and the responsible employee who are responsible for supervision of all works related to the processing of personal data, and handle complaints from and damage remedy for data subjects with regard to the processing of personal data as follows: 

• Privacy Officer: [Young Yull Kim, Azelis Korea President]
• Responsible Employee: [Chan Jung, Korea Finance Director] 
• Email: privacy@azelis.com