Russell Investments Korea Limited Privacy Policy (for Public Disclosure)

Russell Investments Korea Limited (the "Company") provides the following Privacy Policy (this "Privacy Policy") in an effort to protect the personal information and rights of individuals who have dealings with the Company, such as customers or employees ("information principals") and to facilitate in addressing the grievances of such persons in relation to their personal information, as required under the Personal Information Protection Act (the "PIPA").

Definitions under the PIPA and Application

"Personal information" is broadly defined to refer to information pertaining to a living individual which contains information identifying a specific person by a name, resident registration number, or in the form of an image, etc. (including information that does not, by itself, make it possible to identify a specific person, but that enables identification of a person easily when combined with other information).

"Manage Personal Information" means to collect, create, link, connect, record, save, hold, process, edit, search, output, correct, recover, use, provide, disclose, destroy personal information, and other acts similar thereto.

When the Company collects personal information under a Discretionary Investment Management or Investment Advisory contract with customers or when it collects personal information of its employees, it will be regarded as a Personal Information Manager and will be required to comply with the PIPA.

Article 1 (Purposes of Processing Personal Information)

The Company may process personal information for the following purposes. Unless otherwise set forth in any applicable laws and regulations, personal information will not be used for any purposes other than as specified below. If there is any change to the purpose underlying use of principal's personal information, the Company will implement any and all necessary measures, including obtaining a separate consent, pursuant to the PIPA.

  1. Establishment and maintenance of financial transactional and customer relationships
    Decision on whether to establish transactional relationships; performance of customer due diligence, establishment, maintenance, performance and management of transactional relationships; and investigation of financial accident, dispute resolution.
  2. Guide on products and services
    Promotion of products and services; provision of convenience to customers such as providing promotional goods and holding customer appreciation events; and customer satisfaction survey.
  3. Civil complaints and consultations
    Consultation and handling of civil complaints
  4. Performance of the Company's legal and administrative obligations
    Performance of the Company's legal and administrative obligations, including (i) report and payment of various taxes such as corporate tax, value-added tax and (ii) issuance and delivery of payment receipt and tax invoice and (iii) provision to regulators as required under the Company's legal/regulatory obligations.
  5. Confirmation of visitors, prevention of crimes and procurement of contact information
  6. Hiring of employee candidates, managing the Company's associates and relevant administrative functions

Article 2 (Period of Processing and Retention of Personal Information)

In principle, the Company shall retain and use personal information until the purposes for processing such personal information are accomplished. When such purposes are accomplished, the Company will immediately destroy such information, unless applicable laws and regulations require the Company to preserve such personal information.

Article 3 (Provision of Personal Information to a Third Party)

In principle, the Company shall process personal information within the scope specified in Article 1 of this Privacy Policy. Therefore, the Company will neither process such personal information beyond the original scope nor provide such personal information to a third party without prior consent of the relevant information principals, except for the following cases:

  1. If the relevant information principals have provided their prior consent with regard to the provision and disclosure of personal information to a third party.

  2. If it is required or permitted to provide personal information to a third party under applicable laws and regulations1, etc.

Personal information that is provided to third party recipients by the Company is summarized as follows:

Recipient(Contact Information) Recipients' Purposes of Use Transferred Items Recipient's Period of Retention and Use

Related body corporates of the Company Currently these affiliates are:

  • Frank Russell Company
  • Russell Implementation Services Inc.
  • Russell Investment Management Company
  • Russell Investment Management Ltd
  • Russell Investment Group Private Limited
  • Russell Investments Ireland Limited
  • Russell Implementation Services Limited
  • Russell Investments Limited
  • Russell Investments Japan Co. Ltd
  • London Stock Exchange Group plc
  • LSEG US Holdco, Inc.

To assist/enable the Company to provide you with its services or information about its services.

For purposes related to the purpose for which we obtained the information.

Customer records
Employee records

Same as that which is applicable to the Company.

Potential acquirer of the Company's business

To perform due diligence on the Company

Customer records Employee records

[*]

1In addition to the recipients listed above, regulatory authorities, courts and tribunals may from time to time receive personal information where they require such information from the Company.

Article 4 (Delegation of Personal Information Processing Services)

The Company delegates personal information processing services as follows and will notify any changes in the delegatees or the details of delegated services through this Privacy Policy.

Delegatee Details of Delegated Services

Related body corporates of the Company (per Article 3)

Business support services including Finance, Human Resources, Information Technology, Internal Audit, Legal, Compliance and Risk Management.

KIM & CHANG

Employee payroll services

JUNGJIN LLC

Accounting and regulatory filing services

SAMIL PWC

Internal Audit and Accounting


Article 5 (Rights and Obligations of Information Principals and Method of Exercise Thereof)

  • Pursuant to the provisions of applicable laws, including the PIPA, information principals may exercise their rights with regard to protection of personal information, including the right to request to the Company to give access to, correct, delete or suspend the handling of their personal information.
  • Exercise of rights under Paragraph1 above may also be performed through legal representatives or delegatees of relevant information principals. Provided, however, that in such case the information principal shall provide the Company with the power of attorney prepared in accordance with the Enforcement Rules of the PIPA.
  • With regard to the exercise of rights by information principals, the Company will immediately take necessary actions in compliance with all applicable laws and regulations, including the PIPA.

Article 6 (Items of Personal Information to be Processed)

Items of personal information that may be processed by the Company are as follows:

  • Account number and license number at financial institutions such as bank or securities company, gender, photo, facsimile number, major, position and title and school name.
  • Name, name of relevant institution, e-mail address, phone number, address, work experiences and educational background of journalists.
  • Name, name of related institutions, address, phone number, e-mail address, facsimile number of officers and employees of relevant associations and organizations, including the Korea Financial Investment Association.
  • (Company) name, telephone number, mobile phone number, facsimile number, e-mail address, business registration number, account information at financial institutions (e.g., bank account numbers), work experience, qualifications of contract counterparties (including officers and employees thereof) such as vendors, customers, marketing agencies, delivery/transportation companies and professional market survey institutions.
  • Name, name of relevant institution or company, telephone number, vehicle number and address of the Company's visitors.
  • Name, picture, gender, a resident registration number, telephone number, mobile phone number, address, e-mail address, educational background, history of military service, marital status and work experiences of the Company's associates.
  • Name, picture, gender, date of birth, telephone number, mobile phone number, address, e-mail address, educational background, history of military service, marital status and work experiences of employee candidates.

The Company does not request or keep health information from employee candidates or from the Company's associates.

Article 7 (Destruction of Personal Information)

  • In principle, the Company will immediately destroy personal information when such personal information is no longer necessary, including when the purposes of processing such personal information are accomplished.
  • When the Company destroys personal information, it will implement measures to ensure that the information is not restored or regenerated.
  • If the Company must retain personal information instead of destroying it, the Company will segregate such personal information and manage it separately from other personal information.
  • If the personal information that must be destroyed is in the form of an electronic file, the Company will permanently delete such information in an irrevocable manner. Any other document, printout, letter and other recorded media will be destroyed by incinerating or shredding them into pieces.

Article 8 (Measures to Ensure Safety of Personal Information)

The Company takes the following technical, managerial and physical actions it deems necessary to ensure safety of personal information in accordance with Article 29 of the PIPA.

  • Managerial actions: establishment and implementation of an internal management plan, regular personal information protection trainings to employees, etc.
  • Technical actions: management of access rights to personal information processing system, etc., installation of access control system, encryption of unique identification information, installation of security programs, etc.
  • Physical actions: control access to personal information storage facilities, such as the computer room, data room, etc.

Article 9 (Amendment to this Privacy Policy)

This Privacy Policy may be subject to changes in accordance with any applicable laws, regulations, guidelines and its internal policies, and the Company will notify such changes in the manner required under applicable laws and regulations.

Article 10 (Collection of Opinions and Handling of Complaints)

Information principals may forward matters relating to inquiries, the handling of complaints, remedies for damages concerning the protection of personal information to the chief privacy officer or the department in charge. The Company will provide a prompt and sufficient response with regard to the complaint of the information principals.

Chief Privacy Officer

Name and Title: Yuseok Kim, Representative Director
Telephone Number: 82-2-6137-6900
E-mail Address: ykim@russellinvestments.com

Personal Information Protection Department

Responsible Person: Soojin Keum
Telephone Number: 82-2-6137-6906
E-mail Address: skeum@russellinvestments.com

Article 11 (Request for Access to Personal Information)

Information principals may request access to personal information to the following department, pursuant to Article 35 of the PIPA. The Company will promptly handle the information principals' request for access to such personal information.

Department Responsible for Receipt and Handling of Request for Access to Personal Information

Department Name: Russell Investments Korea Limited
Responsible Person: Keum Soojin
Contact Information :
Telephone Number 82-2-6137-6906,
E-mail Address : skeum@russellinvestments.com,
Fax Number : 82-2-6137-6999

Article 12 (Methods of Seeking Remedy for Infringement of Rights)

Information principals may seek remedies for damages, consultation, etc. regarding an infringement of personal information to the following institutions.

The following institutions are operated separately from the Company. Information principals may contact such institutions if they are not satisfied with the Company's direct handling of their complaints regarding their personal information, the remedy given or if they believe more specific help is necessary.

Call Center for Personal Information Infringement (of Korea Internet Security Agency)

  • Responsible Business: report and consultation regarding personal information infringement accidents.
  • Website: privacy.kisa.or.kr
  • Telephone Number: (without local number) 118
  • Address: Call Center for Personal Information Infringement, Korea Internet Security Agency, 135, Jungdae-ro, Songpa-gu, Seoul (138-950)

Personal Information Dispute Mediation Committee (of Korea Internet Security Agency)

  • Responsible Business: application for dispute mediation of personal information and group dispute mediation (civil resolution).
  • Website: privacy.kisa.or.kr
  • Telephone Number: (without local number) 118
  • Address: Call Center for Personal Information Infringement, Korea Internet Security Agency, 135, Jungdae-ro, Songpa-gu, Seoul (138-950)

Cybercrime Investigation Department of the Prosecution Service: 02-3480-3573 (www.spo.go.kr)

Cyber Terrorism Response Center of the National Police Agency: 1566-0112 (www.netan.go.kr)


Addendum

This Privacy Policy shall be effective as of 20th July 2015.

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