Privacy Policy for LG Aesthetics Medical Platform™

LG Chem Ltd. (hereinafter the “Company” or “we” or “us”) is committed to protecting your personal information in a manner that is consistent with applicable laws, including data protection laws. This privacy policy (“Privacy Policy”) explains how we collect, use and otherwise process and protect your personal information collected through LG Aesthetics Medical Platform™ (the “Website”).

• - Purposes of the Processing of Personal Information
• - Items of Personal Information Processed
• - Children’s Information
• - Retention of Personal Information
• - Sharing of Personal Information with Third Parties
• - International Transfer of Personal Information
• - Third Party Websites
• - Rights of Data Subjects
• - Measures for the Security of Personal Information
• - Cookies and similar Technologies
• - Contact Information
• - Amendments to this Privacy Policy

• Purposes of the Processing of Personal Information

  The Company processes personal information for the following purposes.

  1. 1. Provision of Services requested by you

     - To Provide you with the requested information and contents on the Website

     - To enable real-time chat consultations on the Website, as well as to respond to inquiries related to the Website

     - To register you with events, including academic events or webinars which you applied for, and arranging and operating such events

     - Provision of customized service and consultation, answering various questions, and handling of complaints

     - Visits to homes for in-home injection training

  2. 2. Marketing and Promotion

     - To provide information on online and/or offline training sessions, meetings, seminars, academic events and other educational or promotional events and related reports, including sending personalised commercial offers and information by the Company and its affiliates

     - To provide e-Newsletters or various information on the Company’s products and services

     - To conduct research or other marketing activities, and arranging and administering related events (e.g., events for giveaway prizes); to conduct market surveys by the Company (intended to hear your valuable opinions and to help improve the Company’s products and services accordingly)

  3. 3. Arranging and Conducting clinical activities, etc.

     - To provide information on clinical trials conducted by the Company solely or in collaboration with a medical partner; to perform clinical activities (e.g., clinical trials) which you take part in; to consult on clinical activities; and to make requests for clinical activities and arranging and executing contracts thereon

  4. 4. Operation and Maintenance of the Website

     - System administration and management including optimizing the Website

     - To maintain security by detecting threats and to protect the Website against fraudulent or malicious activities, etc.

     - Complying with applicable laws

     - We may use your information to track your use of the Website and services provided through the Website to make sure that what you receive or hear from us is relevant and useful to you as an individual. For example, we may recommend a specific webinar to you or send you information about a specific topic when you have shown interest in such topic through your use of the Website.

• Items of Personal Information Processed

  The Company collects the following information from you through the Website:

  - Name, email address and your country of residence

  - Log-in ID (i.e., your email address) and password for the Website

  - Name of your company/clinic you work for, your title or position thereat, and address and zip-code of your company/clinic

  - Specialty and department, type of membership, medical license number, your photograph and any other information on your physician ID card

  - Information about your OS, browser, mobile device, system use details, access log information, IP address information and other information about your activities on our Websites (e.g. contents you viewed, webinars you participated in)

  - Information about the events (e.g. webinars) you registered for and/or participated in through the Website

• Children’s Information

  The Company does not knowingly collect personal information of users under the age of 18. If we learn that we have collected personal information from a child under the age of 18, we will delete such personal information.

• Retention of Personal Information

  The Company will use, store and process personal information for as long as necessary to fulfill the purposes for which it was collected and processed.

  Specifically, the periods for processing and retaining different types of personal information are as follows:

  • - In general, the Company uses and stores your personal information for three (3) years or until you ask the Company to delete your personal information before this three (3) year period expires, unless applicable laws require the Company to continue to preserve such personal information.
  • - In cases where applicable laws require the Company to store certain types of personal information for certain periods of time, the Company will comply with such requirements.
  • - Where we process registration information, we do this for as long as you are an active user of the Website and for three (3) years after this.
  • - Where we process personal information for Website security purposes, we retain it for three (3) years.
  • - Where we process personal information in connection with performing a contract, we keep the data for 10 years from your last interaction with us.
  • - In cases where applicable laws require the Company to store certain types of personal information for certain periods of time, the Company will comply with such requirements.
  • - After the retention period has expired, the Company will destroy the relevant personal information without unreasonable delay and the procedures and methods used for destruction in such cases will be as follows:

    ① Procedures for destruction: Select items of personal information for which a cause for destruction has occurred and destroy the personal information unless other applicable laws require the continued preservation of such personal information.

    ② Methods of destruction: Personal information recorded and stored in electronic files will be destroyed by technical means in a way that renders the personal information irretrievable, and personal information recorded and stored on paper will be shredded or incinerated.

• Sharing of Personal Information with Third Parties

  We may share your personal information to third parties as follows:

  - We share your personal information with service providers who help us to: host and operate the Website; develop, manage and maintain relevant systems; We may also share your personal information with lawyers, auditors, information and security firms, and other third parties who provide services to us.

  - We may share your personal information with our local affiliates situated in the same country as such you, so they can send you offers, promotions, or advertisements about products or services or any useful information they believe you may be interested in. We will obtain your consent for the sharing of your personal information for such purposes when required to do under the applicable laws.

  - We may share your personal information with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.

  - In the event that the business is sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser's adviser and will be passed to the news owners of the business.

• Third Party Websites

  The Website may contain links to third party websites. We do not have any control over such third party websites. We will not be responsible for the protection of any information which you provide while visiting third party websites. When accessing third party websites, you should review the privacy statements applicable to such third-party websites and services you use.

• Rights of Data Subjects

  You have rights to your personal information as provided for under the laws applicable to you. If you are resident of the European Union, please refer to your rights here.

  You can exercise your rights by contacting lampinfo@lgchem.com or forryoo@lgchem.com .

  If you are aware of changes or inaccuracies in your personal information, you should inform us of such changes/inaccuracies promptly so that we may update or correct your personal information.

• Measures for the Security of Personal Information

  The Company takes reasonable measures to safeguard your personal information, including the following:

  1. Organizational measures

  - The Company establishes and implements an internal management plan for the secure management of personal information.

  - The Company provides information security training for personal information handlers at least once a year.

  - The Company minimizes the personnel who have access to important personal information including particular identification information and sensitive information.

  2. Technical measures

  - The Company encrypts important personal information and control different levels of access to ensure that only necessary personnel can access particular personal information for the purpose of work.

  - The Company operates server access control systems and access log forgery/falsification prevention devices, block unauthorized access, and appropriately responds to infiltrations such as hacking incidents.

  - The Company installs a security program to prevent unauthorized transmission of personal information to the outside.

  - The Company encrypts channels to ensure secure transmission of personal information.

  3. Physical measures

  - The Company designates restricted areas such as computer rooms and archives and controls access thereto.

• Cookies and Similar Technologies

  The Company as well as certain third parties that provide content, functionality, or services on the Website uses a variety of technologies to operate and enhance the function of the Website and learn more about how people use the Website.

  The Company uses cookies when operating the Website. Cookies are small text files that the server for the Website sends to your browser and are stored on your computer. Cookies store and retrieve information from time to time for various purposes. You can refuse to receive cookies at any time by configuring your browser settings. You can choose to accept all cookies, require prompt notification for confirmation whenever cookies are stored, or to refuse to receive all cookies by configuring your web browser.

  Please find below a list of the cookies and the purposes of such cookies that the Company uses when operating the Website:

  1. Essential Cookies

  - Essential cookies enable basic functions of the Website like page navigation and access to secure areas of the Website. Without essential cookie, you would not be able to use the Website as intended.

  Essential Cookies table

  Cookie Name	Provider	Purpose	Expiry	Type
  User ID	LG Chem, Ltd.	To keep users able to check previously used ID information	Until the cookie is deleted from the user's device	Session

  2. Functional Cookies

  - Functional cookies enable the website to remember information which was already entered, such as username, password, users’ preferred language or the region that you are in. These cookies improve the user experience, e.g. by enabling automatic log-in.

  Functional Cookies table

  Cookie Name	Provider	Purpose	Expiry	Type
  User ID	LG Chem, Ltd.	To remember previously entered user ID( email address) for login	Until the cookie is deleted from the user’s device	Session

  3. Performance Cookies

  - Performance cookies help the Company to understand how visitors interact with the Website and improve the performance of the Website and the user experience, by collecting and reporting information about the way the Website is used.

  Performance Cookies table

  Cookie Name	Provider	Purpose	Expiry	Type
  collect	Google LLC: Google Analytics	- To send data about the visitor's device and behavior to Google Analytics. - To track the visitor across devices and marketing channels. - To compile reports and to help us improve the website - To analyse your usage behaviour and tailor our Website and other services and marketing communication to your specific preferences and needs. - See more detail information below. For more information about how Google safeguards your data please see: https://support.google.com/analytics/answer/6004245	Pixel: At the end of each web-browsing session; Usage data collected by the pixel: 13 months	Pixel Tracker

  Google Analytics:

  This Website uses Google Analytics, a web analytics service. It is operated by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Analytics uses so-called "pixels". These are counting pixels that are not visible and set on specific areas of our Website to access information stored on your computer that allow an analysis of the use of the Website by you. The tracking pixels collect specific information, including the number of visitors to the Website, where visitors have come to the Website from and the pages they visited.

  
  

  We use the information collected by this tool to track the visitor across devices and marketing channels, to analyse your use of our website and compile reports and to help us improve the website, and to analyse your usage behaviour and tailor our Website and other services and marketing communication to your specific preferences and needs.

  
  

  We have activated the IP anonymization feature on this website. Your IP address will be shortened by Google within the European Union or other parties to the Agreement on the European Economic Area prior to transmission to the United States. Only in exceptional cases the full IP address is sent to a Google server in the US and shortened there. Google will use this information on behalf of the operator of this website to evaluate your use of the website, to compile reports on website activity, and to provide other services regarding website activity and internet usage for the website operator. The IP address transmitted by your browser as part of Google Analytics will not be merged with any other data held by Google.

  
  

  You can prevent the collection of your data by Google Analytics with effect for the future by managing your Cookie preferences as outlined in Section 5 below, or by downloading and installing Google Analytics Opt-out Browser Add-on for your current web browser: http://tools.google.com/dlpage/gaoptout?hl=en.

  
  

  Furthermore, data collection and storage by Google Analytics can be objected to at any time by setting an opt-out cookie, with effect for the future. For this, please click on the following link: Deactivate Google Analytics. By confirming the link, a so-called opt-out cookie is set on your data storage medium. This cookie has a lifetime of 5 years. Please note that, if you delete all cookies from your computer, such opt-out cookie will also be deleted, i.e., if you wish to continue to object to anonymised data collection by Google, you have to set the opt-out cookie again. The opt-out cookie is set per browser and computer. If you visit our websites from your home and workplace or using different browsers, you have to activate the opt-out cookie for the different browsers or for the different computers.

  4. Marketing Cookies

  - Marketing cookies are used to track visitors across websites. The intention is to display content that is relevant and engaging for the individual user.

  Web beacons. Company, along with third-party partners, may also use technologies called web beacons that communicate information from users’ Internet browser to a web server. Web beacons can be embedded in web pages, videos, or emails, and can allow a web server to read certain types of information from user’s browser, check whether a user has viewed a particular web page or email message, and determine, among other things, the time and date on which a user viewed the web beacon, the IP address of user’s computer, and the URL of the web page from which the web beacon was viewed. Company and Company’s partners may use web beacons for a variety of purposes, including to analyze the use of the Website and in conjunction with cookies to improve the Website and to provide users with more relevant promotion materials.

• Contact Information

  Should you have any inquiry or complaint about the processing of your personal information in connection with the Website, please contact Head of the Business Innovation Management Department at 82-2-3773-0981 or at security@lgchem.com.

• Amendments to this Privacy Policy

  This Privacy Policy is effective as of 2021.01.01 and may be amended from time to time. and we will notify you of any material changes using the email address you gave to us on registration or by an announcement on the Website. The changes will apply to the use of the Website after such notice.

  You may check previous versions of the Company’s Privacy Policy on the following webpages:

• Legal Basis for Processing your Personal Information

  The Company processes your personal information for the purposes described in Purposes of the Processing of Personal Information, only: (1) with your consent; (2) when processing is necessary for the performance of a contract between you and us or in order for us to take steps at your request prior to entering into a contract; (3) to comply with a legal obligation; or (4) where the processing is necessary for the purposes of our legitimate interests and where these interests are not overridden by your fundamental rights and interests. Such legitimate interests are marketing activities, responding to your requests for information or complaints, administrative functions within the Company and its affiliates, and maintaining the security and efficiency of the Website. You may obtain further information on the legitimate interests balancing exercises which we have carried out by contacting us using the contact details provided below.

Marketing Cookies table

No.	Legal Basis for Processing	Purposes
1	With your consent	To send you direct marketing in relation to our relevant products and services: - To provide information on online and/or offline training sessions, meetings, seminars, academic events and other educational or promotional events and related reports. - To provide e-Newsletters or various information on the Company’s products and services. - To conduct other marketing activities, and arranging and administering related events (e.g., events for giveaway prizes)
		To send you personalised commercial offers and information via email by the Company and its affiliates on our aesthetics and medical products in the area of face and body, providing of respective guidelines, videos and webinars, market research, satisfaction surveys etc ., by customising the direct marketing communication using and analysing, my usage data in connection with the Website and its services, the direct marketing messages and/or my preferences collected during individual communications. The data may be transferred to third party providers , in accordance with "Sharing Your Personal Information With Third Parties" and "Transfer of your personal information to other countries" sections of this Privacy Policy. To place cookies in accordance with our “Cookies and Similar Technologies”: - We may use your information to track your use of the Website and services provided through the Website to make sure that what you receive or hear from us is relevant and useful to you as an individual. For example, we may recommend a specific webinar to you or send you information about a specific topic when you have shown interest in such topic through your use of the Website.
		On other occasions where we ask you for consent, we will use the data for the purpose which we explain at the time.
2	When processing is necessary for the performance of a contract between you and us or in order for us to take steps at your request prior to entering into a contract	To provide information on clinical trials conducted by the Company solely or in collaboration with a medical partner
		To perform clinical activities (e.g., clinical trials) which you take part in
		To consult on clinical activities
		To make requests for clinical activities and arranging and executing contracts thereon
3	To comply with a legal obligation	To comply with applicable laws including in response to requests by government or law enforcement authorities conducting an investigation
4	Where processing is necessary for the purposes of our legitimate interests and where these interests are not overridden by your fundamental rights and interests	To provide customized service and consultation, to answer various questions, and to handle complaints
		To enable real-time chat consultations on the Website, as well as to respond to inquiries related to the Website
		To provide you with the requested information and contents on the Website
		To verify your professional affiliate and professional identity and to register you as a member of the Website
		To conduct marketing and research activities, and arranging and administering related events (e.g., events for giveaway prizes)
		To conduct market surveys by the Company (intended to hear your valuable opinions and to help improve the Company’s products and services accordingly)
		To register you with events, including academic events or webinars which you applied for, and to arrange and operate such events
		To maintain security by detecting threats and to protect the Website against fraudulent or malicious activities, etc.

• Withdrawing consent or otherwise objecting to direct marketing

  Wherever we rely on your consent, you will always be able to withdraw consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below.

• Your Rights

  If you reside in the EU, you have a right to lodge a complaint to the supervisory authority for data protection where you live, work or where you believe a breach may have occurred.

  Also, subject to limitations and exceptions set forth in the General Data Protection Regulation of the European Union ("GDPR") and other applicable laws, you have the following rights relating to the processing of your personal information by the Company:

  • - Right to access: you have the right to ask us for a copy of your personal information.
  • - Right to rectification: you have the right to ask us to correct your personal information.
  • - Right to erasure: you have the right to ask us to delete your personal information.
  • - Right to restriction of processing: you have the right to ask us to stop any active processing of your personal information.
  • - Right to object: you have the right to object to the processing of your personal information in some circumstances (in particular, where we don't have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).
  • - Right to data portability: you have the right to obtain the personal information you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this data to another controller.

  Requests for the exercise of any of the foregoing rights should be submitted in writing to forryoo@lgchem.com.

• Transfer of your personal information to other countries

  Your personal information may be transferred to, stored, and processed in a country outside the European Economic Area, including South Korea, which may not provide an adequate level of data protection. For example, we may process the personal information in South Korea where the Company is located and the Company may share your personal information with service providers located in or out of South Korea. Such transfers will be carried out in accordance with applicable laws, including, where applicable, contractual requirements set out in standard data protection clauses which EU regulators have pre-approved. You can obtain a copy of such contracts by contacting forryoo@lgchem.com.

• Representative of Company in European Union

  As regards the processing of personal information concerning users within the EU, the Company has designated the following representative in the EU:

  EU Authorized Representative

  LG Chem Europe GmbH

  Europe Life Sciences Business Team

  Alfred-Herrhausen-Allee 3-5, 65760 Eschborn, Germany

  forryoo@lgchem.com

• Recipients

  The Company discloses the personal data to the third party as below.

  Recipient	Purpose
  LG CNS	Maintenance of system