EXTERNAL PRIVACY NOTICE

Last Updated [2018-05-23]

We respect the privacy of every person who visits or registers with www.kocca.kr (the “Site”) of Korea Creative Content Agency Europe (“KOCCA Europe”). We also respect the privacy of every person who uses the services that we make available from the Site or who engages with us to use the services that KOCCA Europe provides (our “Services”) or whose personal information we may process as a result of providing the Services to others or who applies to work at KOCCA Europe.

1. PURPOSE OF THIS POLICY

This privacy notice (“Privacy Notice”) explains our approach to any personal information that we might collect from you or which we have obtained about you from a third party and the purposes for which we process your personal information. This Privacy Notice also sets out your rights in respect of our processing of your personal information. See below for more information.

This Privacy Notice is intended to assist you in making informed decisions when using our Services and/or to understand how your personal information may be processed by us as a result of providing the Services to others or when you apply to work at KOCCA Europe. Please take a moment to read and understand it.

Please also note that this Privacy Notice only applies to the use of your personal information obtained by us, it does not apply to your personal information collected during your communications with third parties.

2 . WHO ARE WE AND WHAT DO WE DO?

Our Services are provided by KOCCA Europe (“we”, “us” or “our”). See below for more information.

KOCCA Europe is the data controller responsible for your personal information provided to us by you or third parties.

KOCCA Europe is a UK establishment of an overseas company, Korea Creative Content Agency, with a UK establishment number BR012873 and whose office is at 1st Floor, 6 Conduit Street, London, United Kingdom, W1S 2XE.

3 . HOW TO CONTACT US?

If you have any questions about this Privacy Notice or want to exercise your rights set out in this Privacy Notice, please contact us by:

• sending an e-mail to london@kocca.kr
• calling us on: +44 (0)20 7016 3330

4. WHAT PERSONAL INFORMATION DO WE COLLECT AND HOW DO WE USE IT?

Our primary goal in collecting personal information from you may be to: (i) verify your identity; (ii) help us deliver our Services (including, but not limited to, providing information on Korean creative contents to corporate clients in Europe and vice versa; arranging meetings between Korean creative businesses and corporate clients in Europe, and/or facilitating discussions with relevant parties relating to business opportunities); (iii) improve, develop and market new Services; (iv) carry out requests made by you in relation to our Services; (v) invite you to industry events specifically related to your field (the “Event”); (vi) investigate or settle inquiries or disputes; (vii) comply with any applicable law, court order, other judicial process, or the requirements of a regulator; (viii) enforce our agreements with you; (ix) protect the rights, property or safety of us or third parties, including our other clients and users of our Services; (x) provide support for the provision of our Services; (xi) recruitment purposes; and (xii) use as otherwise required or permitted by law.

To undertake these goals, we may process generally the following personal information:

• Name and (if applicable) job title;
• Contact information including email address;
• (If applicable) Company name;
• Your interaction with the Site;
• Other information relevant to provision of Services; and
• Any other personal data you provide to us.

If you are a visitor to the Site, Event, or we obtain your personal information from yourself , agencies or industry organisations we work with from time to time.

Primarily KOCCA Europe is engaged by corporate clients (i.e. other corporate entities) and as such those clients are not data subjects. However as part of such instructions personal information about other persons may be provided to us (e.g. personal information relating, without limitation, to any of our corporate clients’ or prospective clients’ workers.)

If you are an individual whose personal information may be processed by us as a result of providing the Services to others (including individual clients and corporate clients) we will process a variety of different personal information depending on the Services provided in question.

The following is a non-exhaustive list which is reflective of the varied nature of the personal information processed as part of a creative content agency.

For instance, if we are providing support to a Korean creative business who wishes to engage a corporate client, we may be provided with, and then process, personal information about that corporate client including but not limited to the corporate client contact’s name and contact details.

We might also need to process personal information in relation to the Korean creative business’ workers who use KOCCA Europe’s Services in the course of their work for our corporate client.

If you are a potential recruit to KOCCA Europe:

• Name and job title;
• Contact information including email address;
• Curriculum vitae, your education, employment history and similar matters and similar information that you may provide to us;
• Other information relevant to potential recruitment to KOCCA Europe; and
• Any other personal data you provide to us.

In particular, we may use your personal information for the following purposes:

• Fulfilment of Services. See below for more information.

  We collect and maintain personal information that you voluntarily submit to us during your use of the Site and/or our Services to enable us to perform the Services that we provide to you.

  These purposes include:

  • to provide information on Korean creative contents to corporate clients and vice versa;
  • to arrange meetings between Korean creative businesses and corporate clients in Europe;
  • to facilitate discussions between relevant parties relating to business opportunities;
  • general management to ensure Services are provided correctly; and
  • relationship management between relevant parties.

  What is our legal basis?

  It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you or it is in our legitimate interest or a third party’s legitimate interest to use personal information in such a way to ensure that we provide the Services in the best way that we can.

• Business administration and legal compliance. See below for more information.

  We use your personal information for the following business administration and legal compliance purposes:

  • to comply with our legal obligations(including Know Your Client, Anti-Money Laundering or Anti-Bribery or similar obligations including but without limitation maintaining regulatory insurance);
  • to enforce our legal rights; and
  • to protect rights of third parties.

  What is our legal basis?

  Where we use your personal information in connection with a business transition, to enforce our legal rights, or to protect the rights of third parties it is in our or a third party’s legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us.

• Recruitment and Talent Management. See below for more information.

  We use your personal information for the following recruitment purposes:

  • To assess your suitability for any position for which you may apply at KOCCA Europe whether such application has been received by us via email or by hard copy or in person application.
  • To review KOCCA Europe’s equal opportunity profile in accordance with applicable legislation, and KOCCA Europe does not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation. All employment related decisions are made entirely on merit

  What is our legal basis?

  Where we use your personal information in connection with recruitment it will be in connection with us taking steps at your request to enter a contract we may have with you or it is in our legitimate interest to use personal information in such a way to ensure that we can make the best recruitment decisions for KOCCA Europe. We will not process any special data except where we are able to do so under applicable legislation or with your explicit consent.

• Client insight and analysis. See below for more information.

  We analyse your contact details with other personal information that we observe about you from your interactions with our Site, our email communications to you and/or with our Services such as the Services you have viewed.

  Where you have given your consent (where lawfully required), we use cookies, log files and other technologies to collect personal information from the computer hardware and software you use to access the Site, or from your mobile. This includes the following:

  • an IP address to monitor Site traffic and volume;
  • a session ID to track usage statistics on our Site; and
  • information regarding your personal or professional interests, demographics, experiences with contact preferences.

  Our web pages and e-mails contain “cookies” "web beacons" or “pixel tags.” (“Tags”). Tags allow us to track receipt of an e-mail to you, to count users that have visited a web page or opened an e-mail and collect other types of aggregate information. Once you click on an e-mail that contains a Tag, your contact information may subsequently be cross-referenced to the source e-mail and the relevant Tag. In some of our e-mail messages, we use a “click-through URL” linked to certain website administered by us or on our behalf.

  By using this information, we are able to measure the effectiveness of our content and how visitors use our Site and our Services. This allows us to learn what pages of our Site are most attractive to our visitors, which parts of our Site are the most interesting and what kind of offers our registered users like to see.

  We also use this information for marketing purposes (see the marketing section below for further details).

  What is our legal basis?

  Where your personal information is completely anonymised, we do not require a legal basis to use it as the information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required.

  Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best products and services to you and our other clients.

• Marketing communications.

  We carry out the following marketing activities using your personal information:

  • Postal marketing. See below for more information.

    We use information that we observe about you from your interactions with our Site, our email communications to you and/or with Services and/or your address details, to send you marketing communications by post where we think will be of interest about us and our services. For example, industry s and insights, newsletters, invites to events and, where permitted by applicable law, promotional materials from KOCCA Europe.

    What is our legal basis?

    Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised information may be subject to other laws where your consent is required.

    Where your personal information is not in an anonymous form, such as your postal address, it is in our legitimate interest to use your personal information for postal marketing.

  • Email marketing. See below for more information.

    We use information that we observe about you from your interactions with our Site, our email communications to you and/or with our Services (and/or your email address, to provide information that we think will be of interest about us and our Services. For example, industry s and insights, newsletters, invites to events and, where permitted by applicable law, promotional materials from KOCCA Europe.

    What is our legal basis?

    Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required.

    Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.
    We will only send you marketing communications via email where you have consented to receive such marketing communications, or where we have a lawful right to do so.

  • Social media remarketing. See below for more information.

    We use information that we observe about you from your interactions with our Site, our email communications to you and/or with Services to provide you with personalised advertising on social media channels where you are a registered user of such services.

    What is our legal basis?

    Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required.

    Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.

5. HOW DO WE OBTAIN YOUR CONSENT?

Where our use of your personal information requires your consent, you can provide such consent:

• at the time we collect your personal information following the instructions provided; or
• by informing us by e-mail, post or phone using the contact details set out in paragraph 3 of this Privacy Notice.

6. OUR USE OF COOKIES AND SIMILAR TECHNOLOGIES

Our Site uses certain cookies, pixels, beacons, log files and other technologies of which you should be aware. Please contact us for our Cookie Policy for more information.

7. DATA SHARING AND EXTRA-EEA TRANSFERS

If you are based within the EEA, please note that where necessary to deliver the Services we will transfer personal information to countries to KOCCA Europe’s Head Office in the Republic of Korea outside the EEA. When doing so we will comply with our legal and regulatory obligations in relation to the personal information including but without limitation a lawful basis for transferring personal information and putting appropriate safeguards in place to ensure an adequate level of protection for the personal information.

8. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?

Regarding visitors to the Site, we will retain relevant personal information for at least three years from the date of our last interaction with you and in compliance with our obligations under the EU General Data Protection Regulation (or similar legislation around the world) (or for longer as we are required to do so according to our regulatory obligations or professional indemnity obligations).

Regarding personal information we have processed as part of providing the Services to any client, we will retain relevant personal information for at least six years from the date of our last interaction with that client and in compliance with our obligations under the EU General Data Protection Regulation (or similar legislation around the world) (or for longer as we are required to do so according to our regulatory obligations or professional indemnity obligations). We may then destroy such files without further notice or liability. If you request your files and documents we may charge you for the costs of copying a duplicate.

If personal information is only useful for a short period e.g. for specific marketing campaigns we may it.

9. CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION

We are committed to keeping the personal information provided to us secure and we will take reasonable precautions to protect personal information from loss, misuse or alteration. See below for more information.

We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:

• unauthorised access;
• improper use or disclosure;
• unauthorised modification; and
• unlawful destruction or accidental loss.

All of our members, employees, workers and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all visitors to the Site and all users of our Services.

10. HOW TO ACCESS YOUR INFORMATION AND YOUR OTHER RIGHTS?

You have the following rights in relation to the personal information we hold about you:

• Your right of access. See below for more information.

  If you ask us, we’ll confirm whether we’re processing your personal information and, if necessary, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.

• Your right to rectification. See below for more information.

  If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If you are entitled to rectification and if we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

• Your right to erasure. See below for more information.

  You can ask us to or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If you are entitled to erasure and if we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

• Your right to restrict processing. See below for more information.

  You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us. If you are entitled to restriction and if we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

• Your right to data portability. See below for more information.

  With effect from 25 May 2018, you have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.

• Your right to object.

  You can ask us to stop processing your personal information, and we will do so, if we are:

  • relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
  • processing your personal information for direct marketing.
• Your rights in relation to automated decision-making and profiling. See below for more information.

  You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.

• Your right to withdraw consent. See below for more information.

  If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.

• Your right to lodge a complaint with the supervisory authority. See below for more information.

  If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the UK Information Commissioner’s Office (ICO)]. You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.

11. COLLECTION OF INFORMATION BY THIRD-PARTY SITES AND SPONSORS

The Site contains links to other sites whose information practices may be different than ours. Visitors should consult the other sites' privacy notices as KOCCA Europe has no control over information that is submitted to, or collected by, these third parties

12. CHANGES TO THIS PRIVACY NOTICE

We may make changes to this Privacy Notice from time to time. See below for more information.

To ensure that you are always aware of how we use your personal information we will this Privacy Notice from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We will notify you by e-mail of any significant changes. However, we encourage you to review this Privacy Notice periodically to be informed of how we use your personal information.