Overview
Effective Date: [2026.03.23] Last Revised: [2026.03.23]
Pearrolls (the "Company") establishes and discloses this Privacy Policy to protect users' personal information and comply with applicable laws while providing EchoMoment (the "Service"). This Policy is prepared based on the current Service structure and may be revised if features are added or changed in the future.
Article 1 (Personal Information Processed and Purposes)
1. Use of Core Features
The Company provides the Service without account registration or login. Recording files, playback-related information, and app settings (for example, theme, language, and other default options) are generally stored in local storage on the user's device, and the Company does not store such recording files or local settings on Company servers. The processing purpose is recording, playback, local file management, and maintaining app settings.
2. App Permissions
To provide the Service, the Company may request the following device permissions:
- Microphone permission: To provide voice recording functionality
- File/media/document access permission: To save, import, export, share files, and optionally store to Google Drive
If the user does not grant permissions, some features may be restricted.
3. Google Drive Storage Feature (When Chosen by User)
If a user directly uses Google Drive save or export features, the Service may process Google account authentication/authorization information, the recording files selected by the user for storage, and minimal file metadata required for upload and storage.
The purpose is to save or export files to Google Drive selected by the user. The Company does not separately store those files on Company servers.
4. Advertising (AdMob)
The Service may use the Google Mobile Ads SDK (AdMob) for ad delivery. According to Google's public documentation, this SDK may automatically process IP address, user interaction information, diagnostic/performance information, device or account identifiers (for example, advertising identifiers), and advertising-related data depending on platform and configuration.
The purpose is ad delivery, ad performance measurement, analytics, fraud prevention, and consent management required by law.
5. Paid Features and Purchase Restoration (RevenueCat, App Store, Google Play)
The Company may use RevenueCat to verify paid feature purchases, grant entitlements, confirm subscription status, and restore purchases. In this process, purchase history, app user identifiers (for example, anonymous App User ID or app-generated identifiers), receipts or purchase tokens, subscription status, locale/currency information, and similar data may be processed.
According to RevenueCat's public documentation, purchase history may be collected, but payment card information itself is not collected by RevenueCat. Payments may be processed through the App Store or Google Play payment systems.
6. Customer Inquiries and Complaint Handling
When users contact the Company by email or other channels, the Company may process email address, name (if provided), inquiry details, attachments, and order/device information voluntarily provided by the user to respond and resolve issues.
The purpose is responding to inquiries, checking errors, supporting purchase restoration or refunds, and dispute handling.
Article 2 (Retention and Processing Period)
- Recording files and app settings Recording files and most settings are stored locally on the user's device and are retained until the user deletes them directly or removes the app.
- No storage on Company servers as a principle The Company does not store recording files or local settings on Company servers.
- Google Drive-stored data If the user uses Google Drive storage features, those files may be retained according to Google Drive or related Google policies until deleted by the user.
- Advertising-related data Retention periods for data processed by AdMob and Google services follow Google's policies, applicable laws, and user settings. Google states that user data may be processed on servers worldwide, including outside the user's country of residence.
- Purchase/subscription management data Retention periods for RevenueCat-related information follow RevenueCat policies, contractual relationships, and applicable laws. RevenueCat states that service-related data is stored on AWS in the United States.
- Customer inquiry data Customer inquiry and complaint handling data may be retained for one year after completion of inquiry handling or for periods required by law.
Article 3 (Provision of Personal Information to Third Parties)
- As a principle, the Company does not sell users' personal information or provide it to third parties.
- Exceptions apply in the following cases:
- Where a user directly selects a specific third-party service or recipient by executing Google Drive save, file export, or sharing features
- Where required by specific legal provisions or by lawful requests from investigative/supervisory authorities
- Where external services in Article 4 are used to provide paid features, deliver ads, or operate the Service
Article 4 (Use of External Services and Outsourced Processing)
The Company may use the following external services for operating the Service.
1. Google AdMob
- Purpose: Ad delivery, ad performance measurement, fraud prevention, and consent management where needed
- Data that may be processed: IP address, ad/device identifiers, in-app interaction data, diagnostic/performance data, ad-related data
2. RevenueCat
- Purpose: In-app payment status verification, purchase restoration, subscription entitlement management, entitlement verification
- Data that may be processed: Purchase history, receipts/purchase tokens, App User ID or anonymous identifier, subscription status, locale/currency information
3. Google Drive (Optional Feature)
- Purpose: Storage or export of recording files selected by the user
- Data that may be processed: Google account authentication information, user-selected files, and minimal metadata required for storage Google API Services User Data Policy requires clear disclosure of requested Google user data types and purposes and requires updates to privacy notice/policy when access beyond originally disclosed scope is needed.
4. App Store / Google Play Payment Systems
- Purpose: In-app payment, subscription management, refunds, purchase status verification
- Note: Payment and subscription handling may be subject to policies of each app marketplace operator.
Article 5 (Cross-Border Transfer of Personal Information)
The Service may include external services provided by overseas providers, and some information may therefore be processed outside the country.
1. Google LLC and Affiliates (AdMob, Google Drive, etc.)
- Transferred items: Ad-related identifiers, IP address, interaction/diagnostic data, files selected for Google Drive storage, and authentication-related information
- Transfer purpose: Ad delivery, analytics, fraud prevention, and Google Drive storage selected by user
- Timing of transfer: When ads are requested, or when a user executes Google Drive storage feature
- Destination country/region: Overseas servers operated by Google (including regions outside user's residence)
- Retention/use period: According to Google's policies and user settings
2. RevenueCat, Inc.
- Transferred items: Purchase history, receipts/purchase tokens, App User ID or anonymous identifier, subscription status, related technical information
- Transfer purpose: Purchase verification, entitlement provisioning, subscription status checking, purchase restoration
- Timing of transfer: During paid feature purchase, restoration, or subscription status check
- Destination country/region: United States (AWS)
- Retention/use period: According to RevenueCat policies and applicable law
Article 6 (Destruction Procedures and Methods)
- The Company destroys personal information without delay when processing purposes are achieved or retention periods expire.
- If retention is required by law, such information is separately retained for the legally required period and then destroyed.
- Destruction procedures and methods are as follows:
- Electronic files: deleted using technical methods that make recovery/reproduction difficult
- Paper documents: shredded or incinerated
- Because local storage data cannot be remotely accessed or batch-deleted by the Company, users must manage deletion directly through in-app delete features, device settings, Google Drive deletion, or app deletion.
- For purchase management data, the Company may process deletion requests within supported scope, including use of RevenueCat deletion functions. RevenueCat documentation states customer data deletion is available.
Article 7 (Rights and Obligations of Data Subjects and Legal Guardians; How to Exercise Rights)
- Users may request access, correction, deletion, suspension of processing, and withdrawal of consent from the Company within the scope of applicable law.
- However, for data such as recording files and app settings stored only on user devices and not on Company servers, the Company cannot directly access, correct, or delete such data; users must manage it themselves.
- Files saved to Google Drive can be deleted directly in Google Drive, and access permissions can be managed in Google account settings.
- Some purchase/subscription-related data is processed through RevenueCat, App Store, or Google Play, so additional verification may be required depending on the request.
- Choices regarding ad consent or tracking may be exercised through device settings, app marketplace/platform settings, or in-app privacy options (if provided), depending on supported OS and SDK environments. Google AdMob guidance includes consent collection/withdrawal support in some regions, and Apple requires ATT permission for tracking or access to ad identifiers.
- Rights may be exercised by contacting the inquiry channel below.
Article 9 (Children's Personal Information)
- As a principle, the Service is not primarily directed to children under age 14.
- If the Company becomes aware that personal information of a child under 14 has been collected without legal guardian consent, the Company will delete such information or take required actions in accordance with applicable law.
Article 10 (Security Measures)
- The Company adopts a structure in which recording files are not stored on Company servers.
- For personal information directly processed by the Company, the Company endeavors to implement reasonable safeguards such as minimizing access rights, managing inquiry data, managing external service access keys, and general security controls.
- External services such as Google Drive, AdMob, RevenueCat, App Store, and Google Play operate under each provider's security policies and technical/administrative safeguards. RevenueCat indicates TLS is applied for data security in transit.
- Users should also manage their own data security through device locks, up-to-date operating systems, and protection of Google and app marketplace accounts.
Article 11 (Policy Updates)
- The Company may change this Policy based on applicable law, Service feature changes, external service changes, or operational needs.
- If this Policy changes, the Company may notify changes through in-app notices, store pages, the Company website, or other appropriate methods.
- If new processing activities are introduced in the future (for example, iCloud storage, additional ad SDKs, analytics SDKs, login features, server sync features), the Company will revise this Policy accordingly.
- If access scope or purposes for Google user data change, the Company will update related notices and required consent procedures in advance.
Article 12 (Chief Privacy Officer and Contact)
- Personal Information Controller: Pearrolls
- Chief Privacy Officer: Hyunjin Lee / CEO
- Inquiry Email: contact@pearrolls.com
- Contact: +82-10-5490-0107
- Address: 50, Ip-buk-ro, Gwonseon-gu, Suwon-si, Gyeonggi-do, Republic of Korea
The Company will endeavor to review and respond without delay to inquiries, complaints, and requests for relief related to personal information processing.
Article 13 (How to Seek Remedy for Rights Infringement)
Users may contact the following organizations for consultation or relief regarding personal information infringement:
- Personal Information Infringement Report Center (Korea): 118 (without area code)
- Personal Information Dispute Mediation Committee (Korea): 1833-6972
- Supreme Prosecutors' Office (Korea): 1301
- National Police Agency (Korea): 182 (Personal Information Protection Commission)