We fully recognize the importance of protecting personal information. We believe that properly handling personal information is part of our social responsibility and declare that we strive to protect personal information in accordance with the following principles (hereinafter “this Privacy Policy”). The definitions of terms other than those defined separately in this Privacy Policy shall be in accordance with the definitions in the Act on the Protection of Personal Information (Act No. 57 of 2003) and other related laws and regulations (hereinafter "Personal Information Protection Laws").

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i.Our Company Profile

Please refer to CONTACT on our corporate Website.

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ii. Compliance with Laws and Regulations

We will strictly comply with Personal Information Protection Laws, guidelines, industry self-regulation rules, and internal rules, etc. when carrying out operations in which personal information is handled.

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iii. Acquisition of Personal Information

We will acquire personal information by fair and legitimate means. In addition, unless permitted by Personal Information Protection Laws, we will not acquire any special care-required personal information without the prior consent of the individual to whom such personal information pertains.

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iv. Use of Personal Information

(1) We will use personal information only for the purposes of use officially announced in advance or within the scope of use informed at the time of acquisition and to the extent necessary to carry out business.

(2) We will not use personal information in a manner that may encourage or induce illegal or unlawful activities.

(3) In the case where we share personal data with a third party, or entrust the handling of personal data to a third party, we will examine such third party rigorously, and perform proper supervision to ensure that such third party keeps the personal information confidential.

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v. Provision of Personal Data to Third Parties

Except as provided by Personal Information Protection Laws, we will not provide personal data to any third party without the prior consent of the individual to whom such personal data pertains.

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vi. Provision of Personal Data to Third Parties in Foreign Countries

When we disclose or provide personal data to a third party located in a foreign country, we will comply with the rules of Personal Information Protection Laws, and in principle, we will obtain the consent of the individual in question after providing the information required by Personal Information Protection Laws in advance.

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vii. Safety Management Measures for Personal Information (Required)

(1) We appropriately store and manage personal information in an accurate and up-to-date manner and implement necessary measures to prevent unauthorized access, leakage, loss, or damage.

(2) Specific safety management measures include the following:

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I. Basic Policy and Internal Framework

We establish a basic policy to ensure proper handling of personal data, including compliance with Personal Information Protection Laws and the designation of a contact point for inquiries.

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II. Organizational Measures

We appoint a manager responsible for personal data handling, clearly define the scope of data and authorized personnel, and maintain a reporting system for suspected violations. Regular self-inspections and audits by internal and external parties are conducted.

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III. Human Measures

Employees receive training on proper handling of personal data, and confidentiality obligations are stipulated in employee regulations.

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IV. Physical Measures

Access to areas where personal data is handled is controlled, and measures are taken to prevent unauthorized viewing, theft, or loss of equipment, media, and documents, including during transportation.

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V. Technical Measures

Access controls are implemented to limit employee access to personal information databases, and systems are protected from unauthorized access and malicious software.

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VI. Understanding the External Environment

We outsource certain data storage to a cloud service provider. Personal data is stored in United States of America under the provider’s management, and we implement appropriate measures based on our understanding of United States of America personal information protection framework, referencing information from the Personal Information Protection Commission of United States of America.

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VII. Disclosure, Correction, Suspension of Use, and Deletion of Personal Information (Required)

We appropriately and promptly respond to requests for disclosure, correction, suspension of use, or deletion of personal information, as well as inquiries and complaints, in accordance with Personal Information Protection Laws. Requests should be directed to the designated Personal Information Inquiry Desk.

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VIII. Compliance Program for the Protection of Personal Information (Required)

We have established a compliance program for the protection of personal information, including this Privacy Policy and related regulations. We ensure employees and relevant parties are informed of this program and continuously implement, review, and improve it to ensure proper management of personal information.

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Purposes of Use of Personal Information

The Company will use the personal information that it acquires for the following purposes. If you have any questions, please contact via Contact-SOESCO@soesco.llc.

1. Personal Information of Business Partners
Negotiations, communications, consultations, order acceptance and placement, settlement or other processing relating to business transactions; receipt of goods or services relating to business transactions; and appropriate and smooth performance of other operations of the Company.

2. Personal Information of the Company’s Officers, Employees, Former Employees and their Family Members
Work-related communications, exchanges of information, and compliance with rights and duties relating to labor laws and regulations, tax laws and regulations and social welfare laws and regulations, including human resource policies (including transfers, evaluations, and career development such as education), payment of wages, attendance management, benefits and so on; performance of various procedures specified by internal regulations; and other labor management and smooth performance of the operations of the Company.

3. Personal Information of Job Applicants Acquired during Hiring Activities
Provision of information and communications relating to hiring by the Company, screening of job applicants and hiring decisions; provision of documents and communications for hiring procedures after a provisional decision is made; and other labor management and smooth performance of the operations of the Company.

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