The Black Label Inc. (the “Company”) hereby establishes and implements this Privacy Policy in accordance with the Personal Information Protection Act of the Republic of Korea (the “PIPA”) to protect the rights and interests of data subjects using the Company’s mobile application, “Churrrrr” (the “Fan Communication Application”). This Privacy Policy shall be made readily accessible at all times in the Fan Communication Application, enabling the user of the Fan Communication Application (the “Users”) to understand how their personal information is processed by the Company, as well as the protective measures the Company has established to secure such information.
The Company processes the User’s personal information for the following purposes. The Company does not process personal information for any purposes other than those specified herein. In the event of any changes to the purposes of processing, the Company shall take all necessary measures, including obtaining separate prior consent from the User.
To verify the intent of membership registration or withdrawal, to manage and maintain membership eligibility, to prevent unauthorized access to services, and to issue notices.
To provide fan communication services and related content.
To address complaints, including acknowledging and resolving the complaints, and communicating the outcome to the complainant, to establish plans for service improvement, and to maintain records related to dispute resolution.
The items of personal information processed by the Company, as well as the corresponding retention and usage periods are as follows:
| Purpose of Processing | Item of Personal Information | Retention and Usage Period |
| Membership Registration and Management | [Mandatory Items]: Name, date of birth, gender, nationality, email address (ID), and password | applicable laws or regulations shall be retained until the later of: (i) the expiration of the statutory retention period; or (ii) the date of membership withdrawal) |
| Provision of Services |
[Mandatory Items]: Email address, nickname, nickname for chat,
and date of birth [Optional Item]: Profile picture |
|
| Complaint Resolution and Service Improvement | [Mandatory Items]: Name, email address, nickname, nickname for chat, and access and activity log information (including IP information, mobile device information, log history, history of service usage, and history of change in User information) |
| Item of Personal Information | Legal Basis for Retention | Retention Period |
| Access IP information, access and activity log history | Article 15-2 of the Protection of Communication Secrets Act of the Republic of Korea | Three (3) months from the date of creation of the information |
| Records of agreements, records of exercising the consumer right of revocation | Article 6 of the Act on the Consumer Protection in Electronic Commerce of the Republic of Korea | Five (5) years from the date of creation of the information |
| Records of payments and provision of goods/services | " | Five (5) years from the date of creation of the information |
| Records of resolving consumer complaints or dispute | " | Three (3) years from the date of creation of the information |
| Books and records of all transactions, as required by applicable tax laws | Article 85-3 of the Framework Act on National Taxes of the Republic of Korea and Article 144 of the Framework Act on Local Taxes of the Republic of Korea | The periods specified in Article 85-3 of the Framework Act on National Taxes of the Republic of Korea and Article 144 of the Framework Act on Local Taxes of the Republic of Korea |
The Company does not provide the User’s personal information to any third party, except under the following circumstances:
(i) The User has provided prior consent;
(ii) The Company is obligated to provide the personal information of the User to third parties pursuant to applicable laws or regulations;
(iii) It is deemed necessary by the Company to protect the User from imminent danger to their life or safety; or
(iv) Any of the circumstances set forth in Article 17, Paragraph 1 or Article 18, Paragraph 2 of the PIPA.
| Trustee | Entrusted Work |
| SmileShark Co., Ltd. | IT systems operation and management, server management |
- Destruction Procedure: The Company selects personal information subject to destruction and proceeds with destruction after obtaining approval from the Personal Information Protection Officer.
- Destruction Method: Personal information in electronic form is destroyed using technical methods that render it irretrievable. Personal information in physical form is destroyed by shredding or incineration.
In accordance with Article 29 of the PIPA, the Company implements the following technical, administrative, and physical measures to ensure the secure processing of personal information:
- The User’s personal information is protected by password and encryption, and separate security protocols, including encryption of files and data transmissions, are implemented to safeguard important data.
- The Company implements protective measures, including the use of antivirus programs and software that are regularly updated, to prevent damage from computer viruses.
- The Company implements an intrusion detection and firewall system, which are monitored and managed twenty-four (24) hours a day, to prevent the leakage or damage of the User’s personal information caused by hacking, viruses, and other cyber threats.
- The Company implements an internal management plan to ensure the secure processing of the User’s personal information.
- The Company grants access to the User’s personal information only to a minimum number of authorized personnel.
- The Company conducts regular training sessions for officers and employees who process the User’s personal information to ensure they are up to date with security technologies and legal obligations regarding data protection of personal information.
- All officers and employees processing the User’s personal information are required to submit security pledges. The Company has established internal procedures to prevent information leakage and to monitor compliance with this Privacy Policy.
- The transfer of responsibilities among officers and employees processing the User’s personal information is conducted under secure conditions. The Company clearly defines accountability for any personal information breaches that occur during the onboarding and offboarding of its staff.
- The User’s personal information is stored separately from other data.
- The Company has designated specific areas as data centers or data storage rooms and restricts access to such areas.
The Company designates the following individual as its Personal Information Protection Officer, responsible for supervising the processing of personal information, addressing User complaints, and providing remedies. The User may contact either the Personal Information Protection Officer or the Personal Information Protection Manager regarding any matters related to the processing of their personal information that may arise while using the Fan Communication Application.
| Classification | Name | Position / Department | Email Address | Phone Number |
| Personal Information Protection Officer | Kyung-In Jung | CEO | contact@theblacklabel.com | +82 1551-0391 |
| Personal Information Protection Manager | Chang-Hoon Lee | Director / Business Strategy Development | contact@theblacklabel.com | +82 1551-0391 |
If the User is not satisfied with the Company’s response to a complaint or remedy, or if a dispute arises between the Company and the User, the User may contact the following institutions in the Republic of Korea to seek assistance.
| Institution | Website | Telephone Number (only available in the Republic of Korea) |
| Personal Information Infringement Report Center | https://privacy.kisa.or.kr | 118 |
| Personal Information Dispute Mediation Committee | https://www.kopico.go.kr | 1833-6972 |
| Cybercrime Investigation Division of the Supreme Prosecutors’ Office | https://www.spo.go.kr | 1301 |
| Cyber Security Division of the National Policy Agency | https://cyber.go.kr | 182 |