Fannuri Service Privacy Policy

Article 1: Overview of Privacy Policy

This Privacy Policy (hereinafter "Policy") applies to the Fannuri application (hereinafter "Service") operated by Ubnuri Co., Ltd. (hereinafter "Company") and explains how users' personal information is collected, used, and protected. This Policy has been prepared in reflection of the "Personal Information Protection Act" as well as global privacy standards such as the GDPR and CCPA. The meaning of the term "Personal Information" used in this Policy is as follows:

Personal Information Protection Act (Korea)

The term "Personal Information" used in this Policy refers to personal information as defined in Article 2 of the Personal Information Protection Act
For the purposes of EU General Data Protection Regulation No. 2016/679 (hereinafter "GDPR") and the UK Data Protection Act 2018, the term "Personal Information" refers to any information relating to an individual or information that can directly or indirectly identify an individual, particularly by reference to identifiers such as a name, identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that individual.
For the purposes of the California Consumer Privacy Act (hereinafter "CCPA"), the term "Personal Information" also includes information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

Article 2: Purposes of Processing Personal Information

The Company processes the personal information of Members for the following purposes in accordance with relevant laws and regulations:
- Utilization for Marketing and Promotional Purposes

· Individually sending promotional information (events, promotions, etc.) via email or app notifications (conducted only with the user's separate consent).

- Sending individual advertisements and promotional information (events, promotions, etc.) via email or app notifications (Only conducted with the user's separate consent)

Provision of Company Websites, Apps, Products, and Services: Providing the Company’s websites, apps, products, and services; account registration; guidance and consultation on service use; identification and prevention of fraudulent use; providing Fannuri community registration and community activity features; statistics and analysis; provision of promotional materials (upon request); contacting Members regarding the Company’s websites, apps, or services; provision and operation of event services (verifying applicants for event participation, providing and delivering prizes to winners, and other grievance handling); and production of personalized products for individuals.
Business Operations of the Company: Operating and maintaining the Company’s websites, apps, and services; providing content to Members; displaying advertisements and other information to Members; user authentication for the sale/delivery of goods and the identification/prevention of fraudulent use, such as duplicate purchases or use; confirmation of intent through communication with Members via the Company’s websites, apps, or services; and informing Members of changes to the Company’s websites, apps, or services.
Communication and Marketing: Providing services to send news and other information that may be of interest to the Member via contact methods such as email and app push notifications, provided that prior consent has been obtained from the Member in accordance with relevant laws and regulations; providing customized services for each Member on the Company’s websites, products, and services; retaining and updating Member contact information when necessary; allowing Members to withdraw consent or configure opt-out settings for emails sent by the Company and recording the Member's choices.
IT System Management: Management and operation of the Company’s communication, IT, and security systems; auditing (including security audits) and monitoring of related systems.
Improvement of Company Websites, Apps, and Services: Identifying issues related to the Company’s websites, apps, or services; establishing plans to improve the Company’s websites, apps, or services; and developing new websites, apps, or services.

Article 3: Categories of Personal Information Processed

The personal information of Members processed by the Company is as follows:

What is Essential Information? Information required to perform the essential functions of the corresponding service.
What is Optional Information? Additional information collected to provide more specialized services. (There are no restrictions on using the service even if optional information is not provided.)

1. Categories of Personal Information Processed Without Member Consent

Legal Basis: Please refer to the "Legal Basis" section for each processing point below.

[Required items]

Service	Time of processing	Legal basis for processing	Personal information Processed	Period for retention and use
Fannuri	Paid Service purchase	Article 15, Paragraph 1, Subparagraph 4 of the Korean Personal Information Protection Act (Conclusion of Contract)	Receipt number (for in-app purchases)	For 3 months after leaving the service or period stated in relevant laws.
For all service	Event	Article 15, Paragraph 1, Subparagraph 4 of the Korean Personal Information Protection Act (Performing of Contract)	Participation in community events: Weverse Account (email), name, and membership number (for membership holders)	For 1 year from the end of the relevant event, and up to 6 months from the announcement of prize winners for the personal information of non-winning participants.
	Event		Offline performance events such as fan meetings, public broadcasts, etc.: Video information (recorded during the event) Online performance events such as video call fan meeting: Video information (recorded during the event)	Within 7 days after the end of events such as fan meetings or retention period according to relevant laws.
	Handling customer inquiries	Article 15, Paragraph 1, Subparagraph 4 of the Korean Personal Information Protection Act (Performing of Contract)	General inquiry: weverse account (email address) and the details of the customer inquiries Purchase inquiry: weverse account (email address), the details of the customer inquiries, mobile phone number	Stored for 3 years after the customer inquiry in accordance with relevant laws.

2. Personal information items processed with the member's consent

Legal basis: Article 15, Paragraph 1 of the Korean Personal Information Protection Act (in the case where consent is obtained from a data subject)

[Required items]

Service	Time of processing	Personal information Processed	Period for retention and use
Fannuri Account	New account sign-up	General members: Account (email address), password, name, nickname Members connected with social media accounts (Google, Apple): Account (email address), name, nickname	For 3 months after deleting the account or period stated in relevant laws.
Fannuri	Service sign-up	User verification information (for connecting to Fannuri account)	For 3 months after leaving the service or period stated in relevant laws.
	When using the artist community services	Nickname, profile image
	Processing refund requests from customers using paid services	Fannuri account ID (email address), name (first name and last name), bank name, bank account number, address	For 5 years after the refund, as stated in relevant Korean laws.
	When reporting illegally filmed materials	Name, mobile phone number (telephone number), email address	For 3 years from the reported date, as stated in relevant Korean laws
	For making a reservation for K-Pop Concert service	Mobile phone number, email address and ticket number	3 months after the service's purpose is achieved
K-Pop Concert	For providing performance contents	Email address, user verification information (for connecting to Fannuri account), and purchase status of related products.	90 days after the ends of performances (concerts, showcases, fan events, etc.).
For all Service	Event	Prize shipping: weverse account (email address) and recipient information (Name, mobile phone number, and address)	For 1 year from the end of the relevant event, and up to 6 months from the announcement of prize winners for the personal information of non-winning participants
	Event	Offline performance events such as fan meetings, public broadcasts, etc.: weverse account (email address), name, date of birth, and phone number Online performance events such as video call fan meeting: weverse account (email address), name, date of birth, phone number, and social media account (KakaoTalk or LINE, etc)	For 1 year from the end of the event for event winners, and for up to 3 months from the end of the event for non-winning participants
	Handling customer inquiries	General inquiry: weverse account (email address) and the details of the customer inquiries Purchase inquiry: weverse account (email address), the details of the customer inquiries, mobile phone number	Stored for 3 years after the customer inquiry in accordance with relevant laws.
	For SMS authentication	Country code and mobile phone number	For 1 year after deleting the account, or as stated in the relevant Korean laws
	Transmission of advertising information for marketing	Email address, automatically generated information(App push identifier, device information, etc.)	For 3 months after deleting the account or period stated in relevant laws.
	Accessing and using the service, providing services for reward	Information automatically generated by cookie, service usage history (date of log-in, IP address, fraudulent usage, etc), device information (unique device identifiers and OS version) and logged-in country	For 3 months after leaving the service or period stated in relevant laws.

Our service is not offered for children (under 14 years old for South Korean and under 16 years old for international users). If we discover that we have collected the personal information of a child, we will delete the information and cancel the user's account. If you believe that we have collected information of a child, please inform us via contact information in Article 10.

Article 4 Retention of Personal Information

If we collect any personal information from you, we comply with our internal policy to use and retain such personal information for the period during which you use our services.

We immediately destroy your personal information when it becomes unnecessary, such as when the retention period has elapsed or when the purpose of processing personal information has been achieved.

In addition, we separately store and manage your personal information until the retention period specified in the provisions of applicable law has elapsed. If we need to preserve personal information in accordance with our internal policies, we will retain relevant personal information for a specified period.

Keeping Of Personal Information In Accordance With Relevant Laws

Details About Information Kept In Accordance With Our Internal Policies

· Records regarding contracts or withdrawal of offer, etc.: 5 years (Act on the Consumer Protection in Electronic Commerce)

· Records regarding payment and supply of goods, etc.:

- Weverse JAPAN: 7 years and 2 months from the end of the month based on transaction standards (Japanese Consumption Tax Law)

- Others: 5 years (Act on the Consumer Protection in Electronic Commerce)

· Records regarding the handling of consumer complaints or disputes: 3 years (Act on the Consumer Protection in Electronic Commerce)

· Service users’ Internet logs, materials to trace location of access, history of website visits: 3 months (Protection of Communications Secrets Act)

· Records regarding labeling and advertising: 6 months (Act on the Consumer Protection in Electronic Commerce)

· Retention of records of technical and managerial measures for preventing the circulation of illegally filmed materials: 3 years (Telecommunications Business Act)

· Records on provision of goods or services: 3 months from membership cancellation or the relevant period under applicable law

· Records on provision of services to promotional event participants

- Prize shipping events: For 1 year from the end of the event for event winners, and for up to 6 months from the announcement of prize winners for non-winning participants

- Offline/online concerts and events: For 1 year from the end of the event for event winners, and for up to 3 months from the end of the event for non-winning participants

· If prior consent has been obtained from individual members with respect to the period for retaining their personal information: The relevant retention period

Article 5 Procedures and Methods of Destroying Personal Information

Once the purposes of collection and use of your personal information are achieved, we destroy your personal information in accordance with our internal policies and other applicable laws. However, personal information collected with your consent or stored in the form of electronic files will be deleted using technical means that make the records unreproducible, and personal information printed on paper such as filings or printed materials will be shredded or incinerated.

Article 6 Your Legal Rights

Subject to applicable law, you may have the following rights relating to your personal information managed by us. You may exercise your rights at any time, by contacting the data protection officer via the contact information provided in Article 10 (Data Protection Officer).

The right not to provide your personal information to us (however, please note that we will be unable to provide you with the full benefit of our Sites, Apps, or services, if you do not provide us with your personal information – e.g., we might not be able to process your requests without the necessary details);
The right to request information regarding the nature, processing and disclosure of your personal information managed by us and request access to, or copies of such personal information;
The right to request rectification of any inaccuracies in your personal information managed by us;
The right to request, on legitimate grounds:
- Deletion of your personal information managed by us; or
- Suspension of processing of your personal information managed by us;
The right to have certain personal information transferred to another entity, in a structured, commonly used and machine-readable format, to the extent applicable;
Where we process your personal information managed by us on the basis of your prior consent, the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the processing of your personal information in reliance upon any other available legal bases, as applicable); and
The right to submit complaints to an authority in charge of protection of data regarding the processing of your personal information managed by us.

Article 7 Technical/Administrative Measures for Protecting Personal Data

When handling personal information, we take appropriate measures to keep the information safe and prevent from loss, theft, leakage, falsification, or damage, and we take technical measures as follows:

Your personal information is protected by password and encrypted information. However, your information can be exposed to others in many ways including when you use the public internet, so you need to be responsible for protecting your own information. We are not responsible for any damages that arise from your negligence or the fundamental nature and risks of the internet.
Your personal information is protected with a password and encrypted information by default, and important data are protected with separate security functions by encrypting files and transmitted date.
We use vaccine programs to prevent possible damage by computer viruses, and vaccine programs are updated periodically.
We prevent leakage and damage of personal information caused by hacking and viruses by monitoring the system 24 hours a day using a system that detects and blocks external intrusion.

We fully acknowledge the importance of your personal information, and accordingly, we have a reasonably limited number of employees handling personal information. The personnel in charge of protecting personal information conducts periodical education for the employees, putting the utmost effort to protect personal information. Also, we periodically check the compliance status of commitments stated in the policy and relevant employees, and when we detect any violation, we immediately correct and improve the issue and take necessary measures.

Article 8 Installation and Operation of Automatic Collection Tools for Personal Information and Refusal Thereof

We use cookies to store and discover information about members. Cookies are strings of small amounts of text transmitted by the website server to users’ computer browsers (e.g., Internet Explorer, Safari, Chrome, Firefox). Cookies identify each member’s computer, but do not identify individual members.
We use Google Analytics (Terms of Service)and Firebase(Terms of Service), API provided by Google (Privacy Policy), for providing services and statistics analyses.

(1) Operation of Cookies

① Provide differentiated information depending on each individual’s interests
② Analyze members’ and non-members’ frequency of visits and time spent on each visit to identify members’ tastes and interests for use in targeted marketing
③ Identify the traces of browsing records of contents in which members were interested in to provide personalized services on the next visit
④ Analyze customers’ habits and use the results as criteria for service reorganization, etc.

(2) Cookie options

By adjusting the settings on their web browser, members may accept all cookies, receive notifications whenever cookies are installed, or refuse all cookies.

However, if you refuse cookies, you may not be able to use certain functions of the service that require login.

You can set whether to permit cookies (on Internet Explorer) as follows:
① Go to [Tools] and [Internet Options].
② Click [Privacy].
③ Under the tab [Settings], choose the level you want from "Accept All Cookies – Low – Medium – Medium High – High – Block All Cookies."

(3) Cookies expire when you close or log off from the browser.

(4) The Company collects and uses the minimum online behavioral information to provide optimized services such as personalized advertising to users.

The Company collects and uses the minimum online behavioral information to provide optimized services such as personalized advertising to users. Behavioral information refers to online activity information that can infer or analyze an individual's interests, preferences, inclinations, or tendencies, such as website and app visit history, purchase, and search history.

① User protection when processing behavioral information

When providing services using behavioral information, such as personalized advertising, the Company collects only the minimum behavioral information and does not collect sensitive behavioral information that may clearly infringe on an individual's rights, interests, or privacy, such as thoughts, beliefs, family and kinship relationships, educational background, medical history, or other social activity history. The Company does not collect behavioral information for personalized advertising purposes from online services primarily used by children under 14 years of age and does not provide personalized advertising to them.

② Notice on collection and processing of behavioral information

The company collects behavioral information for the services it operates as follows and allows online personalized advertising business operators to collect and process behavioral information.

[Notice on collection and processing of behavioral information]

Items of behavioral information collected and processed	The user's web and app service visit history, usage records such as searches and clicks, advertising identifiers
Method of collecting and processing behavioral information	Automatically collected and transmitted when users visit the Company's website or run the app
Purpose of collecting and processing behavioral information	Providing online personalized advertising based on the interests and preferences of users/td>
Advertising business operators that collect (tools) and process behavioral information	Google LLC
Duration of keeping and using personal information	Retained for 14 months and then destroyed
How to exercise user control rights	[Web browser] · Internet Explorer: Menu > Tools > Internet Options > General > Search Record > “Delete” and “Settings” · Chrome: Menu > Set > “Personal Information and security” > “Cookies and Other Site Data” > Block Cookies and Delete Data · Safari: Set Environment > “Prevent Cross-Site Tracking” and “Block All Cookies” [App] · Android: Settings > Google Settings > Ads > Delete Advertising ID · iOS: Settings > Privacy & Security > Apple Advertising > Turn off Personalized Ads
Methods to remedy user damage	· Email to adjust privacy grievance: privacy@fananuri.com · Phone : +82 070-7537-1338

Article 9 Decision-Making Standards for Additional Use and Provision of Personal Information

In accordance with Article 15(3) and Article 17(4) of the Personal Information Act of South Korea, we may additionally use or provide your personal information without your consent, in consideration of Article 14-2 of the Enforcement Decree of the Personal Information Protection Act of South Korea.

[Article 9 Decision-Making Standards for Additional Use and Provision of Personal Information]

Third party recipient	Personal information to be provided	Purpose of provision	Period for retention and use
Labels and affiliated artists (excluding foreign labels) entered in Fannuri services	Nickname used in community, FID, content in posts	Operating and managing artist communities and sending out event announcements	For 3 months after Service withdrawal or as stated in relevant laws
	(event winner's) Email address	Community event winner announcement and winner verification	For 1 year after the event ends
	Generated information (internal identification key, device information, etc.), service usage history (date of log-in, IP address, fraudulent usage, etc.), device information (unique device identifiers, OS version), your location	Performing statistical analyses on use of platform services	For 3 months after Service withdrawal or as stated in relevant laws

Accordingly, we have considered the below items for additional use and provision of information without the user's consent.

1. Whether the purpose of additionally using and providing the personal information is relevant to initial purpose of collecting the information.
2. Whether there is predictability about additional use and provision of personal information, based on the circumstances of collecting information or its processing practices.
3. Whether the additional use and provision of personal information violates your rights.
4. Whether security measures have been taken, such as pseudonymization or encryption.

Article 10 Data Protection Officer

In order to protect users’ personal information and handle complaints related to personal information, we have designated our Data Protection Officer as follows. Users may report all complaints related to personal information protection arising in the course of using our services to the Data Protection Officer, and we will provide prompt and sufficient responses to such reports.

Data Protection Officer : Seung-Joo Park
Department responsible for processing complaint : CX/CS team
Department responsible for information inspection request : CX/CS team
Phone: +82 070-7537-1338
Email Address

Fannuri Email

privacy@fananuri.com

Article 11 Handling of Comments and Complaints

We operate a customer services center for smooth communication and resolution of any comments and/or complaints presented by our users in connection with personal information protection. If you are a user in Korea, in the event of a dispute arising between us and you in connection with personal information protection, for which you require help regarding potential infringement upon your information, you can contact the Personal Information Infringement Report Center of the Korea Internet & Security Agency, the Cyber Bureau of the National Police Agency, or other relevant agencies.

[Contact Information]

Korea Internet & Security Agency	https://privacy.kisa.or.kr	118
Personal Information Dispute Mediation Committee	https://www.kopico.go.kr	1833-6972
Cybercrime Investigation Division of Supreme Prosecutors’ Office	https://www.spo.go.kr	1303
Cyber Bureau of National Police Agency	https://cyber.go.kr	182

Article 12 Changes in Privacy Notice

This Privacy Policy will take effect from July 14, 2025 (KST).

Jurisdiction-Specific Terms

The following are supplementary clauses applicable depending on your location or nationality. In the event of conflict between the following and the main text of this Privacy Notice, the following shall prevail.

EEA and UK

For the purposes of this section, the term "personal information" used in the main text of this Notice shall be replaced with the term "personal data" – the term shall have the same meaning as set out in Article 1.

Clause Article 1 of this Notice shall be supplemented with the following text as a new final paragraph:

Article 1 Privacy Notice

For the purposes of the GDPR and the UK Data Protection Act 2018, Ubnuri,.co.Ltd. is the entity (or "controller") that decides how and why your personal data are processed and has primary responsibility for complying with applicable data protection laws.

Clause Article 2 of this Notice shall be replaced with the following:

Article 2 Purposes and Legal Bases for Processing of Personal Data
The purposes of processing of your personal data and the legal bases on which we rely under applicable laws are as follows:

[EEA & UK]

Processing activity	Legal basis for processing
To provide our Sites, Apps, products and services: Providing our Sites, Apps, products or services; creating an account; providing customer support on the use of services; identifying and preventing wrongful uses; providing functions for joining the Weverse community and for community activities; performing statistical analyses; providing promotional materials (upon request); and communicating with you in relation to our Sites, Apps or services; and providing and operating event services (confirming participants for events, providing and delivering prizes to winners, handling other complaints) , and manufacturing individually customized products.	· The processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or · We have a legitimate interest in carrying out the processing for the purpose of providing you with our Sites, Apps or services (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or · We have obtained your prior consent to the processing (the aforementioned legal basis is only used in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way).
To operate our business: Operating and managing our Sites, Apps and services; providing you with content; displaying advertising and other information to you; authenticating users for the sales/delivery of products and the identification and prevention of duplicate purchases/uses or other wrongful uses; communicating and interacting with you via our Sites, Apps or services; and notifying you of changes to any of our Sites, Apps or services.	· The processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or · We have a legitimate interest in carrying out the processing for the purpose of providing you with our Sites, Apps or services (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or · We have obtained your prior consent to the processing (the aforementioned legal basis is only used in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way).
To perform communications and marketing activities: Communicating with you via any means (including via email and app push alerts) to provide news items and other information in which you may be interested, subject to obtaining your prior opt-in consent to the extent required under applicable law; personalizing our Sites, products and services for you; maintaining and updating your contact information where appropriate; obtaining your prior opt-in consent when necessary; where applicable, enabling you to opt-out to withdraw your consent to or unsubscribe from emails sent by us, and recording your choice.	· The processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or · We have a legitimate interest in carrying out the processing for the purpose of contacting you, subject always to compliance with applicable law (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or · We have obtained your prior consent to the processing (the aforementioned legal basis is only used in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way).
To manage IT systems: Managing and operating our communications, IT and security systems; and auditing (including security audits) and monitoring such systems.	· The processing is necessary for our compliance with a legal obligation; or · We have a legitimate interest in carrying out the processing for the purpose of managing and maintaining our communications and IT systems (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
To improve our Sites, Apps and services: Identifying issues related to our Sites, Apps or services; planning improvements to our Sites, Apps or services; and developing new Sites, Apps or services.	· We have a legitimate interest in carrying out the processing for the purpose of improving our Sites, Apps or services (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or · We have obtained your prior consent to the processing (this legal basis is only used in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way).

Direct Marketing

We process personal data to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding Sites, Apps or services that may be of interest to you. We also process personal data for the purposes of displaying content tailored to your use of our Sites, Apps or services. If we provide Sites, Apps or services to you, we may send or display information to you regarding our Sites, Apps or services, upcoming promotions and other information that may be of interest to you, including by using the contact details that you have provided to us, or any other appropriate means, subject always to obtaining your prior opt-in consent, to the extent required under applicable law.

You may unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional electronic communication we send or by unsubscribing online at [Link] Please note that it may take up to 2 weeks to process your unsubscribe request, during which time you may continue to receive communications from us. After you unsubscribe, we will not send you further promotional emails, but in some circumstances we will continue to contact you to the extent necessary for the purposes of any Sites, Apps or services you have requested.

Clause Article 5 of this Notice shall be replaced with the following:

Article 5 Procedures and Methods of Destroying Personal Data

We destroy your personal information in accordance with our internal policies and other applicable laws.

The following shall be added at the bottom of Clause Article 6:

Article 6 Your Legal Rights
In addition to the above rights, you remain entitled to all other statutory rights.
You may also have the following additional rights regarding the processing of your personal information:

the right to object, on grounds relating to your particular situation, to the processing of your personal information by us or on our behalf, where such processing is based on Articles 6(1)(e) (public interest) or 6(1)(f) (legitimate interests) of the GDPR; and
the right to object to the processing of your relevant personal data by us or on our behalf for direct marketing purposes.

Clause Article 8 of this Notice shall be replaced with the following:

Article 8 Cookies and Similar Technologies

When you visit a Site or use an App, we will typically place cookies onto your device or read cookies already on your device, subject always to obtaining your prior consent, where required, in accordance with applicable law.

Clause Article 10 of this Notice shall be replaced with the following:

Article 10 Contact Information

You may contact our DPO [privacy@fannuri.com]if you wish to exercise your rights in connection with this Notice or your personal data.

Email Address

Fannuri account

privacy@fannuri.com

Clause Article 11 of this Notice shall not apply.

California Consumer Privacy Act (CCPA)

Clause Article 4 of this Notice shall be replaced with the following:

Article 4 Retention of Personal Information

We take every reasonable step to ensure that your personal information is only processed for the minimum period necessary for the purposes set out in this Notice. We will retain your personal information in a form that permits identification only for as long as:

(1) we maintain an ongoing relationship with you; or
(2) your personal information is necessary in connection with the lawful purposes set out in this Notice, for which we have a valid legal basis.

Clause Article 6 of this Notice shall be replaced with the following:

Article 6 California Consumer Privacy Act Disclosures
Under the California Consumer Privacy Act ("CCPA"), we must disclose our practices regarding the collection, use, and disclosure of the personal information of California residents ("Consumers").

Collection of Personal Information

We have collected and will collect the following general categories of personal information about Consumers:

Personal identifiers, including names, postal addresses, IP addresses, and email addresses;
Protected classifications, including age;
Internet or other electronic network activity information; and
Inferences for use in creating a consumer profile.

Use of Personal information

We may use the categories of personal information described above for the following business or commercial purposes:

Advance our commercial or economic business interests;
Maintain or service customer accounts;
Provide customer service;
Process or fulfill orders and transactions;
Provide advertising or marketing services;
Provide analytic services;
Perform internal research for technological development;
Ensure the quality and safety of services or devices;
Improve the quality and safety of services or devices;
Debugging to address impairments to operational functionality;
Detect security incidents;
Comply with applicable law and law enforcement requirements;
Protect against malicious, deceptive, fraudulent or illegal activity;
Prosecute those responsible for malicious, deceptive, fraudulent or illegal activity; and
Defend against or bring legal action, claims and other liabilities.

Categories of Sources of Personal information

We collect or obtain personal information of Consumers from the following sources:

Information provided to us by Consumers;
Information we obtain on our own;
Information provided to us through collaboration with Consumers;
Information provided to us in the course of our relationship with Consumers;
Information made public by Consumers;
App data;
Site data;
Information registered by Consumers;
Information obtained from content and advertising providers; or
Information provided to us by third parties.

Disclosure of Personal information

We do not sell any personal information to third parties. In particular, we do not sell the personal information of minors under 16 years of age. In the preceding 12 months, we have disclosed the following categories of personal information to the following categories of recipients:

Categories of recipients	Categories of personal information
Vendors who may need access to Consumers’ personal information to help us provide our services.	· Personal identifiers · Categories of personal information enumerated in Cal. Civ. Code § 1798.80 (e) · Protected classification (if provided) · Internet or other electronic network activity information · Inferences for use in creating a consumer profile
Entities who provide us with email address management and communication contact services, and those who analyze and enhance our marketing campaigns and service.	· Personal identifiers · Categories of personal information enumerated in Cal. Civ. Code § 1789.80 (e) · Protected classification (if provided) · Internet or other electronic network activity information · Inferences for use in creating a consumer profile
Entities we partner with to assist us with our Fannuri community events.	· Personal identifiers · Categories of personal information enumerated in Cal. Civ. Code § 1789.80 (e)

Clause Article 8 of this Notice shall be replaced with the following:
Article 8 California’s "Shine the Light" Law
Under California’s "Shine the Light" law, California residents are entitled to ask us for a notice describing what categories of personal customer information we share with third parties or our affiliates in connection with direct marketing performed by such third parties or our affiliates. The aforementioned notice will identify the categories of information we shared with third parties and our affiliates, and will include a list of names and addresses of such data recipients. If you are a California resident and would like a copy of this notice, please submit a written request to the following email address:
Email Address

Fannuri account

privacy@fannuri.com

Clause Article 10 of this Notice shall be replaced with the following:
Article 10 Consumer Rights under the CCPA
If you are a Consumer, the CCPA grants you the following rights regarding your personal information. If you make a certain request to us in order to exercise, or cause an authorized representative you appointed to exercise on your behalf, your rights to know and delete set forth in the CCPA, we will generally require you to provide us with certain personal information for the purpose of identifying you in the course of handling your request and compare such personal information against the personal information we have collected about you to verify your identity ("verifiable consumer request").
Verifiable consumer requests to know or delete may be submitted through one of the following methods:
Phone : +82 070-7537-1338
Email Address

Fannuri Account

privacy@fannuri.com

Right to Know About Personal Information We Collected about You.

Consumers have the right to submit a verifiable consumer request that we disclose the following personal information we collected about you over the 12-month period preceding the verifiable consumer request, in a readily useable format:

The categories of personal information we collected about you.
The purposes for which the categories of personal information collected about you will be used.
The categories of sources for the personal information we collected about you.
The categories of third parties with whom we share your personal information.
Our business or commercial purpose for collecting your personal information.
The specific pieces of personal information we collected about you.
The categories of personal information we have disclosed for a business purpose.

Right to Request Deletion of Personal Information.

Consumers have the right to request that we delete any personal information we have collected from them.

Right to Non-Discrimination.

Consumers have the right to be free from discrimination when they exercise their rights under the CCPA and, should you exercise those rights, we cannot:

1. Deny you goods or services;
2. Charge you a different price or rate for goods or services;
3. Provide you with a different level of quality of goods or services;
4. Suggest that you may receive a different level of quality of goods or services.

Notice of Financial Incentive

We offer consumers who provide personal identifiers, including their name, home address, and email address, and commercial information, including their purchase history and access to Fannuri community events. As participants in these programs, consumers will have the opportunity to win prizes. The value of this personal information to our business will vary depending on the consumer's purchases from Fannuri. Consumers may opt-in to our community events by signing up on our website. Consumers may cancel their participation in these events at any time.

Authorized Agent

Under the CCPA, you may appoint an authorized agent to submit requests to exercise your rights on your behalf. Should you choose to do so, for your and our protection, we will require your authorized agent to provide us with a signed permission demonstrating they are authorized to submit a request on your behalf. We note, should your authorized agent fail to submit proof that they have been authorized to act on your behalf, we will deny their request.

Clause Article 11 of this Notice shall not apply.

Japan

According to the purpose of the Article, the "relevant laws" and "relevant Korean laws" stated in this Notice shall be replaced with the Act on the Protection of Personal Information (Act No. 57 of 2003) and relevant Japanese laws.

The terms used in Clause Article 2 of this Notice shall be replaced with the following:

We process your personal information for the following purposes pursuant to applicable law:

Clause Article 9 of this Notice is not applied.

The following shall be added to Clause Article 10.

COMPANY : Ubnuri,.Co,Ltd.
ADDRESS : 2958-41, Bocheong-daero, Hoein-nyeon, Bo-eun-gun, Chungeheongbuk-do, 28928, Republic of Korea
CEO : DAE KEUN LEE

Clause Article 11 of this Notice is not applied.