Article 1 [General Provisions]

MusicFlat Co., Ltd. (the “Company”) operates the SellBuyMusic website (the “Site”). The Company makes best efforts to protect customers’ personal information and complies with the Personal Information Protection Act and other applicable laws and regulations. This Privacy Policy provides information on the categories of personal information the Company collects, purposes of use, retention period, and protection measures.

Article 2 [Purpose of Collection and Use of Personal Information]

• The Site provides access to the Company’s content service (the “Service”) enabling users to browse, purchase (“Payment”), and download “Content,” and aims to process payments for paid services and provide customer support.
• Accordingly, the Company collects and uses personal information within the following purposes.
• 1) Membership Registration and Management
• - Identifying members and confirming intent to register
• - Identity verification and personal identification for service use
• - Providing notices, guidance, and announcements related to service use
• - Preventing fraudulent use and detecting abnormal use
• 2) Service Provision and Operation of Paid Services (Payment/Settlement)
• - Providing content and managing download history
• - Providing paid services, confirming purchase history, and processing payments
• - Handling e-commerce related tasks such as refunds, withdrawal of subscription (cooling-off), and settlements
• - Handling dispute responses and usage restriction measures
• 3) Handling Customer Inquiries and Support
• - Receiving, confirming, and responding to inquiries
• - Handling complaints and responding to dispute mediation
• 4) Marketing and Service Improvement
• - Analyzing access frequency and usage statistics
• - Improving service quality and developing new features
• - Providing personalized services and using for advertising (separate consent will be obtained when required by law)

Article 3 [Items of Personal Information Collected]

• 1) Items Collected
• (1) During Sign-up and Service Use
• - Required: Email (ID), password, name (or nickname)
• - Optional: Additional profile information (only if separate input fields are provided)
• (2) During Use of Paid Services (Payments)
• - Payment records (payment method, payment date/time, payment amount, product/subscription information, approval/cancellation/refund history, etc.)
• * Sensitive payment data such as card numbers may be processed and stored by the payment gateway (PG) and may not be stored directly by the Company.
• (3) Automatically Collected During Service Use
• - Service usage records, access logs, IP address, cookies, and device/browser information (scope may vary depending on settings)
• * The Company does not collect resident registration numbers as a rule. The Service is not intended for children under 14 and therefore does not collect legal guardian information or personal information of children under 14.
• 2) Methods of Collection
• - Website (sign-up, service use, payments, etc.)
• - Customer support channels (email, ChannelTalk, etc.)
• - Automatically generated and collected during service use

Article 4 [Age Requirement and Protection of Children’s Personal Information]

• The Company provides the Service to users aged 14 or older.
• Children under the age of 14 may not sign up for or use the Site, and the Company does not collect personal information of children under 14.
• Users must confirm that they are at least 14 years old when registering. The Company is not responsible for issues arising from false age information provided by users.

Article 5 [Retention and Use Period of Personal Information]

• The Company destroys personal information without delay once the purpose of collection and use has been achieved. However, if retention is required under applicable laws, the Company retains the information for the required period and then deletes it.
• - Records on contracts or withdrawal of subscription (cooling-off): 5 years (Act on Consumer Protection in Electronic Commerce, etc.)
• - Records on payments and supply of goods, etc.: 5 years (Act on Consumer Protection in Electronic Commerce, etc.)
• - Records on consumer complaints or dispute resolution: 3 years (Act on Consumer Protection in Electronic Commerce, etc.)
• * If preservation is required under other applicable laws, the Company may retain information for the period prescribed by such laws.

Article 6 [Procedure and Method of Destruction]

• 1) Procedure
• Personal information is transferred to a separate database after the purpose is achieved, stored for a certain period in accordance with internal policies and applicable laws, and then destroyed.
• 2) Method
• - Electronic files: Deleted using technical methods that make recovery impossible
• - Paper documents: Destroyed by shredding or incineration

Article 7 [Provision to Third Parties]

• In principle, the Company does not provide users’ personal information to third parties. Exceptions apply only in the following cases:
• - When the user has provided prior consent
• - When disclosure is required by applicable laws

Article 8 [Outsourcing of Personal Information Processing]

In principle, the Company does not outsource the processing of personal information to external providers without the user’s consent. If outsourcing becomes necessary in the future, the Company will provide prior notice of the subcontractor and the scope of outsourced work and obtain consent when required.

Article 9 [Users’ Rights and How to Exercise Them]

• Users may access or correct their personal information at any time and may request account deletion (membership withdrawal). Users can do so through the “Edit Member Information” or “Withdraw Membership” menu, or by contacting the person in charge of personal information protection.
• Person in charge of personal information management: Minseok Kim
• Phone: 02-542-7001
• Email: help@sellbuymusic.com

Article 10 [Use of Cookies]

• The Company may use cookies to provide personalized services. Users may refuse cookie storage through web browser settings. However, refusing cookies may make it difficult to provide certain services.
• How to change cookie settings (e.g., Internet Explorer)
• Tools → Internet Options → Privacy

Article 11 [Technical and Administrative Measures]

• The Company implements the following measures to protect personal information:
• - Encryption of personal information and access control
• - Operation of security programs to prevent hacking and malware
• - Minimization of personnel handling personal information and 강화 training
• - Management and retention of access logs to personal information processing systems

Article 12 [Contact for Privacy Inquiries]

• The Company makes best efforts to protect users’ personal information. For privacy-related inquiries or complaints, the following contact points are available.
• Privacy Officer
• Name: Minseok Kim
• Phone: 02-542-7001
• Email: help@sellbuymusic.com
• Reporting and Consultation Agencies for Personal Information Infringement
• Supreme Prosecutors’ Office Cyber Investigation Division: cybercid.spo.go.kr
• National Police Agency Cybercrime Reporting Center: ecrm.police.go.kr

Addendum (Effective Date)

This Privacy Policy shall take effect on January 16, 2026.