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Privacy Policy

Effective date: 2026-09-05

Vacatio Inc. ("the Company") complies with the Personal Information Protection Act ("PIPA") and related laws of the Republic of Korea, and establishes and discloses the following privacy policy to protect the personal data of data subjects. This policy applies to the websites and services provided by the Company (including Vacatio Solution, FineStay and VACATIO Hotel). Effective date: 5 September 2026 · Last amended: 5 September 2026.

Contents

  1. Article 1 (Categories, purposes and retention periods of personal data processed)
  2. Article 2 (Purposes of processing)
  3. Article 3 (Personal data of children under 14)
  4. Article 4 (Provision to third parties)
  5. Article 5 (Outsourcing of processing)
  6. Article 6 (Transfer of personal data overseas)
  7. Article 7 (Destruction and separate storage)
  8. Article 8 (Rights of data subjects and how to exercise them)
  9. Article 9 (Installation, operation and refusal of cookies and similar tools)
  10. Article 9-2 (Collection, use and refusal of behavioral data)
  11. Article 10 (Operation of visual data processing devices)
  12. Article 11 (Measures to ensure the security of personal data)
  13. Article 12 (Data protection officer and department receiving access requests)
  14. Article 13 (Remedies for infringement of rights)
  15. Article 14 (Changes to this privacy policy)

Article 1 (Categories, purposes and retention periods of personal data processed)

The Company processes the following personal data. No item is used for purposes other than those specified, and separate consent is obtained if a purpose changes.

CategoryItems collectedPurposeLegal basisRetention period
Inquiries, consultations and demo requests(required) name, email, phone, inquiry details / (optional) business informationResponding to inquiries, consultation, supporting adoption reviewsPIPA Article 15(1)43 years after the purpose is achieved (consultation history management)
Service booking and use (FineStay, etc.)(required) name, phone, email, booking detailsConcluding and performing accommodation bookings and customer supportPIPA Article 15(1)4Until the purpose is achieved. However, under the Act on Consumer Protection in Electronic Commerce, records of contracts or withdrawal of subscription are kept for 5 years, records of payment and supply of goods for 5 years, and records of consumer complaints or dispute resolution for 3 years.
PaymentPayment approval data (payment-method data such as card numbers is collected and processed directly by the payment gateway NICE Payments and is not held by the Company)Payment and settlement of feesPIPA Article 15(1)45 years under the Act on Consumer Protection in Electronic Commerce
Job applicationsName, email, phone, and information contained in resumes/portfoliosConducting recruitment and notifying resultsPIPA Article 15(1)4Retained for 180 days after the process ends, then destroyed
Automatically collected dataIP address, cookies, service usage records, device/browser information, access logsService operation and improvement, statistical analysis, prevention of misusePIPA Article 15(1)4Access logs are kept for at least 3 months under the Protection of Communications Secrets Act and then destroyed.
AI phone and message handlingCaller phone number, call/consultation content (voice and text)Automating responses and managing consultation qualityPIPA Article 15(1)4Retained for 3 years after the purpose is achieved, then destroyed
Marketing (optional consent)Name, email, phoneSending newsletters, promotions and other advertising informationPIPA Article 15(1)1 (consent)Until consent is withdrawn

※ When AI handles a phone call, we notify you at the start of the call that the call may be recorded and logged. After personally identifiable information is removed, consultation data may be used to improve response quality and AI performance; you may object to this use at any time via operation@vacatio.us.

※ We ask applicants not to include sensitive data such as beliefs or health information, or unique identifiers such as resident registration numbers, in their resumes; even if included, the Company does not use them in evaluation. Under the Fair Hiring Procedure Act, applicants may also request the return of the application documents they submitted.

Article 2 (Purposes of processing)

The Company processes personal data for the following purposes: (1) responding to inquiries and consultations; (2) providing services, concluding and performing bookings/contracts, and settling fees; (3) conducting recruitment; (4) improving services and analyzing statistics; (5) preventing misuse and maintaining a secure service environment; (6) fulfilling legal obligations; and (7) sending advertising information (only where consent has been given).

Article 3 (Personal data of children under 14)

As a rule, the Company does not collect personal data from children under the age of 14. Where collection is unavoidable, the consent of a legal representative is obtained.

Article 4 (Provision to third parties)

The Company does not provide personal data to third parties without the data subject’s consent, except: (1) where specially provided by law; (2) where an investigative agency requests it in accordance with the procedures and methods prescribed by law; or (3) where the data subject has consented in advance.

Article 5 (Outsourcing of processing)

To provide the service smoothly, the Company outsources the following personal data processing tasks. Outsourcing contracts include the matters required for safe management and supervision under PIPA Article 26, and any re-outsourcing by a processor requires the Company’s prior approval.

ProcessorOutsourced task
Amazon Web Services, Inc.Cloud infrastructure operation and data storage
NICE Payments Co., Ltd.Payment processing and settlement
Google LLCBusiness email delivery and storage of inquiry/support data (Google Workspace, Sheets, Drive)
Vercel Inc.Website hosting and deployment
NAVER Cloud Corp.Outbound AlimTalk/SMS message dispatch (NAVER Cloud SENS)
Kakao Corp.AlimTalk message delivery
Moru (moru.io)AI phone and message consultation handling

Article 6 (Transfer of personal data overseas)

To provide the service, the Company transfers personal data overseas as follows. The legal basis is PIPA Article 28-8(1)3 (outsourcing of processing and storage).

RecipientDestination countryItems transferredMethod of transferPurposeRetention period
Amazon Web Services, Inc. (aws-korea-privacy@amazon.com)Overseas regions including the United StatesPersonal data collected in the course of service useTransmitted and stored over the network when the service is usedCloud infrastructure operation and backupUntil the outsourcing contract ends
Google LLCUnited StatesEmail and inquiry/recruitment dataTransmitted and stored over the network when the service is usedBusiness email delivery and storage of inquiry/recruitment dataUntil the outsourcing contract ends
Vercel Inc.United StatesAccess data processed when the website is visitedTransmitted over the network when the website is usedWebsite hosting and deploymentUntil the outsourcing contract ends
External language-model and speech-recognition processorsUnited StatesConsultation content entered or spoken by the user during AI-assisted handlingTransmitted over the network when the service is usedGenerating AI-based responsesDeleted after the request is processed (retained for up to 30 days before deletion, depending on the processor’s policy)

Data subjects may refuse the overseas transfer via the contact in Article 12; refusal may limit the use of the relevant service.

Article 7 (Destruction and separate storage)

(1) The Company destroys personal data without delay once the retention period expires or the purpose of processing is achieved.

(2) Data in electronic file form is permanently deleted in a manner that makes recovery or reproduction impossible, and printed materials are shredded or incinerated.

(3) Data that must be retained by law is stored and managed separately from other personal data and is not used for any purpose other than that retention.

Article 8 (Rights of data subjects and how to exercise them)

(1) Data subjects may at any time request access to, correction or deletion of, or suspension of the processing of their personal data, and may withdraw consent.

(2) Rights may be exercised in writing or by email (operation@vacatio.us), and the Company will act without delay (within 10 days).

(3) Rights may be exercised through a legal representative or an authorized agent, in which case a power of attorney must be submitted.

(4) Where there is a statutory ground to refuse a request, the Company notifies the data subject of the reason and how to object.

Article 9 (Installation, operation and refusal of cookies and similar tools)

(1) The Company uses cookies to provide an optimized service.

(2) Users may refuse cookie storage through browser settings (e.g. Chrome — Settings > Privacy and security > Cookies). Refusal may limit the use of some services.

Article 9-2 (Collection, use and refusal of behavioral data)

The Company collects behavioral data using Google Analytics (GA4) and Google Ads.

CategoryDetails
Items collectedWebsite visit records and usage records such as clicks
Method of collectionAutomatic collection through Google Analytics (GA4) and Google Ads when the website is used
PurposeAnalyzing service usage and measuring advertising performance
Retention periodUp to 14 months from collection (the GA4 default setting), after which it is deleted
How to refuseBlock cookies in your browser settings, or turn off personalized ads in Google Ad Settings (adssettings.google.com).

※ The Company does not collect sensitive behavioral data such as beliefs or medical history.

Article 10 (Operation of visual data processing devices)

(1) The accommodation facility operated by the Company (VACATIO Hotel) operates fixed visual data processing devices (CCTV) for facility safety and crime prevention. Details follow the CCTV operation and management policy posted on site.

(2) Mobile visual data processing devices, such as cameras mounted on the Company’s autonomous service robots, are operated with an indication that filming is taking place, in accordance with PIPA Article 25-2.

Article 11 (Measures to ensure the security of personal data)

The Company establishes and implements an internal management plan, manages access rights and controls access, encrypts personal data, retains access logs and prevents their forgery or alteration, installs security programs, and applies physical access controls.

Article 12 (Data protection officer and department receiving access requests)

· Data protection officer — Ji Hyunjun (Chief Executive Officer).

· Department receiving and handling access requests — Operations Team · operation@vacatio.us.

Privacy inquiries, complaints and requests for remedy may be submitted to the contact above, and the Company will respond without delay.

Article 13 (Remedies for infringement of rights)

Reports and consultations regarding personal data infringement may be directed to the following organizations.

OrganizationContactWebsite
Personal Information Dispute Mediation Committee1833-6972www.kopico.go.kr
Privacy Infringement Report Center (KISA)118 without an area codeprivacy.kisa.or.kr
Supreme Prosecutors’ Office1301www.spo.go.kr
National Police Agency182ecrm.police.go.kr

Article 14 (Changes to this privacy policy)

(1) If content is added to, deleted from or modified in this policy, we will give notice on the website 7 days before it takes effect (30 days in advance for significant changes such as items collected, purposes, or provision to third parties).

(2) Previous versions of this policy are available on request at operation@vacatio.us.

VACATIO

Vacatio Inc. · We build the infrastructure of space

operation@vacatio.us
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Vacatio Inc. · CEO Hyunjun Ji · Business Reg. 783-81-02586
2F, 31 Mapo-daero 4da-gil, Mapo-gu, Seoul, Korea · operation@vacatio.us

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