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Privacy Policy

SafeDoc, Inc. (“SafeDoc,” “we,” “our,” or “us”) is committed to protecting your privacy and handling your Personal Data responsibly. “Personal Data” refers to information that can reasonably be linked, directly or indirectly, to an individual.

This Privacy Policy explains how SafeDoc collects, uses, shares, and protects Personal Data obtained through our websites, mobile applications, emails, social media channels, and other online or offline interactions (together, the **“Digital Properties”**). This includes situations where you receive a SafeDoc check-up or related service at one of our partner facilities.

Some of the information we process may be subject to additional privacy laws, such as state or federal health information regulations. In those cases, we comply with all applicable legal requirements.

We may revise this Privacy Policy periodically. Any changes become effective once posted, unless otherwise required by law. If a material update is required, we will notify you directly.

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1. Sources of Personal Data

We may collect Personal Data from a variety of sources, including:

A. Directly from you – for example, when you contact us through Digital Properties, create an account, sign up for offers or newsletters, place or customize an order, or interact with us at one of our partner clinics.

B. Automatically through technology – such as cookies or similar tracking tools when you interact with our Digital Properties. This may include data about your device, browsing behavior, and how you engage with our content.

C. From third parties – such as healthcare professionals at affiliated partner clinics, service providers, business partners, lead generators, social media platforms, or data vendors.

D. From public sources – such as publicly available websites or social profiles.

We may combine information from these sources to create a more complete understanding of your preferences and interactions with SafeDoc.

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2. Types of Personal Data We Collect

We may collect the following categories of Personal Data:

A. Identifiers – name, email, address, phone number, business contact information, account details, cookie IDs, and IP address.

B. Records and interactions – marketing and purchasing preferences, account settings, communication logs (chats, calls, emails), signatures, and descriptive details.

C. Demographic information – age, date of birth, gender, and similar details.

D. Commercial and financial information – purchase history, subscription details, payment information, delivery information, fraud checks, complaints, and related legal or transactional records.

E. Internet activity – browsing history, search history, and interactions with our Digital Properties (see “Cookies and Tracking Technologies” below).

F. Geolocation (non-precise) – approximate location based on IP address.

G. Sensory data – photographs (e.g., at events), audio recordings, or video recordings.

H. Professional information – job title, employer, professional credentials, affiliations, or specialties.

I. Education information.

J. Inferences – insights drawn from collected data to understand your interests, usage patterns, and communication preferences.

K. Sensitive Personal Data – SafeDoc processes sensitive personal information only in cases where there is the data subject’s separate consent or where such processing is required or permitted by law, in accordance with **Article 23 of the Personal Information Protection Act.

Sensitive personal information refers to data that may significantly infringe upon an individual’s privacy, including information related to beliefs or ideology, membership or withdrawal from labor unions or political parties, political opinions, health, sexual life, and other similar information.

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3. How We Use Personal Data

SafeDoc may use your Personal Data for the following purposes:

A. Service delivery

To provide and manage products and services you request, including:

- Processing orders, payments, and transactions
- Delivering healthcare and related services
- Providing customer service and responding to inquiries
- Verifying eligibility for programs or benefits
- Sending communications regarding your appointments, subscriptions, or services
- Hosting webinars or informational sessions

B. Internal business operations

For administrative and operational purposes, including:

- Maintaining user accounts and internal business records
- Enforcing company policies
- Conducting analysis and management reporting
- Budgeting, procurement, accounting, and auditing
- IT administration, network security, and system management

C. Research and development

To improve and expand our services by:

- Ensuring quality, safety, and performance
- Debugging and repairing system errors
- Designing and testing new products or services
- Measuring and improving the effectiveness of marketing campaigns

D. Legal, safety, and compliance

To comply with legal or regulatory obligations, including:

- Responding to government or law enforcement requests
- Pursuing legal rights or defending claims
- Ensuring health and safety (e.g., communicable disease management)
- Preventing fraud, malicious activity, or security breaches

E. Corporate transactions

If SafeDoc undergoes a merger, acquisition, asset sale, restructuring, or bankruptcy, your data may be transferred as part of that transaction.

F. Marketing and advertising

To provide relevant communications, including:

- Sending newsletters, surveys, promotions, or event invitations
- Delivering personalized advertising on SafeDoc platforms or third-party sites
- Analyzing how you interact with our emails or website content
- Building marketing or product audiences across devices and services

👉 You may opt out of marketing emails at any time using the unsubscribe link in the email or by contacting us (see Section 10: Contact Information).

Note: We may also use anonymized or aggregated data for any lawful purpose.

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4. Retention Period of Personal Information

SafeDoc retains and processes personal information within the retention and usage period prescribed by relevant laws, or within the period consented to by the data subject at the time of collection.

The specific retention and processing periods for each category of personal information are as follows:

1. Membership Registration and Management:

Until membership withdrawal.

However, in the following cases, information will be retained until the relevant reason no longer exists:

1. When an investigation or inquiry related to a violation of applicable laws is in progress — until the completion of such investigation or inquiry.
2. When any obligations or liabilities arising from the use of the website remain — until such obligations or liabilities are fully settled.
2. Provision of Goods or Services:

Until the completion of product/service delivery and payment/settlement.

However, in the following cases, data shall be retained for the periods specified below in accordance with the *Enforcement Decree of the Act on the Consumer Protection in Electronic Commerce, etc.:

- Records on contracts or subscription withdrawals: 5 years (Article 6(1)2)
- Records on payment and supply of goods: 5 years (Article 6(1)3)
- Records on consumer complaints or dispute resolution: 3 years (Article 6(1)4)
- Records on labeling or advertisements: 6 months (Article 6(1)1)
3. Retention of Communication Logs under Article 15-2(2) of the Protection of Communications Secrets Act:
- Computer communications, internet log data, and trace data of access points: 3 months

5. How We Disclose Personal Data

In accordance with **Article 17(1)(1) of the Personal Information Protection Act**, SafeDoc may share personal data with third parties **only to the minimum extent necessary** and **only with the consent of the data subject**.

**A. Affiliates** – Our parent companies, subsidiaries, and other corporate affiliates.

**B. Service providers** – Vendors who support us in delivering services, such as IT providers, data analytics companies, hosting services, payment processors, and event organizers.

**C. Professional advisors** – Accountants, lawyers, auditors, and consultants.

**D. Legal and regulatory authorities** – Government agencies, law enforcement, or courts, where disclosure is required to:

- Comply with laws and regulations
- Protect rights, property, or safety of SafeDoc, our users, or others
- Enforce our Terms of Service

**E. Corporate transactions** – In connection with a merger, acquisition, asset sale, restructuring, or bankruptcy.

**F. Business partners** – Such as marketing and advertising networks, social media platforms, cookie operators, data brokers, or other partners. Where required by law, we will obtain your consent before sharing data. Please review their privacy policies for details of their practices.

**G. With your consent** – Any other disclosure made with your express permission.

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## 6. Cookies and Other Tracking Technologies

Our Digital Properties, along with authorized third parties, use **cookies and other tracking tools** to collect information about you, your device, and your interactions with SafeDoc platforms. This section explains:

- The types of tracking technologies used,
- The purposes for which they are used,
- The kinds of information collected,
- How this information may be shared, and
- The choices available to you.

### A. Types of Cookies and Tracking Technologies

SafeDoc and third parties may use:

- **Cookies** – Small files placed on your device when you visit a website. Some last only during a browsing session, while others remain for multiple visits.
- **Pixels, web beacons, and tags** – Small snippets of code or transparent graphics embedded in pages to measure interactions and support marketing activities.
- **Session replay tools** – Technologies that record how you interact with our websites and forms, helping us troubleshoot issues and improve usability.
- **Embedded scripts and SDKs** – Tools that allow us to integrate applications, features, and interactive experiences into our platforms.

### B. Purposes for Using These Technologies

These tools are used to support SafeDoc’s operations and your experience, including:

- **Personalization** – Remembering your preferences and past activity to improve your experience.
- **Performance** – Monitoring and improving the speed and functionality of our websites.
- **Analytics** – Understanding how visitors use our Digital Properties. For example, SafeDoc uses **Google Analytics**, which may rely on cookies and tracking technologies. (See: [Google Privacy & Partners](https://www.google.com/policies/privacy/partners)).
- **Advertising** – Delivering tailored ads, measuring the effectiveness of campaigns, and conducting interest-based advertising across SafeDoc and third-party platforms.
- **Security** – Detecting and preventing fraudulent or malicious activity.

### C. Information Collected

Tracking technologies may collect:

- Device details (IP address, cookie ID, Ad ID, device ID, operating system, browser type)
- Location data (approximate or precise, depending on settings)
- Browsing and search history
- Information about how you interact with our websites (e.g., pages viewed, features used)

### D. Sharing of Information

We may allow certain third parties to collect or access information directly through these tools, including:

- Social media platforms
- Advertising and marketing networks
- Analytics providers
- Security and fraud prevention partners
- Service providers supporting SafeDoc operations

### E. Your Choices

- **Managing cookies** – Most browsers allow you to delete or block cookies. Instructions can be found in your browser’s Help menu. Please note that some features of our websites may not function properly if cookies are disabled.
- **Multiple devices** – You may need to repeat cookie settings for each device or browser you use.
- **Interest-based advertising** – Opting out of interest-based ads does not remove all advertising, only targeted advertising.
- **Do Not Track (DNT)** – Some browsers offer a DNT feature. At this time, SafeDoc does **not** respond to DNT signals.

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## 7. Your Preferences

You may request corrections or updates to your Personal Data by contacting us (see Section 10: **Contact Information**).

You can also opt out of receiving promotional emails:

- By using the “unsubscribe” link included in our emails,
- By adjusting your preferences in your SafeDoc account settings (if applicable), or
- By contacting us directly to have your details removed from our marketing list.

Please note: opting out of promotional communications does not affect operational emails related to your account, appointments, or transactions.

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## 8. Data Security and Retention

**Security**

SafeDoc applies reasonable technical, administrative, and organizational measures to safeguard your Personal Data from accidental or unlawful destruction, loss, unauthorized disclosure, or misuse. However, no online system can guarantee absolute security, and we encourage you to take precautions when sharing information online.

**Retention**

We retain Personal Data for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer period is required by law. This may include:

- Delivering services and managing your account,
- Maintaining our business relationship,
- Meeting legal and regulatory obligations,
- Improving our services over time, and
- Ensuring ongoing safety and compliance.

Even after your relationship with SafeDoc ends, we may keep certain records for legitimate business purposes (e.g., contractual obligations, recordkeeping, or to simplify future onboarding). If you wish to know more about applicable retention periods, please contact us (see Section 10).

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## **9. Procedures and Methods for Destroying Personal Information**

SafeDoc promptly destroys personal information when it becomes unnecessary, such as upon the expiration of the retention period or when the purpose of processing has been achieved.

If personal information must be retained under other applicable laws even after the consented retention period has expired or the processing purpose has been fulfilled, SafeDoc will **store such information separately** by transferring it to a separate database (DB) or storing it in a different location.

**Procedures and Methods for Destruction:**

• **Destruction Procedure:**

When a reason for destruction arises, SafeDoc selects the personal information subject to destruction and destroys it upon approval from the company’s **Personal Information Protection Officer**.

- **Destruction Method:**

Personal information stored in **electronic files** is permanently deleted in a way that prevents recovery or reconstruction.

Personal information recorded or stored in **paper documents** is destroyed by shredding or incineration.

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## **10. Measures to Ensure the Security of Personal Information**

SafeDoc takes the following measures to ensure the security of personal information:

A. **Administrative Measures:** Establishment and implementation of internal management plans, regular employee training, and operation of a dedicated privacy management team.

B. **Technical Measures:** Management of access rights to personal information processing systems, installation of access control systems and other protective measures, separation from external internet networks, encryption of personal information, retention and monitoring of access logs, installation and updates of security programs, and regular vulnerability checks and improvements to information systems.

C. **Physical Measures:** Access control for computer rooms and data storage areas, secure storage of documents and backup media in locked facilities, disaster prevention and response measures, and control of the transfer and use of external storage devices.

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## **11. Rights and Obligations of Data Subjects and Their Legal Representatives, and How to Exercise Them**

A. The data subject may, at any time, request SafeDoc to **access, transfer, correct, delete, suspend processing, or withdraw consent** regarding their personal information (collectively referred to as “exercise of rights”).

※ For children under the age of 14, such rights must be exercised by their **legal representative**.

For minors aged 14 or older, the data subject may exercise their rights directly or through their legal representative.

B. The exercise of rights may be made to SafeDoc pursuant to **Article 41(1) of the Enforcement Decree of the Personal Information Protection Act** via **written request, phone, email, fax, or the internet**, and SafeDoc will take prompt action in response.

C. Rights may also be exercised through an **authorized representative**, such as a legal guardian or delegate. In such cases, a **power of attorney** in the form prescribed in **Appendix 11 of the “Guidelines on Personal Information Processing Methods”** must be submitted.

D. The right to request access to or suspension of personal information processing may be **restricted** under **Articles 35(4)** and **37(2)** of the Personal Information Protection Act.

E. If other laws explicitly require the collection of certain personal information, the data subject may **not request its deletion**.

F. SafeDoc verifies that the individual making the request is the **data subject or a duly authorized representative** before processing such a request.

## 12. Children’s Privacy

SafeDoc’s Digital Properties are intended for adults aged **18 and older**. We do not knowingly collect Personal Data from individuals under 18.

If you believe we may have inadvertently collected information from a minor, please notify us (see Section 10). We will promptly delete such information.

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## 13. External Links

Our Digital Properties may contain links to external websites or third-party services (including advertisements or sponsor content). SafeDoc is **not responsible** for the privacy practices or data collection policies of those services. Please review their privacy notices directly for more information.

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## **14. Personal Information Protection Officer and Contact for Inquiries or Complaints**

A. SafeDoc is responsible for overseeing all matters related to the processing of personal information and has designated the following **Personal Information Protection Officer** to handle complaints, inquiries, and requests for relief from data subjects concerning personal information processing.

▶ **Personal Information Protection Officer**

Name: **Yesol Lee**

Position: **CEO**

Contact: **Tel. +82 2-2088-8677 / Email. global@safedoc.kr / Fax. 070-7610-8677**

▶ **Department in Charge of Personal Information Protection**

Department: **Business Planning Team**

Contact: **Tel. +82 2-2088-8677 / Email. global@safedoc.kr / Fax. 070-7610-8677**

B. Data subjects may contact the **Personal Information Protection Officer** or the **Personal Information Protection Department** for any inquiries, complaints, or requests for relief regarding personal information that may arise while using SafeDoc’s services (or business operations).

SafeDoc will respond to and handle such inquiries **without undue delay**.

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## **15. Changes to This Privacy Policy**

This Privacy Policy is effective as of **October 27, 2025**.