Privacy Policy

Effective date: December 30, 2025

ActionPower Co., Ltd. (https://www.actionpower.kr, hereinafter the "Company") collects, uses, and provides personal information based on the consent of members who use the internet site and mobile application (daglo.ai, hereinafter "daglo") operated by the Company.

The Company complies with the relevant laws of the Republic of Korea as well as personal information protection regulations and guidelines, and maintains the following Privacy Policy to protect members' personal information and rights so that members can use the service with confidence.

01. Collection and Use of Personal Information

A. The Company collects personal information for the purpose of verifying the user's identity and intent to use the service in order to provide optimized and customized services. At the time of initial membership registration, the Company collects only the minimum information essential to perform the core functions of the service, and may additionally collect information necessary for payment, product delivery, and refunds arising from the use of services provided by the Company.

B. The Company does not use personal information for purposes other than the collection and use purposes set forth in Paragraph C of this Article, nor does it provide such information to third parties without the user's consent.

C. The Company may collect and use personal information for the following purposes. Where the collection and retention of resident registration numbers and bank account numbers is unavoidable under relevant laws such as the Act on Consumer Protection in Electronic Commerce, the Framework Act on National Taxes, and the Electronic Financial Transactions Act, or where the collection and retention of mobile phone number information is unavoidable for fee settlement such as mobile micropayments, the Company may collect such information after notifying the user.

1) Purpose and Items of Collection

(Required) Identity verification, SSO integration (*for registration purposes, limited to name, ID, password, mobile phone number, and email address) — Name, ID, password, email address, date of birth, gender

(Required) Contact for notice of contract performance and changes to terms, identity verification, and handling of customer complaints such as civil petitions — ID, mobile phone number, email address, telephone number, address

(Required) Service use and payment — Recipient information, payment information, bank account information, mobile phone number, cash receipt information, LLM conversation history (including input information such as files, images, and videos, and information the user has granted access to (voice, video, files, URLs, images, etc.))

(Required) Marketing — Advertising identifiers, service usage records, cookies

(Optional) Service quality improvement — Voice and video files, call recording files, transcription results, edited text, patterns of interaction with the service

(Optional) Provision of customized services and user analysis — Gender, age group, occupation, purpose of use, expected features

2) Additional Collection Related to Supplementary Services

In the course of using supplementary or customized services, or entering events (including but not limited to support programs and supporters operations), additional personal information may be collected solely from users of the relevant service. When collecting additional personal information, the Company will, at the point of collection, inform the user of the "items of personal information collected, the purpose of collection and use of the personal information, and the retention period of the personal information" and obtain consent. In addition, during the initial onboarding process of the service, optional survey information such as gender, age group, occupation, and area of interest may be additionally collected in order to set up the user's profile and provide customized recommendations. Such information is collected only when the user enters it directly, and there is no restriction on service use even if it is not entered.

3) Automatically Generated and Collected Information

In the course of using the service or processing business operations, the following information may be automatically generated and collected, stored, combined, and analyzed.

IP address, smartphone device information (device model, OS, mobile carrier, device ID), service access date and time, service usage records and other usage history information, voice and video files, call recording files, names of contacts stored on the mobile phone (names of call counterparts), telephone numbers, etc.

D. When collecting a user's personal information, the Company always obtains the user's consent unless there is a legal basis, and does not collect information that may infringe on the user's fundamental human rights, such as race, place of origin, place of permanent residence, ideology, political orientation, criminal records, or health status, except with the user's consent or as stipulated by law.

E. The Company allows membership registration only for those aged 14 or older, and in principle does not collect the personal information of children under the age of 14 for whom the consent of a legal representative is required for the collection and use of personal information. However, where the consent of a legal representative has been obtained, the Company may collect and use the personal information of users under the age of 14.

F. The Company may collect personal information through the following methods.

Website, written form, fax, telephone, customer center inquiries, event entries, in-app initial surveys

Automatic collection through information generation collection tools

G. In collecting personal information, the Company classifies the minimum personal information necessary for service provision as "required consent items" and other personal information as "optional consent items," and provides procedures for consenting to each separately. The Company does not refuse to provide its service on the grounds that a user has not provided personal information beyond the minimum necessary.

02. Use of Collected Personal Information

The Company uses personal information only for the following purposes, such as member management, service development, provision and improvement, and building a safe internet usage environment.

A. The Company uses personal information for member management, such as confirming the intent to register as a member, verifying age and obtaining the consent of a legal representative, verifying the identity of the user and legal representative, identifying users, and confirming the intent to withdraw membership.

B. In addition to providing existing services such as content (including advertising), the Company uses personal information for the discovery of new service elements and the improvement of existing services, such as demographic analysis, analysis of service visits and usage records, formation of relationships among users based on personal information and interests, and provision of customized services based on acquaintances and interests. The optional survey information provided by the user, such as gender, age group, occupation, purpose of use, and preferred features, is used for providing personalized services, enhancing recommendation features, improving services, and statistical analysis.

C. The Company uses personal information for user protection and service operation, such as measures to restrict use against members who violate laws and the Company's terms of use, prevention of and sanctions against acts that interfere with the smooth operation of the service including fraudulent use, prevention of account theft and fraudulent transactions, delivery of notices such as amendments to terms, preservation of records for dispute resolution, and handling of civil petitions.

D. The Company uses personal information for identity verification, purchase, and fee payment associated with the provision of paid services.

E. The Company uses personal information for marketing and promotional purposes, such as providing event information and participation opportunities and providing promotional information.

F. The Company uses personal information for analysis of service usage records and access frequency, statistics on service use, service analysis using user behavior analysis tools, and the provision of customized services and placement of advertisements based on such statistics.

G. The Company uses personal information to build a service usage environment that users can use with confidence in terms of security, privacy, and safety.

03. Outsourcing of Personal Information Handling

A. The Company may outsource the handling of personal information to others for smooth and improved services. In this case, the Company will inform the user in advance of all of the following matters and obtain consent. The same applies where any of the following matters changes. 1) The party receiving the outsourced personal information handling 2) The content of the work for which personal information handling is outsourced

B. Where necessary to perform a contract concerning the provision of information and communications services and to enhance user convenience, the Company may outsource the handling of personal information to others without going through the notification and consent procedures, by disclosing the matters set forth in each item of Paragraph A in accordance with the Privacy Policy.

C. The Company outsources work as follows in connection with the processing of personal information, and takes necessary measures to ensure that personal information is managed safely when concluding outsourcing contracts in accordance with relevant laws. When concluding outsourcing contracts, the Company considers the personal information protection capabilities of the trustee and periodically checks whether the trustee fulfills its obligations such as safe management and destruction of personal information. In addition, the information processed through outsourcing is limited to the minimum information necessary to provide smooth services.

NHN KCP Corp. — Payment processing

KG Inicis Co., Ltd. — Payment processing

Toss Payments — Payment processing

NICE Information Service Co., Ltd. — Identity verification

Google LLC — Statistical analysis via Google Analytics, statistical analysis via Firebase Analytics, integration for providing language model (LLM)-based features

AssemblyAI, Inc. — Service operation

OpenAI OpCo, LLC — Integration for providing language model (LLM)-based features

Anthropic PBC — Integration for providing language model (LLM)-based features

Perplexity AI, Inc. — Integration for providing language model (LLM)-based features

X.AI LLC — Integration for providing language model (LLM)-based features

Appsflyer — Analysis of media and sites that drove app installs

Amplitude — Statistical analysis via Amplitude

Microsoft Corporation — Statistical analysis via Microsoft Clarity

Airbridge — Mobile app/web inflow path analysis, ad performance measurement and statistical analysis, attribution data processing

Sentry — Error monitoring and log analysis

04. Cross-Border Transfer of Personal Information

For smooth personal information processing, the Company outsources to overseas entities as follows. (Trustee — Location — Method of transfer — Contact of information management officer — Outsourced items — Outsourced work — Retention period)

Amazon Web Services, Inc. — USA — Transmitted via server from time to time during service use — aws-korea-privacy@amazon.com — ID, email, smartphone device information (device model, OS, device ID), IP address, cookies, service access date and time, service usage records, call recording files, call counterpart names, telephone numbers, etc. — Provision of service operating environment and data storage — Retained during the service provision period

Google LLC — USA — Transmitted via server from time to time during service use; transmitted when a user enters personal information in the chat window and sends it; transmitted when using LLM-integrated features such as summarization based on documents containing personal information or STT results — googlekrsupport@google.com — ID, email, smartphone device information (device model, OS, device ID), IP address, cookies, service access date and time, service usage records, call recording files, call counterpart names, telephone numbers, etc., and chat history or STT results when using language model (LLM)-integrated features — Provision of service operating environment and data storage — Retained during the service provision period

AssemblyAI, Inc. — USA — Transmitted via server from time to time during service use — support@assemblyai.com — Voice and video files and call recording files entered by the user — Provision of service operating environment — Retained during the service provision period

OpenAI OpCo, LLC — USA — Transmitted when a user enters personal information in the chat window and sends it; transmitted when using LLM-integrated features such as summarization based on documents containing personal information or STT results — privacy@openai.com — Chat history or STT results when using language model (LLM)-integrated features — Provision of service operating environment — Retained during the service provision period

Anthropic PBC — USA — Transmitted when a user enters personal information in the chat window and sends it; transmitted when using LLM-integrated features such as summarization based on documents containing personal information or STT results — privacy@anthropic.com — Chat history or STT results when using language model (LLM)-integrated features — Provision of service operating environment — Retained during the service provision period

Perplexity AI, Inc. — USA — Transmitted when a user enters personal information in the chat window and sends it; transmitted when using LLM-integrated features such as summarization based on documents containing personal information or STT results — support@perplexity.ai — Chat history or STT results when using language model (LLM)-integrated features — Provision of service operating environment — Retained during the service provision period

X.AI LLC — USA — Transmitted when a user enters personal information in the chat window and sends it; transmitted when using LLM-integrated features such as summarization based on documents containing personal information or STT results — privacy@x.ai — Chat history or STT results when using language model (LLM)-integrated features — Provision of service operating environment — Retained during the service provision period

Microsoft Corporation — USA — Transmitted via server from time to time during service use — privacy@support.microsoft.com — Website usage information (behavioral data such as page navigation, clicks, and scrolling), browser information, device information, IP address, etc. — Analysis of patterns of interaction with the website, statistics, and service improvement purposes — Retained during the service provision period

Sentry — USA — Transmitted via server from time to time during service use — compliance@sentry.io — Device information, IP address, user ID — Error information collection — Retained during the service provision period

05. Retention of User Personal Information: Period of Use and Destruction

In principle, the Company retains and uses a user's personal information for the period notified and agreed upon, and destroys it without delay when the purpose of collection and use of the personal information is achieved or when the user requests destruction. However, the following information is retained for the period specified below for the reasons stated.

A. Reasons for Retaining Information under Relevant Laws and Company Policy

Where it is necessary to preserve information in accordance with the provisions of relevant laws such as the Commercial Act, the Company retains the user's personal information for a certain period stipulated by law. In this case, the Company stores such information separately and uses it only for the purpose of such retention, and does not use it for other purposes such as marketing.

1) Reasons for Retaining Information under Relevant Laws (Relevant law — Purpose — Items collected — Retention period)

Protection of Communications Secrets Act, Article 12-2 — Provision upon request of an investigative agency that has obtained a court warrant — Log records, IP addresses, etc. — 3 months

Act on Consumer Protection in Electronic Commerce, Article 6 — Records on consumer complaints or dispute handling — Consumer identification information, dispute handling records, etc. — 3 years

Act on Consumer Protection in Electronic Commerce, Article 6 — Records on payment and supply of goods, etc. — Consumer identification information, contract/withdrawal records, etc. — 5 years

Act on Consumer Protection in Electronic Commerce, Article 6 — Records on contracts or withdrawal of subscription, etc. — Consumer identification information, contract/withdrawal records, etc. — 5 years

Framework Act on National Taxes, Article 85-3 — Calculation of the exclusion period for the imposition of national taxes — National tax supporting documents, etc. — 10 years

Framework Act on National Taxes, Article 85-3 — Calculation of the extinctive prescription of the right to collect national taxes — Tax base and tax amount filing data, etc. — 5 years

Value-Added Tax Act, Article 71 — Books, tax invoices, import tax invoices, receipts, etc. — Filing data for the VAT tax base and tax amount, etc. — 5 years

Electronic Financial Transactions Act, Article 22 — Verification of electronic financial transaction records — Records on electronic financial transactions, information on counterparties, etc. — 5 years

2) Reasons for Retaining Information under Company Policy

Retention of fraudulent transaction records. Reason: Exclusion of fraudulent transactions — Retention period: 6 months — Retained items: ID, mobile phone number, email address, date of birth, reason for fraudulent transaction, member status value at withdrawal, etc. (※ Fraudulent transaction: a transaction with a method or content that violates laws, the terms of service between the Company and the user, or public order and morals, or otherwise infringes on the rights or interests of the Company, members, or others.)

B. The retention and use period of collected personal information is from the conclusion of the service use agreement (membership registration) until the termination of the service use agreement (including withdrawal application and ex officio withdrawal). In addition, upon withdrawal of consent, the Company destroys the user's personal information without delay, except for data stored for a certain period in accordance with the retention reasons specified above, and where the handling of personal information has been outsourced to a third party, it also instructs the trustee to destroy it.

C. A dormant account is an account that has not been used even once for at least 2 years. The Company reserves the right to delete accounts that have been dormant in the service for at least 2 years, along with the activities and data of such accounts. The criteria for the dormancy period are determined in accordance with the service dormancy policy.

D. The Company notifies the user, by methods such as notices and email, of the fact that the personal information will be destroyed or stored/managed separately, the expiration date of the period, and the items of the relevant personal information, no later than 30 days before the expiration of the period under Paragraph C. To this end, users must provide/update accurate contact information to the Company.

E. A user's personal information is destroyed without delay after the purpose of collection and use is achieved. Personal information printed on paper is destroyed by shredding it with a shredder or by incineration, and personal information stored in electronic file form is destroyed using a technical method or physical method that renders the records irreproducible.

06. Smartphone App Management

When using the service through a smartphone app, the Company notifies the user that it accesses device information, etc. within the scope for which consent to the collection and use of personal information has been obtained, and information is collected or transmitted only after obtaining approval. Even if a user has granted device access permissions on the app, it does not mean that all information related to the granted permissions is immediately collected or transmitted.

07. Rights of Users

A. Users may view and correct their personal information at any time through "Edit Information" on the daglo site, and where requested by email or in writing, the Company will process the viewing, correction, and deletion. Where a user's personal information has been provided to or its handling outsourced to a third party, the user may request destruction from the Company or the "third party" or "trustee." However, member ID, name, resident registration number, and alien registration number cannot be corrected; changes to name due to a legal name change and changes to resident (business) registration numbers due to administrative issues may be permitted as exceptions. Where correction or deletion is prohibited or restricted under other laws, such processing may be restricted. In addition, in the case of a request to correct an error in personal information, the Company does not use or provide the relevant personal information until the correction is completed, unless the provision of the personal information is requested under another law. If incorrect personal information has already been provided, the Company will notify the third party of the correction result so that the correction is made.

B. Users may request the suspension of processing of their personal information on the daglo site at any time. However, the Company may refuse a request to suspend processing in the following cases.

Where there are special provisions in the law or where it is unavoidable to comply with legal obligations

Where there is a risk of harming the life or body of another person, or a risk of unfairly infringing on the property and other interests of another person

Where, without processing the personal information, it is difficult to perform the contract, such as being unable to provide the service agreed upon with the data subject, and the data subject has not clearly expressed an intention to terminate the contract

C. Users may withdraw at any time the consent they have given to the collection, use, and provision of personal information through membership registration, etc. Consent can be withdrawn by clicking "Membership Withdrawal Application" on the Company site or by contacting us in writing, by email, etc., and the Company will take necessary measures such as deletion of personal information without delay. However, where the Company is required to retain the member's personal information in accordance with the provisions of laws or terms, such processing may be restricted. In this case, the member must state their member ID and identity verification information for identification purposes, and there may be some restrictions on the service or some services may not be available due to the withdrawal.

08. Obligations of Users

Users have a duty to protect their own personal information, and the Company is not responsible for problems arising from the leakage of personal information due to the user's own carelessness, such as the transfer, lending, or loss of ID, password, or access medium without fault on the part of the Company, or leaving the device while logged in, or due to problems on the internet that the Company cannot control despite reasonable care, such as hacking using methods or technologies that cannot be blocked by security measures under relevant laws.

A. Users must keep their personal information up to date, and the responsibility for problems arising from the user's input of inaccurate information lies with the user.

B. In the case of membership registration by stealing another person's personal information, or transactions of goods by stealing a resident registration number, etc., the user may lose user qualification and be punished in accordance with the Resident Registration Act.

C. Users are responsible for maintaining the security of their ID, password, etc., and may not transfer or lend them to third parties. Users have an obligation to cooperate with the periodic change of passwords for security in accordance with the Company's personal information protection policy.

D. After using the Company's service, users must always log out of their account and close the web browser program.

E. Users must comply with the "Act on Promotion of Information and Communications Network Utilization and Information Protection," the "Personal Information Protection Act," the "Resident Registration Act," and other laws concerning personal information.

09. Matters Concerning the Collection, Use, and Provision of Behavioral Information and Refusal Thereof

The Company collects and uses behavioral information through cookies, without identifying individuals, in order to improve and optimize the usability of the services provided to users and to provide customized services and benefits, online customized advertising, etc. Such information does not include information that directly identifies individuals, and is used only for the purposes of statistical analysis and service improvement. If you do not wish to have data collected, you may refuse collection by the method set forth in [Matters Concerning the Installation, Operation, and Refusal of Automatic Personal Information Collection Devices] at the bottom of this policy. However, if you refuse to store cookies, there may be restrictions on the use of some services.

A. Information on Google Analytics

For the purpose of providing better services to users, the Company uses Google Analytics, a web analytics service provided by Google LLC (hereinafter "Google"). Google Analytics uses cookies to collect information on how users use the website. Google transmits the information collected through cookies to and stores it on Google servers located in the United States. Google may provide this information to third parties where required by law or to third parties who process the relevant information on Google's behalf. Google does not associate a user's IP address with any other data held by Google. Information on Google's privacy protection can be found in the [Google Analytics Privacy Notice].

To refuse data collection by Google Analytics, you may configure settings on the Google site or refuse to store cookies through [How to Refuse Cookie Settings] at the bottom. However, if you refuse to store cookies, there may be restrictions on the use of some services that require login, and the responsibility for this lies with the user.

B. Microsoft Clarity

Microsoft Clarity is a user behavior analysis tool that helps understand how users interact with the website through features such as session replay and heatmaps. Microsoft Clarity uses cookies to collect information on how users use the website. Clarity provides screen masking features to ensure that sensitive information is not collected, and users may refuse data collection at any time in accordance with Microsoft's policy.

To refuse data collection, you may configure settings on the Microsoft Clarity site or refuse to store cookies through [How to Refuse Cookie Collection] at the bottom. However, if you refuse to store cookies, there may be restrictions on the use of some services that require login, and the responsibility for this lies with the user. Information on Microsoft's privacy protection can be found here.

C. KT Nasmedia

KT Nasmedia is not subject to outsourcing of personal information handling. It uses advertising identifiers (ADID, IDFA, etc.) to provide customized advertising based on app/web usage history and performs ad effectiveness analysis and statistical analysis. Such information cannot identify individuals and is automatically collected via cookies and SDKs.

To refuse data collection, you may refuse to receive marketing information through [Matters Concerning the Installation, Operation, and Refusal of Automatic Personal Information Collection Devices] at the bottom.

Web — Website usage information (behavioral data such as page navigation, clicks, and scrolling), browser information, device information, IP address, etc. — Automatically collected upon website visit — Analysis of how users interact with the website, statistical analysis, and service improvement purposes — Upon service termination or membership withdrawal

Mobile app — Advertising identifiers, access information, device information, etc. — Automatically collected when the user launches or uses the app — Provision of customized advertising, ad effectiveness measurement, statistical analysis — Upon service termination or membership withdrawal

D. Airbridge

For the analysis of inflow paths, ad performance measurement, and campaign optimization of mobile app and web services, the Company uses Airbridge, a mobile app attribution tool provided by AB180 Inc. The following information may be collected and used through the Airbridge SDK and tracking links. The actual items collected may vary depending on the service and app settings.

Advertising identifiers (ADID, IDFA, etc.)

Whether the app is installed and launched, in-app event information (registration, purchase, etc.)

Device information (device OS, device model, app version, etc.)

Access information (IP address, country/language, carrier information, etc.)

Browser/app environment information (screen size, network status, etc.)

Such information is used only for the purposes of ad performance analysis, compilation of usage statistics, detection of fraudulent traffic, and campaign optimization in a form that cannot directly identify individuals, and is processed in compliance with relevant laws and Airbridge's personal information processing policy.

E. Sentry

For service error analysis and stability improvement, the Company uses Sentry (Functional Software, Inc.). The following information may be automatically collected and used through the Sentry SDK. The actual items collected may vary depending on the service and app settings.

Browser information (browser name/version), OS information

Device information (device model, OS version, etc.)

Page URL, request path, click timing, and other usage information directly related to error occurrence

Error stack traces, console logs, network error logs, and other data for service error analysis

IP address, cookies, or anonymous identifiers (after PII filtering is applied)

Such information is processed in a form that cannot directly identify individuals, and is used only for the purposes of service error analysis and quality improvement. It is also processed safely in accordance with Sentry's privacy policy and relevant laws.

10. Matters Concerning the Installation, Operation, and Refusal of Automatic Personal Information Collection Devices

A. The Company uses cookies that store and frequently retrieve usage information to provide customized services to users. A cookie is a text file automatically generated in the user's web browser when accessing a website. This cookie is automatically deleted when the user logs out and closes the web browser.

1) Purpose of Using Cookies

Cookies are used for customized services (including personalized advertising) and statistical analysis by collecting information on the visits and usage patterns of the daglo service visited by the user, IP address, browser type, access server, server location, responses to specific advertisements, and other related information.

2) How to Refuse Cookie Collection

Users have the option to choose whether to install cookies, and may allow or refuse cookie storage through browser settings. However, if you refuse cookie storage, there may be restrictions on the use of some services such as login.

Internet Explorer — Refuse cookie use in [Tools > Internet Options > Privacy > Advanced]

Microsoft Edge — Configure in [Settings and more > Settings > Cookies and site permissions > Cookies and data stored]

Chrome — Refuse cookie use in [Settings > Privacy and security > Cookies and other site data > General settings]

Android — Disable "Allow cookies" in [Settings > Internet settings > Privacy and security > Other]

iOS — Select "Block all cookies" in [Settings > Safari > Privacy and security]

B. The Company uses users' advertising identifiers and analytics software to provide more appropriate and useful services and advertisements (including customized advertising) to users. In this process, app/web usage information may be automatically collected and transmitted through SDKs and scripts provided by third parties such as Google Analytics, Microsoft Clarity, and Airbridge. Users may refuse the use of interest-based advertising through device or browser settings or the Opt-Out features provided by each operator.

How to block marketing information reception — Android: Deselect [Settings > Google > Privacy > Marketing information reception]

How to block personalized advertising — Android: Select "Opt out of Ads Personalization" in [Settings > Google > Ads] or [Settings > Google > Privacy > Ads] / iOS: Deselect "Personalized Ads" in [Settings > Privacy > Apple Advertising]

11. Privacy Officer

A. The Company designates a Privacy Officer as follows to take overall responsibility for the handling of personal information and to handle complaints and provide remedies for damages from data subjects in relation to personal information processing.

Privacy Officer Name: Lee Ji-hwa

Position: CTO

Contact: (+82)070-7775-0033, privacy@actionpower.kr (※ Connects to the personal information protection department)

B. Data subjects may direct all inquiries, complaints, and matters concerning remedies for damages related to personal information protection that arise while using the Company's service (or business) to the Privacy Officer and the relevant department. The Company will respond to and handle data subjects' inquiries without delay.

For reports or consultations regarding other personal information infringements, you may contact the following organizations.

Personal Information Dispute Mediation Committee: www.kopico.go.kr / (1833-6972)

Personal Information Infringement Report Center: privacy.kisa.or.kr / (118)

Supreme Prosecutors' Office: www.spo.go.kr / (1301)

National Police Agency: ecrm.police.go.kr / (182)

12. Duty of Notification

This Privacy Policy may be changed according to government policy or the needs of the Company, and where there are additions, deletions, or modifications to the content, the Company will provide prior notice through the website or email 7 days before implementation; where prior notice is difficult, it will give notice without delay, and this policy takes effect from the date of notice. However, where matters disadvantageous to users are added, deleted, or modified, prior notice will be given 30 days in advance, and the changes will take effect after 30 days have elapsed. In addition, where content related to matters requiring the separate consent of customers under relevant laws such as the Act on Promotion of Information and Communications Network Utilization and Information Protection, such as the collection and use of personal information and provision to third parties, is added or changed, the Company will obtain the separate consent of customers in accordance with relevant laws.

Notice Date: December 23, 2025

Effective Date: December 30, 2025