Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• •"Company" (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to SeAH Holdings Corporation and SeAH Steel Holdings Corporation.
• •"Country" refers to the Republic of Korea.
• •"Cookies" are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
• •"Device" means any device that can access the Service such as a computer, a cell phone or a digital tablet.
• •"Personal Data" is any information that relates to an identified or identifiable individual.
• •"Service" refers to the Website.
• •"Service Provider" means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
• •"Usage Data" refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• •"Website" refers to SeAH Group website, accessible from https://www.seah.co.kr/index.asp.
• •"You" means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Types of Data Collected

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of Our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit Our Service or when You access the Service by or through a mobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

• •Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of Our Service.
• •Web Beacons. Certain sections of Our Service and Our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when Yougo offline, while Session Cookies are deleted as soon as You close Your web browser.

We use Persistent Cookies for the purposes set out below:

• •Tracking and Performance Cookies
• Type: Persistent Cookies
• Administered by: Third-Partie
• Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new pages, features or new functionality of the Website to see how Our users react to them.

Details of the Cookies

Strictly necessary cookies

These cookies are necessary for the operation of the website and cannot be disabled in Our systems. They are usually set in response to actions you have taken that constitute a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or be informed of the existence of these cookies, but some parts of the website may be affected. These cookies do not store any personally identifying information.

Use of Your Personal Data

We may use Your information for data analysis, identifying usage trends, and to evaluate and improve Our website.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with Our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce Our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your Personal Data and other personal information.

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.

Analytics

We may use third-party Service providers to monitor and analyze the use of Our Service.

• •Google Analytics 4
• Google Analytics 4 is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of Our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
  For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy

Where you are an individual located in the European Economic Area or the United Kingdom, you have the following rights:

Right to access

You have the right to obtain from us free information about Your Personal Data processed at any time and a copy of this information. Furthermore, You will have access to the following information: the purposes of the processing; the categories of personal data concerned; where possible, the envisaged period for which the personal data will be processed, or, if not possible, the criteria used to determine that period; the existence of the right to request from us rectification or erasure of personal data, or restriction of processing of personal data concerning you, or to object to such processing; the existence of the right to lodge a complaint with a supervisory authority; where the personal data are not collected directly from you, any available information as to their source; and the existence of automated decision-making, including profiling, and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for you.

Right to rectification

You have the right to obtain from us, without undue delay, the rectification of inaccurate Personal Data concerning You. Taking into account the purposes of the processing, You shall have the right to have incomplete Personal Data completed, including by means of providing a supplementary statement.

Right to be forgotten

You have the right to obtain from us the erasure of Personal Data concerning You as soon as possible, and we shall have the obligation to erase Personal Data without undue delay where required by the law, including when:

• •the Personal Data is no longer necessary in relation to the purposes for which they were collected or otherwise processed;
• •there is no longer a legal ground for the processing;
• •You object to the processing and there are no overriding legitimate grounds for the processing;
• •the Personal Data has been unlawfully processed;
• •the Personal Data must be erased for compliance with a legal obligation in accordance with the applicable law to which we are subject.

Right to restriction of processing

You have the right to obtain from us the restriction of processing where one of the following applies:

• •the accuracy of the Personal Data is contested by You, for a period enabling us to verify the accuracy of the personal data;
• •the processing is unlawful and you oppose the erasure of the Personal Data and requests instead the restriction of their use instead;
• •we no longer needs the Personal Data for the purposes of the processing, but they are required by You for the establishment, exercise or defense of legal claims; and/or
• •You have objected to processing pursuant to applicable laws.

Right to object

You have the right to object, on grounds relating to your particular situation, at any time, to the processing of Personal Data concerning you. We shall no longer process the Personal Data in the event of the objection, unless we can demonstrate reasonable grounds for the processing, which override the interests, rights and freedoms of You, or for the establishment, exercise or defense of legal claims.

Right to withdraw data protection consent

You have the right to withdraw your consent to the processing of your Personal Data at any time.

Right to lodge a complaint

We would appreciate if You engaged with us in case You would have any issue with Our data protection practices as described in this Policy.

In case such practices and additional exchange with us would not be satisfactory, You have the right to lodge a complaint with the Supervisory Authority of Your usual place of residency, including as the case may be within the EU (see list here) or in the UK with the Information Commissioner’s Office.

If you have any questions regarding this privacy policy or the protection of your personal data, you may reach out to the Communications team at:

• •For inquiries: seagpr@seah.co.kr