Last updated: September 10, 2025

1. Nature and scope of the terms and conditions

These terms and conditions describe the relationship between AssembleCircle Corp. (hereinafter referred to as "AssembleCircle") and WebCeph members (hereinafter referred to as "members") or non-members who use the WebCeph service, and define the rights, obligations, and necessary matters between the member and AssembleCircle in relation to the use of the WebCeph service provided by AssembleCircle to members.

When you use the WebCeph service or sign up as a member, you are required to confirm or agree to these terms and conditions. These terms and conditions basically apply to all WebCeph services, but separate terms and operating policies may be applied for each individual service to comply with relevant laws and regulations and to achieve the purpose of each service.

2. WebCeph Service

The WebCeph service is an orthodontic/orthognathic artificial intelligence cloud platform designed by orthodontists and oral surgeons and developed by orthodontists. You can use the WebCeph service using a device that can connect to the Internet, such as a PC or mobile phone. The WebCeph service includes diagnostic data analysis services for orthodontic and orthognathic surgery, and clinical case sharing and discussion platforms for academic purposes. For specific details of individual services, please refer to the WebCeph website.

The WebCeph service assists doctors with diagnosis, treatment planning, and clinical practice. However, the WebCeph service is neither a medical institution nor a healthcare provider and does not provide medical advice or a diagnosis. The WebCeph service is not a substitute for professional judgment. AssembleCircle recommends that members make clinical decisions and provide care in consultation with qualified healthcare professionals.

AssembleCircle provides the same service to all members, but the scope of the service provided for each individual service may vary to comply with relevant laws and regulations and to achieve the goal of individual service. For example, some WebCeph services may be provided only to members with medical qualifications, and members who wish to use those services may be required to provide proof of such qualifications.

AssembleCircle may modify, suspend, or terminate some or all content of the WebCeph website or service for reasons of compliance with related laws and regulations, maintenance and management of services, and business judgment. For example, to perform routine or non-routine maintenance of the WebCeph service, to correct errors, or to perform other changes, we may suspend the WebCeph website or some operations of the WebCeph service as needed. In addition, AssembleCircle may stop the operation of the WebCeph service in a certain residential area. If a member violates the terms and conditions and related laws, services may no longer be provided to the member.

3. Sign Up

1. The intellectual property rights in any content (“Content”) created by a member through the WebCeph service belong to the member in accordance with applicable laws. Intellectual property rights relating to the WebCeph service (e.g., AssembleCircle’s trademarks) and all materials stored, displayed, or accessible on the WebCeph website are owned by or licensed to AssembleCircle. You may not modify, copy, reproduce, republish, upload, post, transmit, distribute, sell, license, lease, publicly display or perform, edit, or otherwise use such materials in any way without AssembleCircle’s prior written consent. Derivative works may not be created.
2. In addition, members may view, use, download, and print selected portions of the WebCeph website for personal, non-commercial, and informational purposes, without posting WebCeph contents as is.
3. AssembleCircle shall not be held liable for any infringement of intellectual property rights of third parties during the process of creating contents by members, or disputes on intellectual property rights between members arising from members using contents of other members. (See also Section 7.)

4. Types of services and how to use them

1. AssembleCircle provides the following services to its members.
   1. Dental diagnostic medical data analysis service
   2. Clinical and academic discussion service for clinicians and researchers
   3. Dentist–patient clinical and educational data delivery service
   4. Educational services in the form of video lectures, text lectures, and others
   5. All other services provided to members through additional development by AssembleCircle or through partnership agreements with other companies
2. In principle, the service operates 24 hours a day, 365 days a year, unless there is a special obstacle in the business or technology of AssembleCircle.
3. AssembleCircle may determine the availability of some services separately. In this case, we will notify you via e-mail or notice pop-up within the service.

5. Restrictions on service use

1. AssembleCircle may restrict members' use of services in the following cases:
2. In the case of a time when there is a high possibility of a service error related to the financial institutions affiliated with AssembleCircle
3. When it is difficult to provide normal service due to repair, upgrade, inspection, replacement, hacking, etc.
4. In case the service operation is impossible due to force majeure such as natural disaster, war, explosion, terrorism, etc.
5. In case of occurrence of each subparagraph of Article 6 Paragraph 2, etc.
6. If AssembleCircle intends to restrict the use of the service, the reason, date, and period are determined in advance and notified via e-mail or notice pop-up within the service. However, if AssembleCircle recognizes that it is urgently necessary to limit the use of the service, it may post notice after the restriction on the use of the service.
7. AssembleCircle is not responsible for any restrictions on the use of services that are not attributable to AssembleCircle.

6. Cancellation of service use contract

1. A member may terminate or cancel the service use contract by applying for the termination of the use contract in the method determined by AssembleCircle.
2. AssembleCircle may terminate or cancel the service use contract with the member for any of the following reasons:
   1. If the member violates these terms and conditions or related laws in a way that frustrates the purpose of the contract
   2. When a member falsely fills in important information such as information related to qualifications for service use
   3. When a member steals or uses another person's name or payment information
   4. When a member uses the WebCeph service for illegal purposes
   5. When a member interferes with the operation of the WebCeph service (including distribution of malicious code or hacking)
   6. Other cases where AssembleCircle objectively judges that it is necessary to refuse to provide the service
3. When AssembleCircle terminates or cancels the contract of use in accordance with this Article, it may set a reasonable period and grant the member an opportunity to file an objection. AssembleCircle immediately resumes the service if the objection is justified.

7. Intellectual property rights

The intellectual property rights in any content (“Content”) created by a member through the WebCeph service belong to the member in accordance with applicable laws. Intellectual property rights relating to the WebCeph service (e.g., AssembleCircle’s trademarks) and all materials stored, displayed, or accessible on the WebCeph website are owned by or licensed to AssembleCircle. You may not modify, copy, reproduce, republish, upload, post, transmit, distribute, sell, license, lease, publicly display or perform, edit, or otherwise use such materials in any way without AssembleCircle’s prior written consent. Derivative works may not be created.

In addition, members may view, use, download, and print selected portions of the WebCeph website for personal, non-commercial, and informational purposes, without posting WebCeph contents as is.

AssembleCircle shall not be held liable for any infringement of intellectual property rights of third parties during the process of creating contents by members, or disputes on intellectual property rights between members arising from members using contents of other members.

8. Data management policy

WebCeph services involve cloud-based transfer, storage, indexing, backup, and deletion operations. By using the service, members authorize AssembleCircle to process data strictly for service provision and improvement in accordance with the EU Privacy Policy/Notice and applicable data protection laws. For the avoidance of doubt, any personal data concerning patients (including health/biometric data) is processed solely as instructed by the member (controller) and is not used for advertising, public display, or creation of derivative works beyond what is necessary to provide the service.

The above authorization continues only for the duration and purposes permitted by applicable law and the EU Privacy Policy/Notice. Non-personal, de-identified, or anonymized information may be used to maintain and improve the services. WebCeph does not publish or publicly display patient personal data.

9. Collection of personal information

The company strives to protect the personal information of members as stipulated by relevant laws and regulations. The protection and use of personal information is in accordance with the relevant laws and regulations and the company's personal information processing policy.

The company does not provide personal information without the individual consent of the information subject to third parties, except in cases where the member uses the service and is requested to provide information from an investigative agency or other public institution in violation of related laws.

The company provides personal information to entrusted processors only to the extent necessary to provide the service, and manages and supervises them to ensure safe processing of users’ personal information.

The company does not directly solicit personal data from minors online. In clinical contexts, members (as controllers) remain responsible for complying with applicable laws on minors’ data (including obtaining any required consents or authorizations) before submitting patient data to WebCeph for processing.

Exceptions apply to processing by our sub-processors strictly for service provision under data processing agreements and, where applicable, approved transfer mechanisms (e.g., SCCs/DPF) as detailed in the EU Privacy Policy/Notice.

10. Personal information entrusted by WebCeph

When a member provides data, etc. to AssembleCircle for the use of the WebCeph service, the member must have all legal rights to the personal information (patient information) and must obtain the data subject’s (patient’s) consent for the entrustment of such personal information where required by law.

For example, if you collect personal information (patient information) from patients of the hospital or clinic you operate and provide it to AssembleCircle, you must use an appropriate consent form to collect such personal information and obtain the data subject’s (patient’s) consent for entrusting the personal information to AssembleCircle.

[Check the consent form included in the member's guide (link)]

If the member's provision of personal information (patient information) for consignment violates relevant laws or the terms and operating policy of the WebCeph service, provision of the WebCeph service may be suspended, personal information (patient information) may be deleted, the member's use of the WebCeph service may be restricted, or the account may be suspended. AssembleCircle is not responsible for any disputes between the member and the data subject (patient) or damages to the data subject arising from violations of laws and regulations, etc.

Members who agree to these terms and conditions are deemed to have entrusted personal information processing work to AssembleCircle in accordance with Article 26 of the Personal Information Protection Act. Please familiarize yourself with the following regarding personal information processing consignment.

• Purpose and scope of commissioned work: AssembleCircle processes personal information (patient information) entrusted by members within the scope necessary to provide the service. AssembleCircle does not process personal information (patient information) beyond that scope. Where third-party interconnection (e.g., the company’s internet service “Toosapp” at https://toosapp.com) is needed, members (as controllers) are responsible for obtaining any required consents from data subjects before submitting data for processing.
• Consignment period: AssembleCircle is entrusted with processing of personal information (patient information) during the member's service use period.
• Following consignment on International transfer of personal information (patient information): AssembleCircle transfers and processes personal information (patient information) entrusted by members located outside Korea within the scope of the purpose of providing the service to Korea as follows.

  Trustee (country to which personal information is transferred according to the consignment)	Commissioned work	Items of personal information transferred	Transfer date and transfer method	Trustee contact information	Purpose of use and retention period of trustee
  AssembleCircle Corp. (Korea)	WebCeph service provision and data management	Name, date of birth, gender, race, facial picture, oral picture, X-ray picture, measurement coordinates in medical images (radiation pictures and clinical pictures), diagnosis contents, treatment plan, treatment details	Upon collection, data are transferred and stored in the cloud service	411-ho, 4th floor, 240, Pangyoyeok-ro, Bundang-gu, Seongnam-si, Gyeonggi-do (13493)	Until the member's service ends

  Trustee (country to which personal information is transferred according to the consignment)	AssembleCircle Corp. (Korea)
  Commissioned work	WebCeph service provision and data management
  Items of personal information transferred	Name, date of birth, gender, race, facial picture, oral picture, X-ray picture, measurement coordinates in medical images (radiation pictures and clinical pictures), diagnosis contents, treatment plan, treatment details
  Transfer date and transfer method	Upon collection, data are transferred and stored in the cloud service
  Trustee contact information	411-ho, 4th floor, 240, Pangyoyeok-ro, Bundang-gu, Seongnam-si, Gyeonggi-do (13493)
  Purpose of use and retention period of trustee	Until the member's service ends

• Re-consignment restrictions: AssembleCircle does not transfer or re-consign all or part of the personal information (patient information) entrusted by the member to a third party, except in the case of obtaining prior consent from the member. A member who agrees to these terms and conditions is deemed to have read the following matters and consented to the re-consignment of the processing of personal information (patient information) as described below.
  
  Privacy & International Transfers (Reference and Precedence)
  For data storage locations (EU-based image storage; U.S.-based database for text data) and GDPR transfer mechanisms (SCCs/DPF; explicit consent as complementary), please refer to our EU Privacy Policy and EU Privacy Notice. If any inconsistency arises, the EU Privacy Policy/Notice shall prevail.

  Trustee (country)	Commissioned work	Items of personal information transferred	Transfer date and transfer method	Trustee contact information	Purpose of use and retention period of trustee
  Amazon Web Services Korea LLC (United States)	Cloud service	Name, date of birth, gender, race, facial picture, oral picture, X-ray picture, measurement coordinates in medical images (radiation pictures and clinical pictures), diagnosis contents, treatment plan, treatment details	When collecting personal information, it is stored in the cloud service	12F, 508, Nonhyeon-ro, Gangnam-gu, Seoul (GS Tower) (06141)	Cloud service provision, until the end of the consignment contract
  Amazon Web Services Korea LLC (Canada)
  Amazon Web Services Korea LLC (Germany)
  Amazon Web Services Korea LLC (United Kingdom)
  Amazon Web Services Korea LLC (Australia)
  Amazon Web Services Korea LLC (Brazil)
  Amazon Web Services Korea LLC (France)
  Amazon Web Services Korea LLC (India)
  Amazon Web Services Korea LLC (S.Korea)
  Amazon Web Services Korea LLC (Japan)
  Amazon Web Services Korea LLC (Singapore)
  Amazon Web Services Korea LLC (Sweden)

  Trustee (country)	Amazon Web Services Korea LLC (United States)
  Commissioned work	Cloud service
  Items of personal information transferred	Name, date of birth, gender, race, facial picture, oral picture, X-ray picture, measurement coordinates in medical images (radiation pictures and clinical pictures), diagnosis contents, treatment plan, treatment details
  Transfer date and transfer method	When collecting personal information, it is stored in the cloud service
  Trustee contact information	12F, 508, Nonhyeon-ro, Gangnam-gu, Seoul (GS Tower) (06141)
  Purpose of use and retention period of trustee	Cloud service provision, until the end of the consignment contract

  Trustee (country)	Amazon Web Services Korea LLC (Canada)
  Commissioned work	Cloud service
  Items of personal information transferred	Name, date of birth, gender, race, facial picture, oral picture, X-ray picture, measurement coordinates in medical images (radiation pictures and clinical pictures), diagnosis contents, treatment plan, treatment details
  Transfer date and transfer method	When collecting personal information, it is stored in the cloud service
  Trustee contact information	12F, 508, Nonhyeon-ro, Gangnam-gu, Seoul (GS Tower) (06141)
  Purpose of use and retention period of trustee	Cloud service provision, until the end of the consignment contract

  Trustee (country)	Amazon Web Services Korea LLC (Germany)
  Commissioned work	Cloud service
  Items of personal information transferred	Name, date of birth, gender, race, facial picture, oral picture, X-ray picture, measurement coordinates in medical images (radiation pictures and clinical pictures), diagnosis contents, treatment plan, treatment details
  Transfer date and transfer method	When collecting personal information, it is stored in the cloud service
  Trustee contact information	12F, 508, Nonhyeon-ro, Gangnam-gu, Seoul (GS Tower) (06141)
  Purpose of use and retention period of trustee	Cloud service provision, until the end of the consignment contract

  Trustee (country)	Amazon Web Services Korea LLC (United Kingdom)
  Commissioned work	Cloud service
  Items of personal information transferred	Name, date of birth, gender, race, facial picture, oral picture, X-ray picture, measurement coordinates in medical images (radiation pictures and clinical pictures), diagnosis contents, treatment plan, treatment details
  Transfer date and transfer method	When collecting personal information, it is stored in the cloud service
  Trustee contact information	12F, 508, Nonhyeon-ro, Gangnam-gu, Seoul (GS Tower) (06141)
  Purpose of use and retention period of trustee	Cloud service provision, until the end of the consignment contract

  Trustee (country)	Amazon Web Services Korea LLC (Australia)
  Commissioned work	Cloud service
  Items of personal information transferred	Name, date of birth, gender, race, facial picture, oral picture, X-ray picture, measurement coordinates in medical images (radiation pictures and clinical pictures), diagnosis contents, treatment plan, treatment details
  Transfer date and transfer method	When collecting personal information, it is stored in the cloud service
  Trustee contact information	12F, 508, Nonhyeon-ro, Gangnam-gu, Seoul (GS Tower) (06141)
  Purpose of use and retention period of trustee	Cloud service provision, until the end of the consignment contract

  Trustee (country)	Amazon Web Services Korea LLC (Brazil)
  Commissioned work	Cloud service
  Items of personal information transferred	Name, date of birth, gender, race, facial picture, oral picture, X-ray picture, measurement coordinates in medical images (radiation pictures and clinical pictures), diagnosis contents, treatment plan, treatment details
  Transfer date and transfer method	When collecting personal information, it is stored in the cloud service
  Trustee contact information	12F, 508, Nonhyeon-ro, Gangnam-gu, Seoul (GS Tower) (06141)
  Purpose of use and retention period of trustee	Cloud service provision, until the end of the consignment contract

  Trustee (country)	Amazon Web Services Korea LLC (France)
  Commissioned work	Cloud service
  Items of personal information transferred	Name, date of birth, gender, race, facial picture, oral picture, X-ray picture, measurement coordinates in medical images (radiation pictures and clinical pictures), diagnosis contents, treatment plan, treatment details
  Transfer date and transfer method	When collecting personal information, it is stored in the cloud service
  Trustee contact information	12F, 508, Nonhyeon-ro, Gangnam-gu, Seoul (GS Tower) (06141)
  Purpose of use and retention period of trustee	Cloud service provision, until the end of the consignment contract

  Trustee (country)	Amazon Web Services Korea LLC (India)
  Commissioned work	Cloud service
  Items of personal information transferred	Name, date of birth, gender, race, facial picture, oral picture, X-ray picture, measurement coordinates in medical images (radiation pictures and clinical pictures), diagnosis contents, treatment plan, treatment details
  Transfer date and transfer method	When collecting personal information, it is stored in the cloud service
  Trustee contact information	12F, 508, Nonhyeon-ro, Gangnam-gu, Seoul (GS Tower) (06141)
  Purpose of use and retention period of trustee	Cloud service provision, until the end of the consignment contract

  Trustee (country)	Amazon Web Services Korea LLC (S.Korea)
  Commissioned work	Cloud service
  Items of personal information transferred	Name, date of birth, gender, race, facial picture, oral picture, X-ray picture, measurement coordinates in medical images (radiation pictures and clinical pictures), diagnosis contents, treatment plan, treatment details
  Transfer date and transfer method	When collecting personal information, it is stored in the cloud service
  Trustee contact information	12F, 508, Nonhyeon-ro, Gangnam-gu, Seoul (GS Tower) (06141)
  Purpose of use and retention period of trustee	Cloud service provision, until the end of the consignment contract

  Trustee (country)	Amazon Web Services Korea LLC (Japan)
  Commissioned work	Cloud service
  Items of personal information transferred	Name, date of birth, gender, race, facial picture, oral picture, X-ray picture, measurement coordinates in medical images (radiation pictures and clinical pictures), diagnosis contents, treatment plan, treatment details
  Transfer date and transfer method	When collecting personal information, it is stored in the cloud service
  Trustee contact information	12F, 508, Nonhyeon-ro, Gangnam-gu, Seoul (GS Tower) (06141)
  Purpose of use and retention period of trustee	Cloud service provision, until the end of the consignment contract

  Trustee (country)	Amazon Web Services Korea LLC (Singapore)
  Commissioned work	Cloud service
  Items of personal information transferred	Name, date of birth, gender, race, facial picture, oral picture, X-ray picture, measurement coordinates in medical images (radiation pictures and clinical pictures), diagnosis contents, treatment plan, treatment details
  Transfer date and transfer method	When collecting personal information, it is stored in the cloud service
  Trustee contact information	12F, 508, Nonhyeon-ro, Gangnam-gu, Seoul (GS Tower) (06141)
  Purpose of use and retention period of trustee	Cloud service provision, until the end of the consignment contract

  Trustee (country)	Amazon Web Services Korea LLC (Sweden)
  Commissioned work	Cloud service
  Items of personal information transferred	Name, date of birth, gender, race, facial picture, oral picture, X-ray picture, measurement coordinates in medical images (radiation pictures and clinical pictures), diagnosis contents, treatment plan, treatment details
  Transfer date and transfer method	When collecting personal information, it is stored in the cloud service
  Trustee contact information	12F, 508, Nonhyeon-ro, Gangnam-gu, Seoul (GS Tower) (06141)
  Purpose of use and retention period of trustee	Cloud service provision, until the end of the consignment contract

  The following tables illustrate cloud infrastructure availability by regions for informational purposes. Actual storage and transfer locations for EU data subjects (images in the EU; text data in the U.S.) are governed by the EU Privacy Policy and EU Privacy Notice.

  Privacy & International Transfers (Reference and Precedence)
  For data storage locations (EU-based image storage; U.S.-based database for text data) and GDPR transfer mechanisms (SCCs/DPF; explicit consent as complementary), please refer to our EU Privacy Policy and EU Privacy Notice. If any inconsistency arises, the EU Privacy Policy/Notice shall prevail.

  Countries transferred upon re-entrustment	Country of data subject (patient)
  United States	Bahamas / Belize / Bermuda / Cayman Islands / Costa Rica / Cuba / Dominica / Dominican Republic / El Salvador / Guadeloupe / Guam / Guatemala / Haiti / Honduras / Jamaica / Mexico / Montserrat / Nicaragua / Northern Mariana Islands / Panama / Pitcairn / Puerto Rico / Republic of Korea / Saint Barthelemy / Saint Kitts and Nevis / Saint Lucia / Saint Martin (French part) / Sint Maarten (Dutch part) / Tanzania / Turks and Caicos Islands / United States / United States Minor Outlying Islands / Virgin Islands
  Canada	Canada / Greenland / Saint Pierre and Miquelon
  Germany	Albania / Angola / Armenia / Austria / Azerbaijan / Belgium / Bosnia and Herzegovina / Bulgaria / Cameroon / Central African Republic / Chad / Congo / Congo / Croatia / Cyprus / Czech Republic / Egypt / Equatorial Guinea / Georgia / Germany / Greece / Holy See (Vatican City State) / Hungary / Israel / Italy / Jordan / Lebanon / Libya / Liechtenstein / Luxembourg / Macedonia / Malta / Moldova / Montenegro / Namibia / Netherlands / Niger / Nigeria / Palestine / Poland / Romania / Russian Federation / Rwanda / San Marino / Serbia / Slovakia / Slovenia / South Africa / South Sudan / Sudan / Swaziland / Switzerland / Syrian Arab Republic / Tunisia / Turkey / Uganda / Ukraine / Zambia / Zimbabwe
  United Kingdom	Guernsey / Iceland / Ireland / Isle of Man / Jersey / United Kingdom
  Australia	American Samoa / Antarctica / Australia / Cook Islands / Fiji / French Polynesia / French Southern Territories / Heard Island and McDonald Islands / Kiribati / Marshall Islands / Micronesia, Federated States of / Nauru / New Caledonia / New Zealand / Niue / Norfolk Island / Papua New Guinea / Samoa / Solomon Islands / Tokelau / Tonga / Tuvalu / Vanuatu / Wallis and Futuna
  Brazil	Anguilla / Antigua and Barbuda / Argentina / Aruba / Barbados / Bolivia, Plurinational State of / Bonaire, Sint Eustatius and Saba / Bouvet Island / Brazil / Chile / Colombia / Curacao / Ecuador / Falkland Islands (Malvinas) / French Guiana / Grenada / Guyana / Martinique / Paraguay / Peru / Saint Vincent and the Grenadines / South Georgia and the South Sandwich Islands / Suriname / Trinidad and Tobago / Uruguay / Venezuela, Bolivarian Republic of
  France	Algeria / Andorra / Benin / Burkina Faso / Cape Verde / Cote d'Ivoire / France / Gabon / Gambia / Ghana / Gibraltar / Guinea / Guinea-Bissau / Liberia / Mali / Mauritania / Monaco / Morocco / Portugal / Saint Helena, Ascension and Tristan da Cunha / Sao Tome and Principe / Senegal / Sierra Leone / Spain / Togo / Western Sahara
  India	Afghanistan / Bahrain / Bangladesh / Bhutan / Botswana / British Indian Ocean Territory / Burundi / Comoros / Djibouti / Eritrea / Ethiopia / India / Iran, Islamic Republic of / Iraq / Kazakhstan / Kenya / Kuwait / Kyrgyzstan / Lesotho / Madagascar / Malawi / Maldives / Mauritius / Mayotte / Mozambique / Nepal / Oman / Pakistan / Qatar / Reunion / Saudi Arabia / Seychelles / Somalia / Sri Lanka / Tajikistan / Turkmenistan / United Arab Emirates / Uzbekistan / Yemen
  Korea, Republic of	China / Hong Kong / Korea, Democratic People's Republic of / Korea, Republic of / Macao / Mongolia / Taiwan
  Japan	Japan
  Singapore	Brunei Darussalam / Cambodia / Christmas Island / Cocos (Keeling) Islands / Indonesia / Lao People's Democratic Republic / Malaysia / Myanmar / Palau / Philippines / Singapore / Thailand / Timor-Leste / Viet Nam
  Sweden	Aland Islands / Belarus / Denmark / Estonia / Faroe Islands / Finland / Latvia / Lithuania / Norway / Svalbard and Jan Mayen / Sweden

• Measures to ensure the safety of personal information (patient information): AssembleCircle takes technical and managerial measures necessary to ensure the safety of entrusted personal information (patient information) in accordance with the relevant regulations under the Personal Information Protection Act. For details on measures to ensure safety, such as restricting access to personal information (patient information), please refer to the Privacy Policy.
• Matters related to supervision, such as checking the management status of personal information (patient information): With respect to AssembleCircle, the member may request confirmation of the status of processing of personal information (patient information) entrusted by the member, access status to personal information (patient information), compliance with purpose limitation and re-consignment restrictions, and whether security measures such as encryption are implemented.

11. Processing of anonymous information

Anonymous information refers to information that is no longer recognizable by using any other information given with reasonable time, cost, and technology. Members may provide or disclose anonymous information to AssembleCircle and other members during the process of using the WebCeph service. In this case, the consent of the information subject (patient) in Section 10 is not required.

For example, photographs in which it is impossible to identify a patient by any technical means may be considered anonymous information.

AssembleCircle does not guarantee the anonymity of anonymous information provided or disclosed by the member, and all risks due to insufficient anonymization are within the scope of the member's responsibility. Before providing anonymous information, be sure to review the appropriateness of anonymization.

In addition, the anonymous information disclosed by the member in the gallery can be used freely by AssembleCircle for new service development, etc.

12. Protection and management of personal information

AssembleCircle collects and uses the personal information included in the data entrusted by the member, including the member's personal information, only within the purpose and scope agreed by the member, and does not provide it to third parties other than AssembleCircle without the consent of the member. It is managed safely in accordance with the laws and regulations related to personal information protection.

The subject of the personal information can request AssembleCircle to view, correct, or delete the personal information at any time, and the member can withdraw his or her consent to provide personal information to AssembleCircle.

Details on the protection and management of personal information can be found in the Privacy Policy.

13. Member Responsibilities

Members must confirm that they are of the age of majority in their jurisdiction and agree to check and comply with these Terms when registering as a member. If a member violates these terms and conditions, the provision of the WebCeph service may be suspended, and the account may be suspended. For example, members should not do the following actions.

1. Falsely entering member information when registering as a member, selling, transferring, lending, or providing your account to others as collateral, permitting its use, or unauthorized use of another person's account
2. Using WebCeph services for false or illegal purposes, impersonating an individual or organization, or falsely stating or falsely describing affiliation with the individual or organization
3. Harmful, intrusive, or damaging activities: interfering with the operation or access of the WebCeph service, damaging the WebCeph service, hijacking the operation of the WebCeph service, or monitoring the hardware, software, or equipment; transmitting viruses, worms, Trojans, time bombs, spyware or other code that limits or prohibits the ability of others to use WebCeph services
4. Any act of removing, blurring, or modifying copyright, trademark or other proprietary notices on the WebCeph website

If a member does not fulfill the obligations under these terms and conditions, even if AssembleCircle does not immediately claim rights or delays enforcement, this does not mean that AssembleCircle has waived those rights. If AssembleCircle decides not to exercise a right in connection with a member's breach of obligations under these terms, AssembleCircle will only do so in writing.

14. AssembleCircle's Responsibilities

If you experience damage due to the intention or negligence of AssembleCircle in the process of using the WebCeph service, AssembleCircle will compensate for your damage in accordance with relevant laws and regulations. However, AssembleCircle is not responsible for any special or punitive damages that are not normally foreseeable. Even if the above damages are caused by natural disasters or equivalent force majeure, AssembleCircle is not responsible.

AssembleCircle makes no warranties, either express or implied, as to the accuracy, appropriateness, timeliness, completeness, and reliability of the following items.

1. WebCeph service output (simulation result, etc.)
2. Content created by members in the process of using the WebCeph service
3. All content included in or delivered through the WebCeph website
4. Medical plans established by doctors using WebCeph services and medical actions performed

The WebCeph website may contain links to third-party sites (including social media). These links are provided solely for your convenience; AssembleCircle does not control or endorse, and is not responsible for, the content of such external sites.

You may not use the WebCeph service for unlawful, deceptive, or misleading commercial communications (including spamming or unauthorized advertising). Clinical and commercial use within the intended purpose of the service is permitted, subject to these Terms and applicable law.

15. Member's liability

1. If a member intentionally or negligently violates the provisions of these Terms and Conditions and causes damage to AssembleCircle, the member must compensate the damage suffered by AssembleCircle.
2. In the event that AssembleCircle receives various objections, including claims for damages or lawsuits, from a third party due to illegal acts or violation of these terms and conditions by a member, the member shall indemnify AssembleCircle at his/her own responsibility and expense.

16. Provision of paid services

The basic services of the WebCeph service are provided for free use after watching advertisements, but some services may be provided as paid services. For example, tracing and basic cephalometric analysis functions of dental medical images can be used for free with advertisements, but functions such as analysis without advertisements or time-lapse video generation of treatment progress can only be used with a paid membership.

WebCeph members can apply for a paid service use contract according to the procedure provided by AssembleCircle and use the paid service after AssembleCircle's approval. However, in the following cases, it may not be accepted or the consent may be withheld.

1. If it is not your real name or if you use someone else's name
2. In case false information is entered or the required information requested by AssembleCircle is not provided
3. If it may negatively affect the status or reputation of the service
4. In case the service cannot be provided due to restrictions on the supply of the service provided by the paid service
5. If you are a member who has a history of requesting content that violates these terms and conditions

In principle, WebCeph members use the paid service provided by AssembleCircle after paying the usage fee. The payment method for the fee for the paid services provided by AssembleCircle is based on credit card payment, but there may be differences in the payment method for each paid service. In the case of a service for which regular monthly payment is made, monthly payment is automatically made unless you request cancellation of the regular payment. In the case of a service for which regular yearly payment is made, yearly payment is automatically made unless you request cancellation of the regular payment.

AssembleCircle may periodically request members' personal information that is essential for payment, and WebCeph members must accurately provide personal information requested by AssembleCircle.

17. Cancellation of use of paid services

If you wish to cancel the paid service use contract, WebCeph members can apply for cancellation of the paid service at any time by using the menu provided in the service, and AssembleCircle will process it promptly as stipulated by law.

The cancellation of the paid service use contract is established by the WebCeph member's application for cancellation of the paid service use contract and the approval of AssembleCircle.

If the application for termination of the paid service use contract is established by the approval of AssembleCircle, the termination will be processed after the period of use for the current subscription term is over, and regular payment will no longer occur. Paid service benefits are maintained normally until the last day of the current subscription term.

If you cancel a subscription service (e.g., monthly subscription service, yearly subscription service), you will not receive a refund for the service you have already paid for.

In the case of one-time payment products (e.g., content products, virtual credits, etc.) that are not subscription services, you can cancel through the WebCeph customer service center within 7 days from the payment date. You must notify the WebCeph customer service center (admin@assemblecircle.com) of your intention to cancel by e-mail, and AssembleCircle will refund within 5 business days after confirming the member's request and refund policy of WebCeph. WebCeph members cannot receive a refund for one-time payment products that have passed 7 days from the payment date.

If you want to use the service again after canceling the contract for using the paid service, you can apply for the paid service again using the menu provided in the service.

18. Delivery of opinions and improvements

Members may provide comments or feedback for the improvement of WebCeph services at any time through the WebCeph Service Customer Center (admin@assemblecircle.com).

19. Dispute resolution

The relationship between AssembleCircle and the member in relation to these terms and conditions or the WebCeph service is governed by Korean law. Any dispute arising between AssembleCircle and the member, any dispute arising out of these terms and conditions or in connection with the WebCeph service will be resolved in accordance with the procedures stipulated in the Korean Civil Procedure Act.

Notwithstanding the foregoing, mandatory consumer protection and data protection laws of the EU/EEA and the Member State of the user shall prevail where applicable.

20. Amendment of Terms and Conditions

AssembleCircle may revise these Terms and Conditions within the scope of not violating relevant laws and regulations. If these Terms and Conditions are revised, we will notify you in advance about the reason for the revision and the effective date. You can send your opinion on the revision of the terms from the date the revised terms are posted on the WebCeph website to the effective date.

In the event of a change to the terms and conditions that are unfavorable to the member, the change will be notified on the WebCeph website 30 days before the change date. If your opinion is not communicated to AssembleCircle by the notified effective date, you are deemed to agree to the revised terms and conditions. If you do not agree to the revised terms and conditions, we may not be able to provide you with WebCeph services subject to the revised terms and conditions.

International Transfers — Reference

Cross-border transfer mechanisms (e.g., the European Commission’s 2021 Standard Contractual Clauses and, where applicable, the EU–U.S. Data Privacy Framework) are implemented as described in our EU Privacy Policy and EU Privacy Notice. A signed copy of our standard DPA and the current SCCs can be provided upon request.