Privacy Policy

Article 1 (Purposes of Processing Personal Information)

The Company processes personal information for the following purposes. Personal information processed will not be used for any purpose other than the following, and if a purpose of use changes, the Company will take the necessary measures, such as obtaining separate consent in accordance with Article 18 of the Personal Information Protection Act.

1. Providing the emergency recording service: providing the voice recording function, and storing, playing and managing recording files on the device
2. Displaying ads (if introduced in the future): if ads are introduced, displaying personalized and non-personalized ads through Google AdMob and measuring ad performance
3. Processing in-app payments: purchasing paid features through Google Play Billing and checking purchase status
4. Improving the service: analyzing app stability, diagnosing errors and improving the user experience
5. Analyzing app usage statistics and measuring ad performance (effective October 29, 2026): compiling app usage statistics, such as installs, launches, screen navigation and purchases, through Google Analytics for Firebase; improving stability by device and version; and measuring the performance (install and purchase conversions) of Google Ads app campaigns run by the Company. This information is not used to analyze users' interests or preferences in order to provide personalized ads.

Article 2 (Personal Information Processed)

1. Information collected directly by the Company

2. Information automatically collected through the Google Analytics for Firebase SDK (effective October 29, 2026)

To analyze app usage statistics, improve stability and measure ad performance (install and purchase conversions), the Company includes Google LLC's Google Analytics for Firebase (firebase-analytics) SDK in the App. When the App is launched and used, this SDK automatically collects the following information and sends it to Google's servers.

The processing of the above information is governed by Article 5 (Entrustment of Processing) and Article 5-2 (Overseas Transfer), and Google's processing is subject to the Google Privacy Policy (https://policies.google.com/privacy).

3. Information that may be automatically collected through a third-party (Google) SDK if ads are introduced

If ads are introduced, the Google AdMob SDK included in the App may automatically collect the following information to provide ads. The items below are not currently collected through an advertising SDK, and this is separate from the collection through Google Analytics under paragraph 2.

If ads are introduced, the above data will be processed in accordance with Google's Privacy Policy (https://policies.google.com/privacy).

Article 3 (Processing and Retention Periods of Personal Information)

Article 4 (Provision of Personal Information to Third Parties)

The Company processes data subjects' personal information only within the scope specified in Article 1 and, except in the following cases, does not process it beyond its original scope or provide it to third parties without the data subject's prior consent.

1. Where the data subject has given prior consent
2. Where there are special provisions in law, or where it is unavoidable in order to comply with legal obligations
3. Where it is unavoidable for a public institution to perform its duties under laws and regulations

The processing of information through Google Analytics for Firebase is governed by Article 5 (Entrustment of Processing) and Article 5-2 (Overseas Transfer).

Article 5 (Entrustment of Personal Information Processing)

To provide the service smoothly, the Company entrusts personal information processing tasks as follows.

If the entrusted tasks or the processor change, the Company will disclose this through this Privacy Policy without delay.

Article 5-2 (Overseas Transfer of Personal Information)

Pursuant to Article 28-8 of the Personal Information Protection Act and Article 31(1)(2) of the Enforcement Decree of the same Act, the Company transfers personal information overseas as follows.

How to refuse overseas transfer, the procedure, and the effect of refusal

• Refusing transfer for analytics and ad performance measurement (effective October 29, 2026): In Android Settings > Privacy > Ads (on some devices, Settings > Google > Ads; menu names and locations may differ depending on the device manufacturer and OS version), selecting "Delete advertising ID" stops the advertising ID from being sent, and selecting "Reset advertising ID" breaks the link with the previous advertising ID. The App currently has no separate setting to turn off the collection of analytics information, so to stop all transmission, including usage statistics based on the app instance ID, you must uninstall the App. If an in-app setting to stop collection is provided, the Company will revise this Policy and explain it. You may request deletion of information already sent under Article 7(2).
• Refusing transfer for advertising: The current version of the App does not display ads, so no overseas transfer for displaying ads occurs, and no purchase is needed to avoid it. If ads are introduced in the future, you can refuse by selecting "Opt out of Ads Personalization" or "Delete advertising ID" in the same settings path above.
• Effect of refusal: Even if you refuse transfer for analytics and ad performance measurement or for advertising, you can use all features of the App, including recording and playback, without restriction. However, if ads have been introduced, non-personalized ads may be shown instead of personalized ads.
• Refusing payment-related transfer: If you refuse the transfer related to in-app payments, you cannot purchase paid features.

Article 6 (Procedures and Methods for Destroying Personal Information)

When personal information is no longer needed, such as when the retention period has expired or the purpose of processing has been achieved, the Company destroys it without delay.

1. Destruction procedure

• Recording files: They are deleted from the device when the user deletes them directly in the recording list in the App, and are deleted automatically when the App is uninstalled.
• App settings data: When the App is uninstalled, it is deleted automatically by the Android system together with the App's dedicated storage.
• Google Analytics data (effective October 29, 2026): It is deleted automatically from Google's systems when the retention period (2 months) expires. If a data subject requests deletion under Article 7(2), the Company processes the deletion of the data linked to that app installation (app instance ID) using the Google Analytics administration features.

2. Destruction method

• Electronic files: Deleted using technical methods that make the records impossible to reproduce.
• Recording files: Stored in app-specific storage (within /Android/data/); when the App is uninstalled, the operating system completely removes that directory.

Article 7 (Rights and Obligations of Data Subjects and Legal Representatives, and How to Exercise Them)

Data subjects (users) may exercise the following privacy rights against the Company at any time.

1. Recording files

• Access: You can view and play all recording files in the recording list in the App.
• Deletion: You can delete individual recordings in the recording list in the App, or delete all data by uninstalling the App.
• Suspension of processing: If you withdraw the microphone permission in Android settings, the recording function stops.

2. Advertising ID and analytics data

• Resetting or deleting the advertising ID (effective October 29, 2026): In Android Settings > Privacy > Ads (on some devices, Settings > Google > Ads; menu names and locations may differ depending on the device manufacturer and OS version), you can select "Reset advertising ID" or "Delete advertising ID". After deletion, the App cannot obtain the advertising ID.
• Requesting deletion of analytics data (effective October 29, 2026): If you make a request using the contact details in Article 17, the Company will process the deletion of the data linked to that app installation (app instance ID) using the Google Analytics administration features. Because the Company distinguishes users only by app instance ID, when making a request you need to provide, as instructed by the Company, information that can identify the installation (such as when the App was installed, the device model and the app version). If the installation cannot be identified, the Company will explain why, and the data will be handled through automatic deletion when the retention period (2 months) expires. Uninstalling the App ends collection under that app instance ID.
• Refusing personalized ads (applies if ads are introduced): You can select "Opt out of Ads Personalization" in the same settings path above.
• No ads at present: The current version of the App does not display ads, so there is no need to make a separate purchase, such as paid features, to avoid ads.

3. Managing app permissions

• You can withdraw permissions such as the microphone at any time in Android Settings > Apps > (this App) > Permissions.
• If you withdraw a permission, you cannot use the related function (recording), but files already saved are not affected.

4. Requests for transmission of personal information

Under Article 35-2 of the Personal Information Protection Act, data subjects may request that their personal information be transmitted to themselves or to a third party. Because the App stores recording files directly on the device, users can transmit them themselves using a file manager or the share function.

5. Exercising statutory rights

Data subjects may exercise their rights under Article 35 (access), Article 36 (correction and deletion) and Article 37 (suspension of processing) of the Personal Information Protection Act in writing or by email to the contact details in Article 17, and the Company will take action without delay. For children under the age of 14, a legal representative may exercise these rights on the child's behalf.

Article 8 (Measures to Ensure the Security of Personal Information)

The Company takes the following measures to ensure the security of personal information.

1. Isolated storage of recording files: Recording files are stored in app-specific external storage (getExternalFilesDir). On Android 10 and later, other apps cannot access these files directly. On Android 9 and earlier, apps with storage permission can read them.
2. Encryption of network transmission: All data transmission by the Google Play Billing and Google Analytics for Firebase SDKs is encrypted with TLS (Transport Layer Security). If ads are introduced in the future, data transmission by the AdMob SDK will also be encrypted with TLS.
3. No servers operated: The Company does not operate its own servers and does not send user data, including recording files, to Company servers. The statistical information in Article 2(2) is sent by the SDK directly to Google Analytics servers, not to Company servers, and the Company only views aggregated results in the Google Analytics administration console.
4. Google Drive backup (optional feature): Recording files are uploaded to the user's own Google Drive account only if a user who has purchased paid features turns this on directly in the app settings. It is off by default, and files are sent over TLS through the Google Drive API (drive.file scope, which accesses only files created by the App) without passing through Company servers. The Company cannot access backed-up files, and users themselves manage turning off backup and deleting files in Drive.
5. Principle of minimum permissions: The App asks users only for the minimum permissions needed to provide the service (microphone and notifications). Among the other normal permissions granted without the user's confirmation, the internet and network state permissions and the advertising ID (AD_ID) permission are used for transmission to Google Analytics (effective October 29, 2026).
6. Code obfuscation: ProGuard obfuscation is applied to the App's code to minimize the risk of data access through reverse engineering.
7. Automatic backup disabled: The Android system's automatic backup feature is disabled (allowBackup=false), so recording files are not automatically backed up to the cloud.

Article 9 (Installation, Operation and Refusal of Tools that Automatically Collect Personal Information)

1. Advertising identifier (Android Advertising ID) and app instance ID

From October 29, 2026, the Google Analytics for Firebase SDK included in the App generates an app instance ID and collects the Android Advertising ID (AAID) (Article 2(2)). The advertising ID is used to measure install and purchase conversions of ad campaigns run by the Company and is not used for personalized advertising.

• Purpose of collection: analyzing app usage statistics, improving stability, and measuring ad performance (install and purchase conversions)
• How to refuse: In Android Settings > Privacy > Ads (on some devices, Settings > Google > Ads; menu names and locations may differ depending on the device manufacturer and OS version), you can select "Delete advertising ID" (Android 12 and later) or "Reset advertising ID". To also stop collection based on the app instance ID, you must uninstall the App; an in-app setting to stop collection is not currently provided.

If ads are introduced in the future, the Google AdMob SDK may also collect the advertising ID to provide personalized ads, manage ad frequency and measure ad performance; in that case, the Company will revise this Policy and give notice, including how to refuse personalized ads through "Opt out of Ads Personalization".

2. Cookies

The App is not a web-based service and does not use cookies. However, the Company's website on which this Policy is posted (emergencyrecorder.com) may use Google Tag Manager and Google Analytics cookies to measure visit statistics, and users can refuse or delete cookies in their web browser settings. Refusing cookies does not restrict browsing of the website.

Article 10 (Collection, Use and Refusal of Behavioral Information)

The Company does not collect or use behavioral information for personalized advertising and does not currently display ads in the App. App usage information collected through Google Analytics for Firebase from October 29, 2026 (Article 2(2)) is used only to compile usage statistics and to measure the performance (install and purchase conversions) of ads run by the Company, and is not used to analyze users' interests or preferences to show personalized ads. To this end, the Company operates Google Analytics with ad personalization signals disabled and without using Google signals. If personalized ads are introduced in the future, behavioral information may be collected and used as follows, and the Company will revise this Policy and give notice before introducing them.

How to refuse the collection of behavioral information

• Resetting or deleting the advertising ID (effective October 29, 2026): "Reset advertising ID" or "Delete advertising ID" in Android Settings > Privacy > Ads (on some devices, Settings > Google > Ads; menu names and locations may differ depending on the device manufacturer and OS version)
• Refusing personalized ads (applies if ads are introduced): "Opt out of Ads Personalization" in the same settings path above
• No ads at present: The current version of the App does not display ads, so there is no need to make a separate purchase, such as paid features, to avoid ads.

Taking these refusal measures does not restrict your use of the App's core features, such as recording and playback.

Article 11 (Processing of Personal Information of Children under 14)

The Company does not knowingly collect personal information of children under the age of 14. Because the App does not require registration, it does not separately verify users' ages; however, if a child under the age of 14 uses the App, we recommend that the child use it under the guidance and supervision of a legal representative.

If the Company becomes aware that personal information of a child under the age of 14 has been collected, it will destroy that information without delay, and the legal representative may make related requests using the contact details in Article 17.

The Company does not process pseudonymized information and does not provide services that may disclose sensitive information within the meaning of Article 23(3) of the Personal Information Protection Act. The Company also does not make automated decisions that significantly affect the rights or obligations of data subjects (Article 37-2 of the same Act).

Article 12 (Special Notice Regarding Recording Files)

1. Storage and management of recording files

• All recording files are stored on the user's device. They are additionally backed up to the user's own Google Drive only if the user turns this on directly in the settings.
• The Company does not collect, view or transmit recording files and has no technical means of accessing them.
• The audio, content and file names of recording files are not sent to any analytics tool, including Google Analytics under Article 2(2).
• Management, backup and deletion of recording files are entirely the user's responsibility.

2. Legal notes on recording

• Articles 3 and 14 of the Protection of Communications Secrets Act of the Republic of Korea (통신비밀보호법) prohibit recording or listening to "a non-public conversation between other people." Recording a conversation in which the user personally takes part is not a conversation between other people. However, a conversation between other people in which the user does not take part may not be recorded even with the consent of some of the parties to the conversation, and a violation may be punished under Article 16(1) of the same Act by imprisonment of not less than 1 year and not more than 10 years and suspension of qualifications for not more than 5 years.
• Users bear legal responsibility for the use and sharing of recording files.
• The App is provided to support recording for lawful purposes (such as securing evidence or taking notes), and use for unlawful purposes is prohibited.

Article 13 (Terms of Service and Disclaimers)

1. Nature of the service and disclaimer of warranties (provided AS IS)

The App is a voice recording aid provided "AS IS" and "AS AVAILABLE". The Company makes no warranties of any kind, whether express or implied, including any warranty:

• that the service will meet users' requirements or expectations
• that the service will be provided without interruption, in a timely manner, securely or without errors
• of the success, completeness, accuracy, quality or continuity of recordings
• that a recording will always start, continue or be saved at any particular moment
• that recording files will have effect as legal evidence
• of the integrity of recording files, protection against damage, or permanent preservation
• that defects or errors in the service will be corrected
• of merchantability, fitness for a particular purpose or non-infringement (implied warranties)

2. Assumption of risk

Users acknowledge and agree that use of the service is entirely at their own discretion and risk. In particular, users acknowledge the following and assume the resulting risks:

• Recording may fail for various reasons, including the device, the environment and software
• Recording files may be damaged, deleted or lost
• Recording quality may vary greatly depending on the surroundings and the condition of the device
• Recordings may not be accepted as legal evidence
• The App may not work properly in an emergency
• Service functions may be restricted or changed due to Android operating system updates or policy changes by device manufacturers

3. Disclaimer for recording failures

Recording may fail, stop or be missed, and recording files may be damaged or deleted, for reasons including but not limited to the following, and to the maximum extent permitted by applicable law, the Company is not liable for any direct, indirect, incidental or consequential damages resulting from them.

4. Disclaimer regarding legal evidence

• The Company does not guarantee that recording files will be accepted as evidence by a court or an investigative agency.
• Whether a recording file is accepted as evidence, its probative value and its lawfulness are matters for the discretion of the competent court or investigative agency, and the Company bears no responsibility for them.
• If a user relies solely on recordings made with the App to secure legal evidence, the resulting risk rests entirely with the user. In important situations, we strongly recommend that you always use multiple means of securing evidence at the same time.
• The Company's marketing materials, app descriptions, promotional text, store listings and the like describe the App's general functions and are not a warranty, promise or contractual obligation as to successful recording or legal effect.

5. Not a substitute for emergency services

6. Disclaimer of professional advice

The service does not provide legal, security, medical or other professional services or advice. The service is only a recording aid, and no professional relationship of trust is formed between users and the Company. The legality of recording depends on the laws of the relevant jurisdiction, and users are solely responsible for checking and complying with the applicable laws before recording.

7. Changes to or suspension of the service

• The Company may change, suspend or terminate the provision of the App without prior notice for reasons such as business judgment, technical reasons, changes in Google Play policies, changes in laws or management reasons.
• Unless there is intent or gross negligence on the part of the Company, the Company is not liable for damages incurred by users due to the suspension or termination of the App service.
• The same applies where the App does not work properly for reasons beyond the Company's control, such as changes in Google Play Store policies, Android OS updates or government regulations.

8. Purchases of paid features and withdrawal of purchase

Withdrawal of purchase (Article 17 of the Act on Consumer Protection in Electronic Commerce, etc.)

• Users may withdraw their purchase within 7 days after purchasing paid features.
• However, under Article 17(2)(5) of the same Act, withdrawal is restricted once provision of the purchased paid features has begun.
• In accordance with Article 17(6) of the same Act, the Company provides a free version so that users can sufficiently try the App's basic features before purchase.
• Where the purchase consists of divisible digital content, it may be withdrawn for any part whose provision has not begun.
• If the purchased features differ from what was displayed or advertised, or the contract is performed differently from its terms, users may withdraw the purchase within 3 months from the date of supply, or within 30 days from the date they became aware, or could have become aware, of that fact (Article 17(3) of the same Act).
• Requests for withdrawal and refunds can be submitted through Google Play or to support@emergencyrecorder.com.

• A purchase of paid features is a license to use the features provided at the time of purchase and does not guarantee the provision of any specific feature in the future or the permanent maintenance of the service.
• If the App service ends, refunds for paid features already purchased will be handled in accordance with the withdrawal provisions above and the Act on Consumer Protection in Electronic Commerce, etc., and the Company will also explain the Google Play refund procedure.
• Expressions such as "lifetime use" and "unlimited" refer to the period during which the App service is normally provided and do not guarantee the continued existence of the Company or the permanent provision of the App. Events such as the Company's closure, transfer of the business or termination of the service may occur.
• The content of paid features may change with app updates, and the Company will make efforts, within a reasonable scope, to provide equivalent or similar features.

9. Scope of liability for damages

To the maximum extent permitted by applicable law, liability for damages is limited as follows.

10. Force majeure

The Company is not liable where it cannot provide the service due to any of the following causes.

• Natural disasters (earthquakes, floods, typhoons, volcanic eruptions, etc.)
• War, insurrection, riots, acts of terrorism
• Government regulations or orders, or changes in laws
• Power outages, communication network failures
• Cyberattacks, hacking, DDoS attacks, malware infections
• Infectious diseases, pandemics, quarantine measures
• Suspension, changes or policy changes of third-party platforms such as Google Play and Android OS
• Hardware or software defects or policy changes of device manufacturers
• Insufficient storage, battery drain or power loss on the user's device
• Other causes beyond the Company's reasonable control

Article 14 (Obligations of Users and Indemnification)

1. Users must use the service in compliance with these Terms, this Privacy Policy and applicable laws.
2. Users are responsible for checking and complying with the recording laws of the relevant jurisdiction (such as the Protection of Communications Secrets Act) before recording, and all legal consequences of unlawful recording are borne entirely by the user.
3. If the Company suffers damage due to a user's intentional or negligent breach of these Terms, an unlawful act, or an infringement of the rights of a third party, the user is liable to compensate for that damage. However, this does not apply to any part attributable to the Company, and the scope of compensation is limited to damage that has a reasonable causal relationship with the user's conduct.
4. Users must not rely on recordings made with the service as their only means of evidence and, in important situations, must always use multiple means of recording at the same time.

Article 15 (Governing Law and Dispute Resolution)

1. The interpretation and application of these Terms and this Privacy Policy are governed by the laws of the Republic of Korea.
2. Matters not set out in these Terms are governed by applicable laws, such as the Act on the Regulation of Terms and Conditions, the Act on Promotion of Information and Communications Network Utilization and Information Protection, etc., and the Act on Consumer Protection in Electronic Commerce, etc.
3. If a dispute arises in connection with use of the service, the Company and the user will consult in good faith to resolve it amicably.
4. If the dispute is not resolved through consultation, it will be resolved by the court having jurisdiction under the Civil Procedure Act.

Article 16 (Severability and Entire Agreement)

1. Severability

If any provision of these Terms is held invalid or unenforceable by a competent court, only that provision will be invalid, and the validity and enforceability of the remaining provisions will not be affected. A provision held invalid will be deemed replaced by a valid provision that best reflects its intent.

2. Entire agreement

These Terms constitute the entire agreement between the Company and users regarding the use of the service and supersede all prior agreements, promises and understandings regarding the use of the service.

Article 17 (Privacy Officer)

The Company has designated the following Privacy Officer to take overall responsibility for personal information processing and to handle data subjects' complaints and provide remedies for damage in connection with personal information processing.

Data subjects may contact the above for any inquiries, complaints, remedies for damage or other matters related to personal information protection that arise while using the App. The Company will respond to and handle data subjects' inquiries without delay.

Article 18 (Changes to This Privacy Policy)

This Privacy Policy was first established on February 16, 2026, and the current version (1.3) was announced on September 29, 2026 and applies from October 29, 2026. Until the effective date, the previous version (1.2) applies; the previous version is available (in Korean) at /privacy/archive/v1.2/.

If any content of this Privacy Policy is added, deleted or modified, the Company will disclose the reasons for and details of the change through in-app notices or this page from 7 days before the effective date. However, for material changes to users' rights, such as the addition of collected items, purposes of use, processing entrustment or overseas transfer, the Company will give notice at least 30 days in advance.

Article 19 (Remedies for Infringement of Rights)

To obtain remedies for infringement of personal information, data subjects may apply to the following organizations for dispute resolution, consultation and the like.