2. Business Model Legality/ Regulatory Approval Investigation

Q12 (Use of Personal Information and Privacy Policies)

When we have users register in an Internet-based service targeting individuals, we heard that we must notify the users of the purpose of our use of personal information. Is the posting of our privacy policy on our site sufficient?

Under the Act on the Protection of Personal Information, when you obtain personal information from a person through entering into a contract with that person, either in the contract itself or through electronic means, you must specify the purpose of use to the person beforehand. For Internet-based services, this should be done in a noticeable way. For example, you could display the purpose of use on the screen before the person can click on the submit button to send personal information. Or you can include a link to the page that includes the purpose of use. Accordingly, if your purpose of use is included in your privacy policy, one idea is to noticeably display a link to the privacy policy on the page where the user inputs personal information.

(Posted: January 27, 2012)