1.Who we are

Uncut Gem is a film and microdrama production company based in Seoul, Republic of Korea. We are the controller of the personal information described in this policy.

Company

Uncut Gem

Address

Suite 1115, 11F, 7 Seocho-daero 77-gil, Seocho-gu, Seoul, Republic of Korea

Privacy contact

Sann Lee, CEO and Privacy Officer · sannlee@gmail.com · +82-10-4902-2307

We have not appointed a data protection officer because our processing does not require one under the GDPR.

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2.Information we collect

Information you give us

When you fill in our contact form, email us, or exchange business cards with us, we collect:

• Contact details: name, company name, job title, email address, phone number, country

• Inquiry details: the type of inquiry (for example feature film investment, microdrama investment, co-production or distribution), the projects you are interested in, and your message

• Marketing preference: whether you have agreed to receive our newsletter

Name, company name, email address and inquiry type are needed to answer you. Everything else is optional. If you do not provide the required fields, we may not be able to respond to your inquiry.

Information collected automatically

Our website is hosted on Wix. When you visit, Wix automatically collects technical information such as your IP address, browser type, device information, pages visited and access times, using cookies and similar technologies (see Section 4).

We do not ask for, and ask you not to send us, sensitive information such as health data, religious beliefs, government identification numbers or financial account details.

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3.How we use your information and our legal bases

We use personal information only for the purposes below. If you are in the EU, EEA or UK, the GDPR requires us to state a legal basis for each purpose.

PurposeInformation usedLegal basis (GDPR)

Responding to inquiries about investment, rights, co-production and distribution, and arranging meetingsContact and inquiry detailsSteps taken at your request before entering into a contract (Art. 6(1)(b)); our legitimate interest in answering business inquiries (Art. 6(1)(f))

Sending materials you request, such as screenplays, treatments and pitch decksContact detailsSteps taken at your request (Art. 6(1)(b))

Following up on contacts made at film markets and festivalsContact details from business cards or meeting notesOur legitimate interest in developing business relationships (Art. 6(1)(f))

Sending our newsletter and event informationName and email addressYour consent (Art. 6(1)(a)), which you can withdraw at any time

Operating, securing and improving the websiteTechnical and usage informationOur legitimate interest in a secure, working website (Art. 6(1)(f)); consent where required for non-essential cookies

Complying with legal obligations and defending legal claimsAny information relevant to the obligation or claimLegal obligation (Art. 6(1)(c)); legitimate interest (Art. 6(1)(f))

Where we rely on legitimate interests, we have weighed them against your rights and expectations. You can object to this processing at any time (Section 9). We do not use your information for automated decision-making or profiling that has legal or similarly significant effects on you.

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4.Cookies and online tracking

Our website uses cookies set by Wix that are necessary for the site to work and to keep it secure. Where we use analytics or other non-essential cookies, we ask for your consent through the cookie banner where the law requires it, and you can change your choice at any time. You can also block or delete cookies in your browser settings; some features may then not work.

Do Not Track. Browsers do not apply a single standard for “Do Not Track” signals, so our website does not currently respond to them. We do honor Global Privacy Control (GPC) signals as an opt-out of any sale or sharing of personal information, although we do not sell or share personal information (Section 5).

Third-party tracking. Our hosting provider, Wix, collects technical information when you use our website as described in Wix’s own privacy policy. We do not allow advertising networks to track you across websites through our site.

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5.Who we share your information with

We do not sell your personal information, and we do not “share” it for cross-context behavioral advertising as those terms are defined under California law. We have not done so in the past 12 months.

We disclose personal information only to:

• Service providers (processors) who handle it on our behalf and under contract: Wix.com Ltd. for website hosting, form responses and email, and Google LLC for our business email.

• Co-producers, investors or distributors, only with your agreement, for example when you ask us to introduce you to a partner on a project.

• Authorities, courts or advisers, where the law requires it or to protect our legal rights.

• A successor company, if our business or assets are reorganized or transferred, under the same protections as this policy.

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6.International transfers

We are based in the Republic of Korea, and our service providers store information in other countries. Your information may therefore be processed outside the country where you live.

RecipientLocation of processingSafeguard

Uncut GemRepublic of KoreaEuropean Commission adequacy decision for the Republic of Korea (2021); UK adequacy regulations (2022)

Wix.com Ltd. (contact: privacy@wix.com)Israel, the United States, the EU and other countries where Wix operatesAdequacy decision for Israel; EU-U.S. Data Privacy Framework certification and Standard Contractual Clauses

Google LLCThe United States and other countriesEU-U.S. Data Privacy Framework certification and Standard Contractual Clauses

For users in Korea, as required by PIPA: the items listed in Section 2 are transferred over the network to the recipients above when you submit a form or email us, for the purposes in Section 3 and for the periods in Section 7. If you do not want your information transferred outside Korea, please contact us by phone instead of using the form or email; we will only be able to answer you by phone in that case.

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7.How long we keep your information

Inquiries and meeting records

3 years from our last contact with you, or until you ask us to delete them

Newsletter subscription

Until you unsubscribe or withdraw consent

Website technical data

As set by Wix’s retention periods for site logs and cookies

Contracts and transaction records

As long as the law requires, for example 5 years under the Korean Commercial Act and tax laws

When a retention period ends, we delete electronic records in a way that cannot be recovered and shred or incinerate paper records.

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8.Security

We limit access to personal information to the few people who need it, protect administrator accounts with two-step verification, and transmit information over encrypted HTTPS connections. No system is completely secure, but if a data breach affects you, we will notify you and the authorities as the law requires.

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9.Your rights

Wherever you live, you can ask us to give you access to your personal information, correct it, delete it, or stop sending you marketing. You can withdraw consent at any time, and doing so does not affect processing that took place before.

EU, EEA and UK residents

Under the GDPR you also have the right to restrict processing, to receive your information in a portable format, and to object to processing based on legitimate interests, including at any time to direct marketing. You may lodge a complaint with the data protection authority in the country where you live or work, or where an alleged infringement took place.

U.S. residents

Depending on your state, including California, Colorado, Connecticut, Virginia and others with comprehensive privacy laws, you may have the right to know what personal information we collect and how we use and disclose it, to access, correct and delete it, and to opt out of its sale, sharing for targeted advertising, or profiling. We do not sell or share personal information, do not use it for targeted advertising or profiling, and do not process sensitive personal information. You may use an authorized agent to make a request, and we will not discriminate against you for exercising your rights. If we deny your request, you may appeal by replying to our decision.

Residents of Korea

Under PIPA you may request access, correction, deletion or suspension of processing, and you may withdraw consent. We will respond within 10 days.

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10.How to make a request

Email sannlee@gmail.com with the subject “Privacy request” and tell us what you would like us to do. To protect your information, we may ask you to confirm your identity, usually by replying from the email address we have on file.

We respond within 10 days for requests under PIPA, within one month under the GDPR, and within 45 days under U.S. state laws. If we need more time where the law allows it, we will tell you why.

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11.Children

Our website is intended for industry professionals and is not directed to children. We do not knowingly collect personal information from children under 14 in Korea, under 16 in the EU, or under 13 in the United States. If you believe a child has sent us personal information, please contact us and we will delete it.

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12.Changes to this policy

We review this policy at least once a year. If we change it, we will post the updated version on this page with a new effective date, and where the change is significant we will notify you by email or through a notice on the website before it takes effect.

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13.Contact and complaints

For any question about this policy or your information, contact our Privacy Officer, Sann Lee, at sannlee@gmail.com or +82-10-4902-2307.

You may also contact a supervisory authority:

• Korea: Personal Information Infringement Report Center, Korea Internet & Security Agency (privacy.kisa.or.kr, call 118 within Korea), or the Personal Information Protection Commission (pipc.go.kr)

• EU and EEA: your national data protection authority (list at edpb.europa.eu)

• United Kingdom: Information Commissioner’s Office (ico.org.uk)

• California: California Privacy Protection Agency (cppa.ca.gov)