1. Private information items and method of collection

1. Private information items such as Name, Email Address
2. Method of collection upon using hotel services

2. Purposes of collection and use of private information

Hotel may collects necessary minimum-level private information for the following items in order to provide effective services.

1. 	Collected items	Purpose
   Require	Name, Mobile number, Date of birth	- Respond to requests for information and services - Effective communication for notices and resolution of dissatisfaction issues - Provide and charge for the hotel accommodation and other goods and services-provide you with a better, more personalized level of service
   	Address, Email address	- Provide and charge for the hotel accommodation and other goods and services - Provide you with a better, more personalized level of service - Effective communication for notices and resolution of dissatisfaction issues - Conduct market research, customer satisfaction and quality assurance surveys, direct marketing and sales promotions - Administer general record keeping - Process credit applications
   Optional	Workplace, Job title, Work number, Home phone number, Number of children, Anniversary, etc.	- Effective communication for notices and resolution of dissatisfaction issues - Conduct market research, customer satisfaction and quality assurance surveys, direct marketing and sales promotions - Conduct market research, customer satisfaction and quality assurance surveys, direct marketing and sales promotions

* Sensitive private information (including race and ethnicity, ideology and faith, hometown and place of birth, political disposition, criminal records, health information and sex life) which could infringe on the basic rights of guests is not collected.

3. Provision and sharing of private information

The Hotel will not, at any time, use the private information outside the boundaries of the “Purposes of Collection and Use of Private Information” or provide such information to a third party or business/institution.

The Hotel does not provide the private information. However, exceptions apply in the following cases : Provision of such information as required by related laws and regulations or upon the demand of an investigative authority for investigative purposes and according to procedures and methods determined by law.

4. Private information retention/usage period and destruction

The Hotel immediately destroys all private information upon the achievement of the purposes of collection or provision of such information.
The time of destruction of the relevant information is as follows :Information collected for providing services : Upon the completion of the request for information

Provided, however, the following information will be retained by The Hotel for the necessary period for various purposes, including confirming the management duty of transactions, pursuant to related regulations and internal policy:

1. - Records of contracts or cancellation of contracts :Up to five years
2. - Records of payments and provision of services : Up to five years
3. - Records of customer dissatisfaction or disputes settlement : Up to three years

Destruction method

1. - Private information printed on paper : Pulverized or incinerated
2. - Private information stored in electronic files : Technically deleted in an unrecoverable manner

5. Consignment of collected private information

The hotel consigns the task of handling the following private information to an outside service provider for the provision of its services :

Homepage, PMS(Property Management System) and maintenance : Sanha IT

In order to ensure the protection of private information in consignment contracts, the hotel requires business partners to strictly adhere to directions regarding private information protection, clearly states its policy on prohibited uses of personal information and responsibility upon contingencies, and stores a copy of the relevant contract in both written and electronic form. Members will be notified of changes to such business partners through the Privacy Policy screen within the hotel’s website.

6. Links to Other Web Sites

In order to anticipate your needs, The Hotel provides links to other web sites for your convenience and information The Hotel is not responsible or liable for any content presented by or contained on any independent web site, including, but not limited to, any advertising claims or marketing practices.
Please note that while The Hotel will protect your information on The Hotel owned and operated web sites, we cannot control and will not be responsible for the privacy policies of third party web sites not controlled or authorized by The Hotel.
Third party web sites that are accessed through links on our web sites have separate privacy and data collection practices, and security measures.
We have no responsibility or liability for the practices, policies and security measures implemented by third parties on their web sites.
We encourage you to contact them to ask questions about their privacy practices, policies and security measures before disclosing any personally identifiable information.
We recommend that you review the privacy statements and policies of linked web sites to understand how those web sites collect, use and store information.

7. Private Information Manager and Private Information Department

1. The Hotel designates the following department and Private Information Manager in order to protect the private information of Members and resolve any dissatisfaction regarding personal information.
   1. - Private Information Department: Metro hotel Administration Team
   2. - Private Information Manager: Seunghwan Oh, Team Manager
   3. - Telephone No.: 82-2-2176-3121
   4. - E-Mail: osh6548@metrohotel.co.kr

8. Technical/institutional management of private information

1. The Hotel seeks the following technical measures to prevent loss, theft, leakage, alteration or damage and ensure safety of private information of Members:
   1. - All private user information is protected by a password, and important data are protected by an additional security function which encrypts or locks files of transmitted data.
   2. - The Hotel adopts the Secure Socket Layer which ensures safe transmission of private information on the network using encryption algorithms.
   3. - The Hotel uses a double firewall to block unpermitted access and prevent the leakage of private user information through hacking, and monitors outside intrusion 24 hours-a-day with the installation of an Intrusion Detection System on each server. The Hotel limits the number of staff authorized to handle private information, conducts training to emphasize the adherence of its principle, and immediately corrects any problems that may arise in this regard.
   4. - The Hotel is not liable for accidents caused by the users or situations resulting from the inherent dangers of the Internet.
   5. - b. In the case of the loss, leakage, alteration, or damage of private information as a result of mishandling by an internal manager or technical management problems, The Hotel will immediately notify the user, take appropriate measures and provide compensation.

9. Protection of private information of users under the age of 14

The Hotel, in principle, does not collect private information of users under the age of 14. Provided, however, if the collection of such information is deemed necessary, The Hotel will adhere to the related laws and notices.

10. Transmission of advertisement information

The Hotel will not transmit for-profit advertisement information. The Hotel will take the following measures in the subject title and content section of e-mails containing on-line marketing advertisement information, including product information, to assist the users’ recognition of such e-mails:

1. - E-mail subject title: All subject titles shall begin with “(Newsletter)” in English, followed by a brief description of the content of the e-mail.
2. - E-mail content section: All e-mails shall clearly contain the name, e-mail address, telephone number and address of the sender so as to enable the user to refuse further e-mail transmissions. Users will be informed in both Korean and English on how to reject such future e-mails.
3. - Information harmful to children/teenagers will contain the wording “(Adult Advertisement)”
4. - E-mails containing the following content in the form of signals, letters, videos or sound (including content that does not contain such direct expressions but may be easily understood by the recipient) will be indicated by the wording “(Adult Advertisement)” in the e-mail subject title.
   1. 1. Lascivious or obscene materials that could arouse sexual interest in children/teenagers (under the age of 19)
   2. 2. Materials that could stimulate fierce or criminal impulses in children/teenagers
   3. 3. Materials encouraging or beautifying all kinds of violence, including sexual violence, and abuse of drugs
   4. 4. Materials determined and notified as harmful material to children/teenagers
5. For-profit advertisement e-mails containing information on internet websites related to contents relevant to each of the above four clauses will be identified with the wording “(Adult Advertisement)” in the subject title of the e-mail.

11. Amendment of this Policy

Our Privacy Policy can be conveniently accessed from the first page of our website. When there is an amendment on the policies, we will make reasonable efforts to alert you to these changes when they occur on the website. We may need to update our Privacy Policy periodically to reflect changes in the types of information we collect. [Supplement] 1. This Privacy Policy is effective starting from 9th of Jan. 2012