Artificial Intelligence (AI) Ethics Policy

Article 1 (Principles of Responsible AI Operation)

In developing and operating AI technology, Software Creation Studio observes the following principles.

1. Transparency

Software Creation Studio provides transparent information, to the extent possible, about the purposes and manner of operation of its AI systems.

Where the Client provides AI-based services to end users, Software Creation Studio supports the relevant technical environment and manner of operation so that users can understand whether AI is being used.

2. Accountability

Software Creation Studio continuously manages the risk factors that may arise in the design, development, and operation of the AI Services, and applies technical and administrative safeguards for responsible AI use.

The outputs provided by the AI Services are provided for work-support and reference purposes, and the Client's final decisions and business judgments made on that basis are made under the Client's own responsibility.

3. Safety

Software Creation Studio applies technical and administrative measures for security management, access control, data protection, and ensuring service stability so that the AI Services can be operated reliably.

4. Privacy & Data Protection

Software Creation Studio complies with applicable laws and security standards in order to protect personal information and customer data in the course of operating the AI Services.

Customer data is handled with respect for the customer's rights, and is not used for further training of AI models, adjusting weights, or improving generalized AI models without the Client's consent.

Article 2 (Principles of Human-Centered AI Operation and Oversight)

Software Creation Studio follows the principle that AI should be used as a tool to support operational efficiency and decision-making, rather than to replace human judgment.

The outputs provided by the AI Services should be used as reference information, and appropriate human review and judgment should be exercised in important decision-making processes.

Where the Client makes important judgments in legal, financial, medical, human resources, or other matters based on AI outputs, the Client must operate a separate review procedure.

Software Creation Studio supports the technical environment so that the Client can, as needed, connect human consultation or review procedures.

Article 3 (Principles of Fairness and Bias Management)

Software Creation Studio endeavors to ensure that the AI Services do not produce unjust discrimination or unfair outcomes for particular individuals, groups, or customers.

In the course of operating the AI Services, it continuously reviews data quality and the appropriateness of outputs.

It carries out technical and administrative improvement activities to minimize bias that may arise in AI models or in data processing. Specifically, Software Creation Studio carries out the following bias management activities.

• It regularly reviews the bias risk of the AI Services at least once a year and, based on the review results, carries out the necessary improvement measures.
• The scope of the bias review includes quality evaluation of the AI Services' outputs, analysis of data bias, and review of user feedback.
• Upon the Client's request, it shares, within a reasonable scope, the results of the bias evaluation of the AI Services applicable to that Client.

With respect to bias factors that may arise from the data or operating environment provided by the Client, Software Creation Studio reviews improvement measures in cooperation with the Client.

Article 4 (Principles of AI Data Protection and Security)

Software Creation Studio treats the protection of the Client's data as a core principle of operating the AI Services.

Data that the Client provides to the AI Services is handled securely within the scope of the purpose of service provision.

Customer data is not used for further training of AI models, adjusting weights, or improving services for other customers without the Client's consent.

In the course of operating the AI Services, technical and administrative safeguards in accordance with applicable laws and security standards are applied to protect personal information and sensitive information.

The conversation data and context information of the PolyBot service are managed securely in each Client's own environment and are protected so as not to be commingled with the data of other Clients.

Article 5 (Transparency of AI Use and User Rights)

Software Creation Studio endeavors to enable users of the AI Services to understand whether AI technology is being used and to respond appropriately.

Where the Client applies an AI service such as PolyBot to services directed at end users, Software Creation Studio provides support so that the Client can clearly indicate that it is an AI-based service.

Software Creation Studio supports the configuration of the Client's operating environment so that users of AI-based consultation or automated features can, where necessary, use human consultation or an alternative procedure.

Software Creation Studio places importance on protecting users' rights in the course of the use of the AI Services.

Article 6 (AI Risk Management and Incident Response)

Software Creation Studio endeavors to manage the errors, security issues, and service risk factors that may arise in the course of operating the AI Services.

1. Continuous Monitoring

Software Creation Studio continuously monitors and carries out improvement activities with respect to errors, security vulnerabilities, or unexpected results that may arise during the operation of the AI Services.

2. Root-Cause Analysis and Remediation

Where an AI-related problem is identified, Software Creation Studio endeavors to ensure service stability through root-cause analysis and the necessary technical measures.

3. Incident Notification and Response Procedures

Where a serious service failure, security breach, or serious malfunction of the AI system occurs, Software Creation Studio responds in accordance with the following procedures.

• (1) Initial Notification: Within 24 hours of becoming aware of a serious incident, Software Creation Studio notifies the affected Client of the incident in writing (including by email). The notification includes an overview of the incident, the anticipated scope of impact, and the initial response measures.
• (2) Post-Incident Analysis: Within a reasonable period after the incident is resolved, Software Creation Studio endeavors to prepare a Post-Incident Report and provide it to the Client. The report includes the cause of the incident, the scope of impact, the response measures, and a recurrence-prevention plan.
• (3) Legal Notification in the Event of a Data Breach: Where a personal information breach is involved, Software Creation Studio notifies the competent supervisory authority within the statutory deadline (72 hours) in accordance with the Korean Personal Information Protection Act and Article 33 of the European GDPR, and also notifies data subjects in accordance with applicable laws.
• (4) Client Cooperation: Where necessary, Software Creation Studio cooperates with the Client to resolve the problem and minimize harm.

Article 7 (AI Governance and Compliance with Global Standards)

Software Creation Studio maintains a continuous management framework for responsible AI operation.

Taking into account internationally discussed AI ethics principles and risk management standards, it continuously improves its AI service operating standards. Software Creation Studio refers to the following international frameworks and standards.

• OECD Principles on AI (2019)
• EU AI Act (Regulation (EU) 2024/1689)
• ISO/IEC 42001 (Artificial Intelligence Management System)
• UNESCO Recommendation on the Ethics of AI (2021)

In the course of operating the AI Services, it places importance on the following principles.

1. Risk-Based Approach

It applies an appropriate level of management, taking into account the purpose, scope of impact, and potential risk factors of the AI system.

2. Transparency & Explainability

It provides information, to the extent possible, so that the purposes and manner of operation of the AI Services can be understood.

3. Safety & Reliability

It carries out continuous inspection and improvement activities for the stable operation and quality improvement of the AI Services.

4. Responsible AI Use

It endeavors to ensure that AI technology is used in a manner that respects human rights and social values.

Article 8 (AI Ethics Governance Framework)

To implement and oversee this Policy, Software Creation Studio operates the following internal governance framework.

1. Overall Responsibility for Policy Implementation

Implementation of this Policy is overseen by the Data Protection Officer (DPO). The Data Protection Officer regularly reviews compliance with the AI Ethics Policy and, where necessary, carries out improvement measures.

2. External Advice

Software Creation Studio may seek the advice of external legal, technical, and ethics experts where a significant AI ethics matter arises or where policy improvement is required.

3. Periodic Review

This Policy is reviewed regularly, at least once a year, to reflect advances in AI technology, changes in law, and global AI ethics trends, and is amended where necessary.

4. Contact

Inquiries and comments regarding this Policy may be submitted through the contact details below.

• Data Protection Officer: Peter Cho
• Email: governance@softwarecreation.studio
• Address: 100 Cheonggyecheon-ro, Jung-gu, Seoul, Signature Tower West, 9F

Article 9 (Relationship with Related Policies)

This Policy applies together with Software Creation Studio's Terms of Service, Privacy Policy, Cookie Policy, and Artificial Intelligence (AI) Service Operating Policy.

This Policy sets out the ethical principles and operating direction concerning the use of AI technology; the related policies prevail with respect to service use conditions, data processing standards, scope of liability, and use restrictions.

Matters concerning personal information protection, service use conditions, and contracts are governed by the Privacy Policy and the Terms of Service, respectively.

Article 10 (Changes to the Policy and Notice)

Where this Policy is changed, Software Creation Studio will announce the reasons for, and content of, the change, together with the effective date, on its website at least 30 days before the effective date.

Previous versions of the Policy are retained so that they can be reviewed via the website.

Supplementary Provisions

This Artificial Intelligence (AI) Ethics Policy takes effect on July 3, 2026.

Software Creation Studio supports its customers' digital transformation and sustainable growth through the responsible use of AI technology, and will continuously strive to provide trustworthy AI Services.