Personal (Location) Information Processing Policy

Blackbird Mobility Co., Ltd. (hereinafter referred to as the "Company") complies with the regulations on the protection of personal information that information and communication service providers must adhere to under laws such as the Act on Promotion of Information and Communications Network Utilization and Information Protection, the Personal Information Protection Act, the Act on Protection of Communications Secrets, and the Telecommunications Business Act. The Company has established a privacy policy based on related laws to protect the rights and interests of users to the fullest extent possible. This privacy policy applies to all services related to "Blackbird T" operated by the Company and contains the following contents.

Article 1 (Purpose of Collection and Use of Personal Information),

The company collects the personal information of users for the following purposes
1. Provision of basic functionalities of the "BLACKBIRD T" service
2. Identification of users and prevention of unauthorized use of the "BLACKBIRD T" service
3. Performance of contracts related to service provision and settlement of fees for paid services if necessary
4. Handling complaints and inquiries from users
5. Delivery of important notices
6. Development of new services and provision of customized services
7. Statistical analysis of members' service usage
8. Provision of advertising information such as event details
9. Compliance with laws and regulations

Article 2 (Items and Methods of Collecting Personal Information)

1. Items of Personal Information Collected
The company collects the following information based on the information provided by the "members" for the purpose of membership registration, provision of "BLACKBIRD T service," smooth customer consultation, and others:
① Required Items
- Personal email address or new ID creation for membership registration: Member's ID (email), password, name, nationality status
- Operating system version, device information, and other operating system and hardware environment information
② Optional Items
- Profile picture, phone number, account and service usage information of external services chosen by the member such as Facebook
③ The following information may be automatically generated and collected when using the service:
- IP address, cookies, visit date and time, service usage records, improper usage records, recommendation history, etc.
④ When necessary for payment in the process of using paid services, the following information may be collected:
- Information necessary for payment such as credit card information, carrier information, gift card numbers, etc.
2. Methods of Collecting Personal Information
The company collects personal information through the following methods:
① Collection through voluntary provision by users during registration or use of "BLACKBIRD T"
② Provision from partner companies and others
③ Collection through information generation tools

Article 3 (Provision of Personal Information to Third Parties and Handling Entrustment)

The company utilizes the personal information of members within the scope specified in the 'Purpose of Collection and Use of Personal Information'. Accordingly, the following information may be disclosed during the service usage process. Additionally, unless necessary for the purpose of the service, with the prior consent of the member, or except in the exceptional cases below, the company does not exceed the scope or provide it to third parties.

1. Disclosure of Personal Information
During the use of the "BLACKBIRD T" service, other information such as the member's name (nickname), profile picture, etc., that the member has optionally entered may be disclosed among members. Additionally, when a member invites another member, information such as the inviter's name (nickname), profile picture, etc., may be disclosed to the invitee depending on the settings.
2.Provision of Personal Information to Third Parties
The company provides personal information to third parties only with the consent of the information subject, special provisions of the law, etc., in accordance with Article 17 and 18 of the Personal Information Protection Act.
① Information consented to by the member
-In cases where prior notice is given and consent is obtained for the affiliation relationship
②Cases where there are special provisions in the law
③When requested by investigative agencies according to the procedures and methods prescribed for investigation purposes
④Payment service agency
- Recipient of personal information: Payment service agency
-Purpose of using the recipient's personal information: Mobile phone number, date of birth, name, passport number, credit card information, bank account information, service usage records, access logs, cookies, access IP information, payment records, etc.
- Retention and use period of the recipient: According to the regulations of the payment service agency
3.Handling Entrustment of Personal Information
For the improvement of services, the company entrusts and processes the personal information of members to other companies within the necessary scope of business as follows. Also, the company stipulates necessary matters to ensure that personal information is safely managed when entrusting according to the relevant laws and regulations. When entering into an entrustment contract, the company specifies matters such as prohibition of personal information processing beyond the purpose of entrusted business, technical and managerial protective measures, restrictions on re-entrustment, management and supervision of the trustee, liability for damages, etc., in documents such as contracts, and supervises whether the trustee handles personal information safely. In addition, if the content of the entrusted business or the trustee changes, we will promptly disclose it through this privacy policy.

The company obtains the consent of the information subject to provide personal information only within the minimum necessary scope for smooth service provision.

Status of Personal Information Processing Entrustment
Recipient of Entrustment (Trustee) Entrusted Business Contents Entrustment Period
KG Inicis Co., Ltd. Payment processing (credit card, simple payment) Until expiration of the usage period of the respective company
Article 4 (Retention and Use Period of Personal Information)

The personal information of members is promptly disposed of once the purpose of collection and use of personal information is achieved. However, the following information is retained for the specified period for the reasons stated below:
Information Sharing According to Company Policy
Retention of misuse records: 1 year (prevention of misuse)
Information Sharing According to Relevant Laws
If it is necessary to retain information for a certain period under the provisions of relevant laws such as the Commercial Act, the Act on Consumer Protection in Electronic Commerce, etc., the company retains the information for the specified period as follows:
① Retention of records related to contracts or withdrawal of subscriptions: 5 years (Act on Consumer Protection in Electronic Commerce, etc.)
② Retention of records related to payment of fees and supply of goods, etc.: 5 years (Act on Consumer Protection in Electronic Commerce, etc.)
③ Retention of records related to consumer complaints or dispute resolution: 3 years (Act on Consumer Protection in Electronic Commerce, etc.)
④ Retention of records related to identity verification: 6 months (Act on Promotion of Information and Communication Network Utilization and Information Protection, Etc.)
⑤ Retention of records related to visits (internet log records, access location tracking data): 3 months (Telecommunications Business Act)
⑥ Retention of operation information records: 1 year (requirement for operator license for transportation platform business)

Article 5 (Access, Modification, Deletion, and Personal Information Forgery)

Members may at any time access, disclose, or privatize their personal information, as well as request modifications, deletion, or destruction.
Request for Access and Modification of Personal Information
1. Members and legal guardians may access and modify the personal information of themselves or children under 14 years of age who are registered at any time. Members or legal guardians can directly access or modify registered personal information, such as accounts, through the profile and MY menu of the "BLACKBIRD T" service for viewing or modification.
2. Deletion of Personal Information (Withdrawal of Membership)
3. If a member or legal guardian of a child under 14 years of age wishes to withdraw from membership, they can directly withdraw after logging in to the mobile application or website. If direct withdrawal is difficult, please contact the personal information manager in writing, by phone, or by email, and we will take immediate action.
4. Personal Information Forgery
If the company discovers individuals who have registered for membership or used "BLACKBIRD T" by using another person's resident registration number, Facebook ID, or other personal information, we will promptly suspend the service for the relevant ID or take necessary measures such as withdrawal of membership.

Article 6 (Destruction of Personal Information)

The personal information of members is promptly disposed of once the purpose of collection and use of personal information is achieved. The personal information destruction process and method of the company are as follows:
1. Destruction Process
Information provided by members for service registration, etc., is transferred to a separate database or storage location after the purpose is achieved. It is then stored for a certain period according to internal policies and other relevant laws and regulations (refer to the retention and use period of personal information) and destroyed. The separately stored personal information will not be used for purposes other than those specified.
2. Destruction Method
Personal information printed on paper is destroyed by shredding or incineration. Personal information stored in electronic file format is deleted using technological methods that prevent the reproduction of records.

Article 7 (Operation of Cookies)

Cookies refer to special text files sent to the hard disk of users when accessing the "BLACKBIRD T" site. Cookies are transmitted in a form that can only be read by the website's server and are stored in the directory of the browser used by the individual.
1. Purpose of Using Cookies
The information collected by "BLACKBIRD T" through cookies is the same as the 'items of personal information collected,' and it is not used for purposes other than those specified in the 'purpose of collection and use of personal information.'
2. Refusal of Cookie Settings
Users have the option regarding cookies. By selecting web browser options, users can decide to allow all cookies, allow cookies through consent, or block all cookies. However, if you refuse to save cookies, you may not be able to use some services that require login.

Article 8 (Rights and Obligations of Members)

The responsibility for accidents caused by inaccurate information entered by the member lies with the user themselves. Members have an obligation to enter personal information accurately and keep it up to date to prevent unforeseen accidents. Along with the right to protect personal information, members also have an obligation to protect themselves and not infringe on others' information. Please be cautious to prevent the leakage of personal information, including passwords, and be mindful not to damage others' personal information, including postings. If members fail to fulfill these responsibilities and damage the information and dignity of others, they may be punished according to related laws such as the "Act on Promotion of Information and Communications Network Utilization and Information Protection, Etc.

Article 9 (Technical/Administrative Measures for Protection of Personal Information)

The company takes the following technical/administrative measures to ensure the security of members' personal information and prevent its loss, theft, leakage, alteration, or damage:
1. Measures against Hacking and Similar Threats
The company makes every effort to prevent the leakage or damage of members' personal information due to hacking, computer viruses, etc. Measures are in place to prevent the leakage or damage of members' personal information or data, and encryption communication is used to securely transmit personal information over the network. Additionally, intrusion prevention systems are utilized to control unauthorized access from external sources.
2. Minimization and Training of Processing Staff
The company limits the handling of personal information to designated personnel and provides them with separate passwords that are regularly updated. Regular training is provided to these personnel to emphasize compliance with the company's personal information processing policy.
3. Operation of Personal Information Protection Organization
The company operates an internal personal information protection organization to confirm compliance with the company's personal information processing policy and the adherence of personnel. Efforts are made to promptly correct and rectify any issues discovered. However, the company does not assume any responsibility for problems arising from the leakage of personal information due to the member's negligence or the intentional or gross negligence of the company.

Article 10 (Contact Information of Personal Information Protection Manager and Department)

You may report any complaints related to personal information protection arising from your use of the "BLACKBIRD T" service to the personal information protection manager or the relevant department of the company. The company will promptly respond to your reports.
1. Personal Information Protection Manager
- Name: Sangdon Park
- Affiliation: BLACKBIRD Mobility Co., Ltd.
- Position: CEO
- Phone: 064-723-8850
- E-mail: spark109@blackbirdt.com
2. Personal Information Management Department
- Department: Technology Research Institute
- Phone: 064-723-8850
- E-mail: spark109@blackbirdt.com

For reporting or consultation regarding other personal information infringements, please contact the following organizations:
- Personal Information Infringement Report Center (www.118.or.kr / 118)
- Korea Internet & Security Agency (www.eprivacy.or.kr / 02-580-0533~4)
- Cyber Crime Investigation Division, Supreme Prosecutors' Office (www.spo.go.kr / 02-3480-2000)
- Cyber Terror Response Center, National Police Agency (www.ctrc.go.kr / 02-392-0330)

Article 11 (Processing of Individual Location Information)

The company processes individual location information as follows:
1. Purpose of Processing and Retention Period of Individual Location Information
The company collects, uses, and provides individual location information within the scope of purposes specified in the location information usage agreement, and retains it for the period notified in Article 11.
2. Basis and Retention Period of Confirmation Materials for Collection, Use, and Provision of Individual Location Information
Pursuant to Article 16(2) of the Act on the Protection and Use of Location Information, the company automatically records and preserves confirmation materials for the collection and provision of individual location information, and retains such data for a minimum of 6 months from the time of recording.
3. Procedure and Method of Destruction of Individual Location Information
Upon achievement of the purpose of processing or expiration of the retention period, the company promptly destroys individual location information using methods that make recovery and regeneration impossible, consistent with the procedures and methods for deleting personal information specified in Article 6.
4. Provision and Notification of Individual Location Information to Third Parties
The company does not provide personal location information to third parties without the user's prior consent. However, in cases where the user directly consents to the provision of individual location information, or when submission obligations arise under relevant laws, or when there is an urgent need to alleviate risks to the user's life or safety, personal location information may be provided.
5. Notification of Provision of Individual Location Information
When the company provides individual location information to a third party designated by the user, it immediately notifies the user of the recipient, date and time of provision, and purpose of provision through the communication device on which the location information was collected.
The content and purpose of the company providing the member's personal location information to a third party for the purpose of providing services are as follows:
① Recipient: Companies providing driving services and drivers providing driving services, users using driving services.
② Purpose of provision: Member and vehicle locations for Blackbird T reservation, vehicle dispatch, and Blackbird T calling service.
6. Rights and Obligations of the Guardian and Method of Exercising Them
If the guardian responsible for protecting the individual's life or body, such as a child under the age of 8 or a legal representative of a minor, agrees to the use or provision of individual location information for the protection of the individual's life or body, it is considered that the individual has consented.
① Children under 8 years old.
② After a minor becomes an adult, their legal guardian.
③ Persons who have mental disabilities according to Article 2, Paragraph 2, Clause 2 of the Act on Welfare of Disabled Persons, and who are severe disabled persons according to Article 2, Paragraph 2, Clause 2 of the Act on Promotion of Employment and Vocational Rehabilitation of Disabled Persons (Only those who have registered as disabled persons under Article 32 of the Act on Welfare of Disabled Persons).
The guardian must submit a written consent form to the company, proving their status as the guardian, along with a document confirming their guardianship.
7. Personal Information Protection Manager and Location Information Management Officer
The company designates a department responsible for personal location information protection to appropriately manage and protect individual location information and to handle user complaints and requests smoothly.

Article 12 (Others)

Please note that this privacy policy of "BLACKBIRD T" does not apply to the collection of personal information by websites or other services linked within the "BLACKBIRD T" service.

Article 13 (Notification Obligation)

In the event of any additions, deletions, or modifications to the current privacy policy, notice will be provided through a 'notice pop-up' within the "BLACKBIRD T" service at least 7 days prior to the effective date.

Date of Announcement : April 15, 2024
Effective Date : April 15, 2024