This Seegene Data Protection Policy (“Policy”) explains how Seegene, Inc. and its subsidiaries and affiliates (collectively, “Seegene”) handle and manage personal data.

The Controller

The controller of your personal data is Seegene, Inc., which provides support with any of your data privacy-related questions, comments, concerns, or complaints. If you wish to exercise your rights in relation to data privacy, or if you have any questions or request with respect to our Policy, please contact us at dataprotection@seegene.com.

Purpose and Basis for Seegene’s Use of Personal Data

Generally, you do not have to provide your personal data in order to access the website. However, if you make an inquiry to us via the website, we may collect your personal data that you provide to us, such as your name, email address, phone number, nationality, the company or institute that you work for, your title and communication with Seegene. We use this information to efficiently process and respond to your inquiries, which is in our legitimate interest as a business entity.

We may process your name and email address to send you our newsletter or useful information regarding our online and offline events, marketing communications, and other helpful information, or to conduct marketing activities. Where required by applicable laws, we will obtain your prior consent before processing your personal data for this purpose. Please also note that, depending on the applicable laws, we may not need to obtain your prior consent before conducting any activities above, especially if they are in our legitimate interest after balancing the interest of the affected parties and depending on the channel through which we conduct the above activities (i.e., email, SMS, phone, post, etc.).

Our website may automatically collect and process technical information without personal identifiers, such as your IP address, access time, pages viewed, URLs clicked on to maintain (especially for security reasons), improve, and evaluate the performance of our website for our legitimate business interest.

In some cases, we may remove your personal identifiers from the data and maintain and manage them in an aggregated form. We may use and process it to generate statistics for our legitimate business interest in improving our website, products, and services.

Transfer and Disclosure of Personal Data

Seegene will not sell or rent your personal data to any third party for the third party’s independent marketing or business operation without obtaining your prior consent.

Seegene may, however, transfer your personal data to:

• Seegene subsidiaries or affiliates for the same purpose as Seegene’s (The list of Seegene subsidiaries and affiliates is available at http://www.seegene.com/global_networks);
• Courts, arbitration bodies, law enforcement authorities, regulators, or attorneys when it is necessary for Seegene to comply with the law, or for the establishment, exercise, or defense of its rights or legal claims; and
• Third parties providing the services below in the table to Seegene, which processes your personal data only for the purpose of providing the designated services (e.g., hosting or IT maintenance/support services).
  
  

  Consignee	Purpose of consignment	Items of personal data used by Seegene or provided to Consignee
  Midas Information Technology Co., Ltd	Recruiting and processing job applications.	information required for job applications, such as name, telephone number, mobile number, address, date of birth, work experience, educational background, etc.
  S-1 Corporation	management of closed-circuit television	video images taken via closed-circuit television installed for the purposes of fire prevention and facility safety

Any personal data that you made publicly available on our website may be globally accessible by any other registered users of our website.

Retention Periods

Unless indicated otherwise, at the time of the collection of your personal data (e.g. in the form completed by you), we will dispose of your personal data

• once it becomes no longer necessary for the purposes for collecting or processing them, or
• to comply with our legal obligations (e.g. retention obligations under tax or other relevant laws)

Your Rights

Under the appliable data protection laws, you have the rights to access or rectify your personal data. To exercise your rights, please contact us at dataprotection@seegene.com.

• If you reside in the European Economic Area (“EEA”)

  If you reside in the EEA and your personal data is covered by the EU General Data Protection Regulation (“GDPR”), subject to the limitations and exceptions provided in the applicable law, you have the rights provided under the Articles 15, 16, 17, 18, 20, 21 of the GDPR:

  • The right to obtain from Seegene a confirmation as to whether your personal data is being processed, and if so, request for access to your personal data;
  • The right to rectify your personal data that is inaccurate;
  • The right to request Seegene for the erasure of your personal data;
  • The right to restrict the processing of your personal data;
  • The right to object to the processing of your personal data for direct marketing or for any other reason relating to your particular situation;
  • The right to data portability (i.e., the right to receive your personal data in a structured, commonly used and machine-readable format and to transmit those data to another controller);
  • The right to withdraw your consent, if applicable. The withdrawal of the consent does not affect the lawfulness of processing your personal data based on your consent provided prior to the withdrawal. Once you withdraw your consent, Seegene may further process your personal data only if there is any other legal ground for Seegene to do so; and
  • The right to lodge a complaint with the responsible supervisory authority if you believe that our data processing is in breach of the GDPR.

• If you are a California resident:

  • California residents are entitled to, once a year and free of charge, request and obtain certain information regarding our disclosure of your personal data to third parties for their direct marketing purposes in the immediately preceding calendar year (e.g., requests made in 2020 will receive information regarding the disclosure made in 2019). We comply with this law by giving you an option to object to our disclosure of your personal data to third parties for their direct marketing purposes. To make such a request, free of charge, please send us an email to dataprotection@seegene.com. We may need additional information to process your request.

Cookies

When you visit our website, certain information is stored on your terminal device (e.g., your computer) in the form of a “cookie.” Cookies are small files that are stored on your terminal device and save certain settings and data to exchange with our website via your browser. For example, cookies enable us to tailor a website to better match your interests or to store your password so that you do not have to re-enter your password every time. Without cookies, certain functions of our website may not work properly.

• First-Party Cookies: cookies set by our website directly
• Cookies that are essential for our website to function properly:
  • Cookies providing security while conducting activities that the users have requested for, which is essential for complying with the security requirements under the applicable laws
  • Cookies ensuring that your content page loads quickly and effectively by distributing the workload among the computers
• Cookies that are necessary for us to deliver a better user experience: A number of our pages use these cookies to remember the followings in order to enhance the functionality of our website:
  • Your display preferences such as contrast color settings or font size;
  • Your language settings;
  • Your password so that you do not have to re-enter it every time;
  • Whether you have already replied to our survey pop-ups (e.g., asking whether the contents on the website were helpful or not) so you do not see them again; and
  • Whether you have agreed (or not) to our use of cookies on this website.
• Cookies that are necessary to enhance the performance of the website, including for website analysis:
  • The “Matomo Analytics” collects information about visitors’ behavior on our website by storing information, such as the pages you visit, your dwell time, the route through which you have accessed our website, and so on. This data is collected via a JavaScript tag in the pages of our website and is not tied to your personal information.
  • Our website uses a web analysis service called “Bizspring Logger” provided by BizSpring, Inc. (“Bizspring”). The Bizspring web log analysis allows our website to analyze your activities on our website by using certain cookies only in accordance with your consent. Bizspring evaluates your use of our websites, creates a website activity report, and provides any other services related to the users’ activities on our website.
• How to control or deactivate cookies: You may control or deactivate any cookies as you wish. You can delete all cookies that are already on your computer, and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site, and some services and functionalities may not work. Below you will find the links providing detailed information regarding the cookies in commonly used browsers:
  • Mozilla Firefox
  • Internet Explorer
  • Google Chrome
  • Safari

Web Beacon

The Web Beacon(also known as, Web bug, pixel tag, clear GIF, or e-mail tracking) is an imbedded image used to monitor the behaviors of a user, which helps analyzing the effectiveness of the website. When you agree to provide your personal information to Web Beacon, Web Beacon uses the information for tracking purposes only.

Third-Party Service

Our website may provide services based on third-party applications and content tools, such as Google maps. These third parties may automatically receive unique types of information every time you interact with us on our website using such third-party applications and tools. Regarding the data processing conducted by third parties and their services that are not controlled by us, please refer to the privacy policies of such third parties.

“Do Not Track” signals

Seegene does not support “Do Not Track” browser settings and does not currently participate in any “Do Not Track” frameworks that would allow Seegene to respond to signals or any other mechanisms from you regarding the collection of your personal or non-personally identifiable information. If you activate “Do Not Track,” Seegene does not collect your Cookies.

Seegene maintains reasonable technical and organizational measures with our best efforts to protect your personal data from loss, manipulation, unauthorized access, destruction, leakage, etc. However, there is always a risk of your personal data being disclosed to unauthorized third parties or compromised in some other way. Therefore, please note that you are also responsible for ensuring that your computer or any other device you are using is adequately secured and protected against malicious software and computer viruses. No data transmission over the internet can be guaranteed to be 100% secure.

Seegene reserves the right to amend and update this Policy without prior notice in order to reflect legal and regulatory changes, technological advances, and good business practice. If Seegene makes any amendment to the Policy, Seegene will update the Policy on the website, reflecting those changes and specifying the effective date of the updated Policy. Therefore, we recommend you to review this Policy regularly for any changes made to the Policy.

This amendment of the Policy is effective as of February, 2020.