Privacy Policy
Established 2026.06.18 · Revised 2026.06.20 (v2)
Article 1 (General)
Baystate Asset Management Co., Ltd. (the "Company"), under Article 30 of the Korean Personal Information Protection Act, protects user personal data, respects user rights, and publishes this policy to ensure effective handling of related concerns.
Article 2 (Personal Data Collected)
The Company collects the following data through the website contact form.
- Required — name, email, message content
- Optional — mobile number (if you prefer a call back), area of interest
- Automatic — IP address, access time, browser information, cookies
The Company collects only the minimum necessary information for inquiry response and does not use data for sales or marketing without separate consent.
Article 3 (Purposes of Processing)
- Responding to inquiries and consultations
- User identification and verification
- Operational statistics and quality improvement
- Compliance with legal obligations (disputes, regulatory submissions)
Article 4 (Retention Period)
| Category | Retention | Basis |
|---|---|---|
| Inquiry records | 3 years | E-Commerce Act, Art. 6 |
| Access logs / cookies | 3 months | Protection of Communications Secrets Act, Art. 15-2 |
| When inquiry leads to onboarding | 10 years from contract termination | FSCMA Art. 62 |
Article 5 (Third-Party Transfer)
The Company does not transfer personal data to third parties except where required by user consent, legal obligation, or regulatory request.
Article 5-2 (International Transfer)
The Company does not currently transfer personal data internationally. Any future transfer will follow the notification and consent procedures under Article 28-8 of the Personal Information Protection Act.
Article 5-3 (Children Under 14)
The Company does not collect personal data from children under 14.
Article 5-4 (Pseudonymized Data)
The Company does not currently process pseudonymized data separately.
Article 6 (Processing Entrustment)
| Processor | Service | Retention |
|---|---|---|
| NHN Cloud Corp. (NHN Hosting) | Website hosting / server operations | Until termination of the service agreement |
| Gabia, Inc. (Hiworks) | Inquiry notification email delivery and storage (Hiworks SMTP) | Until termination of the service agreement |
Article 7 (User Rights and Exercise)
- Access request
- Correction request
- Deletion request
- Processing-stop request
These rights may be exercised in writing, by phone, or by email. The Company will act without delay.
Article 8 (Destruction)
The Company destroys personal data without delay upon expiration of retention period or fulfillment of purpose. Electronic files are permanently and irrecoverably deleted; paper records are shredded or incinerated.
Article 8-2 (Automatic Collection and Refusal Methods)
- The Company may collect cookies and access logs for usage analysis.
- Users may refuse cookies through browser settings.
- Prior consent will be obtained before adopting third-party analytics (such as GA4).
Article 9 (Data Protection Officer)
- Data Protection Officer : Heo Geun-uk (허근욱)
- Contact: help@baystateam.com
Article 10 (Security Measures)
- Administrative — internal management plan, regular employee training
- Technical — access control, encryption, security software
- Physical — data center access control
- Disaster preparedness — backup and recovery procedures
Article 11 (Remedies for Rights Violations)
- Personal Information Dispute Mediation Committee: 1833-6972 / kopico.go.kr
- Personal Information Infringement Report Center: 118 / privacy.kisa.or.kr
- Supreme Prosecutors' Office Cybercrime Investigation: 1301 / spo.go.kr
- National Police Cyber Investigation Bureau: 182 / ecrm.cyber.go.kr
Article 12 (Effective Date)
This policy was established on 2026.06.18 and revised to v2 on 2026.06.20. Future changes will be announced on the site 7 days before taking effect.