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.

Privacy statement for russellinvestments.com

Russell Investments has a firm commitment to privacy. The following discloses our information gathering and dissemination practices for this Web site: russellinvestments.com. The Privacy and Security notice (PDF) of Russell Investments covers these issues in further detail.

We use your IP address to help diagnose problems with our server, and to administer our Web site. Your IP address is used to gather broad demographic information. We use cookies to deliver content specific to your interests, to save your password so you don't have to re-enter it each time you visit our site, and for other purposes.

Our site's registration forms and surveys request users to give us contact information (e.g. their name, phone number, e-mail and mailing address) and limited financial information (e.g. assets under management and investible assets). We use contact information to send the user requested information about our company. The information is also used to contact the visitor when necessary. Users may opt-out of receiving future mailings; see the choice/opt-out section below. The data collected is used to tailor the visitor's experience at our site, showing them content that we think they might be interested in, and displaying the content according to their preferences.

This site contains links to other sites. Russell Investments is not responsible for the privacy practices or the content of such Web sites.

Security

This site has security measures in place to protect the loss, misuse and alteration of the information under our control.

Choice/opt-out

Our site provides users the opportunity to opt-out of receiving communications from us at the point where we request information about the visitor.

This site gives users the following options for removing their information from our database to stop future communications or to no longer receive our service.

You can send e-mail to webmaster@russellinvestments.com.

Correct/update

This site gives users the following options for changing and modifying information previously provided.

You can send e-mail to webmaster@russellinvestments.com.

Cookies

By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set or to reject all cookies. However, you should be aware that if cookies are rejected you will not be able to use some of the online services provided by Russell Investments. For more information on how to configure your browser preferences, please refer to the user guides:

A full list of all cookies Russell Investments uses can be found here .

Cookies for storing your preferences

We use various cookies to store some details you enter and choices you make so that we do not have to ask you for them every time you visit a page that needs them.

Cookie name Purpose
ASP.NET_SessionId,
ASPSESSIONID********
Keeps a record of your current Russell Investments session so that we can provide consistent functionality across the site.  It expires when you logout, close your browser or if you clear your cache of browsing history.

ASPSESSIONID******** will generate a random set of 8 letters that will change with every session. 
ri.com This will remember your preferences from the russellinvestments.com so your preferences will persist on future visits. These preferences include: country selection; audience type selection; acceptance of cookies.
website#lang This will remember your language preference from the russellinvestments.com so your preference will persist on future visits.

Cookies for improving service by measuring traffic

We use Google Analytics, a web analytics service provided by Google, in order to find out how visitors interact with Russell Investments so we can improve it. Information is collected anonymously and website trends are reported without identifying individual visitors.

Cookie name Purpose
__utma Keeps track of the number of times a visitor has been to the site, when their first visit was, and when their last visit occurred. It expires after two years.
__utmb and __utmc The B and C cookies work together to calculate how long a visit takes.

__utmb takes a timestamp of the exact moment in time when a visitor enters a site, while __utmc takes a timestamp of the exact moment in time when a visitor leaves a site.

__utmc has no way of knowing when a user closes their browser or leaves a website, so it waits 30 minutes for another pageview to happen, and if it doesn't, it expires.
__utmz Keeps track of where the visitor came from, what search engine was used, what link was clicked on, what keyword was used, and where they were in the world when the website was accessed.
_ga Used by Google to distinguish users.
_gac Used by Google to store campaign information for AdWords.
_gat_*** This cookie is used with Google Universal Analytics. This cookie is used to monitor and track visitors behavior on the site anonymously.
auto Used by Google to distinguish users.
ELOQUA, ELQSTATUS These cookies are used to collect information about how visitors use our site. This information is used to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. If you click through to our website from an email sent by Eloqua, we are subsequently able to identify the pages you visit on russellinvestments.com. This information is stored securely in Eloqua and never, under any circumstances, supplied to third parties.
VISITOR_INFO1_LIVE, PREF, YSC We use YouTube to embed videos. The VISITOR_INFO1_LIVE cookie attempts to estimate your bandwidth. The PREF cookie may be used by YouTube to store session preferences that relate to your activity when watching the embedded videos. These cookies don't gather information that identifies a user.
SC_ANALYTICS_GLOBAL_COOKIE This cookie is used to identify repeat visits from a single user
6siuuid,  _gd_svisitor, _gd_visitor This cookie is used to monitor and track visitors behavior on the site anonymously.  It collects information from visitors such as Internet protocol address, cookie identifiers, mobile advertising identifiers, and other device identifiers that are automatically assigned to the computer or device of a visitor as well as site usage information such as pages visited, the date and time of the visit, the amount of time spent on each page and other behaviors on the site. Russel Investment could use this information for account marketing to prospective customers, including to track conversions and serve digital ads.
nmstat This cookie is used to help record the visitor’s use of the website. It is used to collect statistics about site usage such as when the visitor last visited the site. This information is then used to improve the user experience on the website. This Siteimprove Analytics cookie contains a randomly generated ID used to recognize the browser when a visitor reads a page. The cookie contains no personal information and is used only for web analytics.
siteimproveses This cookie is used purely to track the sequence of pages a visitor looks at during a visit to the site. This information can be used to reduce user journeys, and enable visitors to find relevant information quicker.
sz-feedback-should-hide This cookie is used to hide/close a feedback widget for specific sessions (visits). It is set when a visitor clicks a button in the feedback widget which indicates they don't wish to see the widget again. The cookie contains no personal information and is used only for web analytics. It simply contains the text 'true' when it is set.
_cfduid The "__cfduid" cookie is set by the CloudFlare service to identify trusted web traffic. It does not correspond to any user id in the web application, nor does the cookie store any personally identifiable information.
tms_VisitorID, tms_wsid The "tms_VisitorID" cookie is used to identify each user and attributes site interactions to them. The cookie is set to expire after 80 weeks, which is extended each time the user visits the site. If the user does not return to the site within that period, the cookie will be automatically deleted. The "tms_wsid cookie" is a housekeeping cookie set to expire after 30 minutes and works in conjunction with the "tms_VisitorID" cookie to capture user activity.

DoubleClick (A Google Company) cookies

We also may use DoubleClick cookies for ad serving through Google’s DoubleClick, which places a cookie on your computer when you are browsing the web and visit a site using DoubleClick advertising (including some Google AdSense advertisements). This cookie is used to serve ads specific to you and your interests (”interest based targeting”). The ads served will be targeted based on your previous browsing history. DoubleClick uses “non personally identifiable information”. It does NOT track personal information about you, such as your name, email address, physical address, telephone number, social security numbers, bank account numbers or credit card numbers. You can opt-out of this ad serving on all sites using this advertising by visiting https://adssettings.google.com/authenticated

The LinkedIn Insight Tag

This tag enables the collection of data regarding members’ visits to your website, including the URL, referrer, IP address, device and browser characteristics (User Agent), and timestamp. This data is encrypted, the IP addresses are truncated, and members’ direct identifiers are removed within seven days in order to make the data pseudonymous. This remaining, pseudonymized data is then deleted within 90 days.

LinkedIn does not share the personal data with the website owner, it only provides aggregated reports about the website audience and ad performance. LinkedIn also provides retargeting for website visitors, enabling the website owner to show personalized ads off its website by using this data, but without identifying the member. LinkedIn members can control the use of their personal data for advertising purposes through their account settings.

Contacting the Web site

If you have any questions about this privacy statement, the practices of this site, or your dealings with this Web site, you can contact:

 

 

Webmaster
Russell Investments
1301 Second Avenue
18th Floor
Seattle, WA 98101
206-505-7877 (206-505-RUSSELLINVESTMENTS)
1-800-426-7969
webmaster@russellinvestments.com

 

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