FilmN (필름엔) Privacy Policy
This is an English translation of the Korean original, provided for convenience. If there is any inconsistency, the Korean version prevails.
FilmN (Representative: Junmo Lee; the "Company") processes users' personal information as described below, in accordance with the Personal Information Protection Act (Republic of Korea), in the FilmN Studio app and on the transfer request page that the app links to (transfer.filmn.info). The Company also processes, under this Policy, the personal information of photographers it finds or contacts to propose a film pack partnership ("Prospective Partner Photographers").
Notice of Changes
Announced October 16, 2026; effective October 23, 2026. This revision adds how the Company processes the personal information of photographers it proposes a film pack partnership to on Instagram (Prospective Partner Photographers) (Sections 1, 2, 3, 4, 5, 6, 9 and 11). Processing of the personal information of app and transfer request page users does not change. Until October 22, 2026, the version effective October 16, 2026 applies, which is this Policy without the provisions on Prospective Partner Photographers.
1. Personal Information Processed, Purposes, and Legal Bases
App and Transfer Request Page Users
The app has no sign-up or login. Photos and videos are processed only on the device and are not sent to or stored on a server. Payments are processed through in-app purchase on the app stores (Apple App Store and Google Play), and the Company does not receive payment method information.
The Company receives information only in the cases below, and processes all of it on the legal bases set out in Article 15(1) of the Personal Information Protection Act. No personal information is processed on the basis of consent.
| When | Information received | Purpose | Legal basis |
|---|---|---|---|
| When requesting a transfer from an existing FilmN artist app | Email address, the app purchased, order number and purchase date and time verified with Google Play (Android), screenshot of purchase history (iOS) | Verifying purchases and refunds, issuing transfer codes and notifying users of them, checking request status, preventing duplicate requests | Measures taken at the user's request (Article 15(1)(4)) |
| When requesting a transfer from an existing FilmN artist app | IP address | Checking for fraudulent requests | The Company's legitimate interests (Article 15(1)(6)) |
| When registering a transfer code in the Android app | Transfer code, app installation identifier (a randomly generated value) | Checking the number of devices registered per code (up to 5) | Measures taken at the user's request (Article 15(1)(4)) |
| When requesting a transfer, checking request status, or registering a code | IP address (log for preventing excessive requests) | Preventing excessive requests and fraudulent use | The Company's legitimate interests (Article 15(1)(6)) |
| When the app receives new film packs or app settings | Standard access logs, such as IP address | Delivering film pack and settings files | Performance of a contract (Article 15(1)(4)) |
| When a user contacts the Company by email | Email address and sender name, inquiry content and attachments, and the app version, device model, and OS version the user includes | Reviewing and answering inquiries | Measures taken at the user's request (Article 15(1)(4)) |
| After the inquiry has been answered | The inquiry email above | Keeping records of consumer complaint and dispute handling | Legal obligation (Article 15(1)(2); Article 6 of the Act on the Consumer Protection in Electronic Commerce, etc. (Republic of Korea)) |
The app installation identifier is a random value generated by the app; it is not a unique device identifier or an advertising identifier. The app version and device information in inquiry emails are pre-filled on the email compose screen, and users can delete them before sending.
Prospective Partner Photographers
The Company proposes, by Instagram message, a partnership to photographers with a distinctive color style to turn that style into a film pack sold in the app. For this, the Company processes the information below. Information not received from the photographer directly comes from public Instagram profiles and public posts (including mentions in other accounts' posts or captions), public web pages that introduce the photographer (such as camera brand photographer pages, articles, or the photographer's own sales pages), and accounts entered directly by Company staff.
| When | Information processed | Purpose | Legal basis |
|---|---|---|---|
| When finding and reviewing photographers to approach | Instagram username; public profile information (name, bio, website, follower count, post count); links, like and comment counts, and posting times of recent public posts and values from analyzing their colors; profile screenshots; how and where the photographer was found (source URLs) and review records (assessment notes and memos) | Reviewing partnership candidates, writing proposal messages | The Company's legitimate interests (Article 15(1)(6)) |
| When proposing and discussing a partnership | Instagram messages exchanged; if the photographer prefers email, their email address, name, and email content and attachments | Proposing and discussing a film pack partnership | The Company's legitimate interests (Article 15(1)(6)) |
| To avoid contacting again | Username, outcome (not proposed, declined, opted out, no deal) and its date, and the date the opt-out result was notified | Preventing unwanted contact, managing opt-outs | The Company's legitimate interests (Article 15(1)(6)) |
Photos from public posts are used only while their colors are analyzed and are not stored on the Company's servers; however, they are sent to Anthropic (Section 5) for the analysis and may be kept there for the period stated in Section 6. The Company processes, for its business interest in finding photographers to work with, only what is needed for a proposal from information the photographer has made public. A proposal message is sent once and not repeated if there is no reply, contact stops immediately when you opt out, and you can ask at any time to stop contact or delete your information as described in Section 11. Proposal messages are exchanged as Instagram (Meta) messages, and conversations on Instagram are kept under Instagram's policies. Once a partnership is agreed, the photographer's information is processed under the partnership contract.
2. Retention Period
- Purchase history screenshots: destroyed 30 days after the request is processed (transfer code issued or request rejected).
- iOS requests not completed because no screenshot was uploaded (email, IP address, etc.): destroyed after 48 hours.
- IP address at the time of a request: destroyed 30 days after the request is processed.
- Email, order number, purchase date and time, request number, transfer code, and registration records: kept for as long as the service is operated, to prevent the same purchase from being transferred more than once and to prevent use after a refund; destroyed without delay if the user requests deletion.
- Access logs for preventing excessive requests: automatically deleted within 2 hours after the last request.
- Access logs created when receiving film pack and app settings files: the Company does not store them separately. Logs that Cloudflare, which handles the delivery, keeps for security purposes are deleted according to Cloudflare's retention policy.
- Inquiry emails: kept for 3 years from the date the inquiry is answered, then destroyed (the retention period for records of consumer complaint and dispute handling under the Act on the Consumer Protection in Electronic Commerce, etc.).
- Prospective Partner Photographer information: destroyed 90 days after the Company decides not to propose, the photographer declines or opts out, or discussions end without a deal; or after 90 days without progress following contact, or 90 days after being found without being contacted. Message text kept on the Company's servers is deleted at the same time. Conversations in the Instagram inbox and the Company mailbox (partners@filmn.info) stay in those services and are deleted on request.
- Records to avoid contacting again (third row of the Prospective Partner Photographers table in Section 1): kept while the Company carries out partnership outreach.
3. Destruction Procedures and Methods
- Information whose retention period has ended or whose processing purpose has been achieved is destroyed without delay. Screenshots, IP addresses, and logs for preventing excessive requests are automatically erased by the server every hour, and Prospective Partner Photographer information and profile screenshots every day.
- Information in electronic file form is deleted in a way that cannot be recovered. However, information remaining in the database's automatic recovery records (Cloudflare D1) is also erased within 30 days at the latest, and is not used for any other purpose in the meantime.
- The Company does not keep personal information in paper documents.
4. Provision to Third Parties
The Company does not sell or provide the personal information of users or Prospective Partner Photographers to third parties. However, exceptions apply where laws contain special provisions, or where an investigative agency requests it in accordance with procedures set by law.
5. Outsourcing of Processing
To operate the service, the Company entrusts the processing of personal information to the following companies.
| Service provider | Tasks entrusted |
|---|---|
| Cloudflare, Inc. | Storing the transfer request page, data, and screenshots; delivering film pack and settings files (server operation); storing Prospective Partner Photographer information and profile screenshots (sales management server operation) |
| Google LLC | Verifying purchase and refund status by order number at the time of an Android transfer request or code registration and for 60 days after approval (Google Play); receiving inquiry emails and sending transfer request confirmation emails and exchanging emails with Prospective Partner Photographers (partners@filmn.info) (Gmail in Google Workspace) |
| Anthropic, PBC | Finding Prospective Partner Photographer candidates (web search), analyzing their public information and profile screenshots, and drafting proposal messages (Claude) |
6. International Transfer
To outsource processing and storage as necessary to perform its contract with users and to conclude partnership contracts with Prospective Partner Photographers, the Company discloses the following in this Policy and transfers personal information overseas in accordance with Article 28-8(1)(3) of the Personal Information Protection Act.
Cloudflare, Inc. (Contact: privacyquestions@cloudflare.com)
- Destination countries: Transfer request information, screenshots, film pack files, and Prospective Partner Photographer information are stored in Cloudflare data centers in the Asia-Pacific region, and may be processed in the United States or other countries where Cloudflare has data centers during transmission and security processing.
- Items transferred: Information related to transfer requests, code registration, excessive-request prevention, and film pack delivery listed in the table in Section 1, and Prospective Partner Photographer information
- When and how: Sent over an encrypted network (HTTPS) at the time of each request, status check, registration, or download. Prospective Partner Photographer information is sent over an encrypted network (HTTPS) when the Company registers or analyzes candidates or records messages.
- Purpose of use and retention period: Server operation and storage; until the end of the retention periods in Section 2
Google LLC (Contact: https://support.google.com/policies)
- Destination countries: The United States and other countries where Google has data centers
- Items transferred: Order numbers (Android transfers); the email address, content, attachments, and device information in inquiry emails; and the recipient email address, request number, and request details in transfer request confirmation emails, and the email address, name, content, and attachments of emails exchanged with Prospective Partner Photographers
- When and how: Order numbers are looked up over an encrypted network (HTTPS) at the time of a transfer request or code registration, every hour while awaiting verification, and once a day for 60 days after approval. Inquiry emails are transmitted by email when the user sends them, and transfer request confirmation emails are transmitted by email when a request is received. Partnership emails are transmitted by email when they are exchanged.
- Purpose of use and retention period: Verifying purchase and refund status, receiving inquiry emails, and sending transfer request confirmation emails, and exchanging partnership emails; until the end of the retention periods in Section 2
Anthropic, PBC (contact: privacy@anthropic.com)
- Destination country: United States
- Items transferred: Prospective Partner Photographers' usernames, public profile information, public post photos and captions, profile screenshots, review records, and proposal message drafts
- When and how: transmitted over an encrypted network (HTTPS) when the Company finds or analyzes photographers to approach and drafts proposal messages. Information about photographers who declined or opted out, and replies sent by photographers, are not sent.
- Purpose of use and retention period: Finding and analyzing candidates and drafting proposal messages (Claude). Anthropic automatically deletes the information it receives and its outputs within 30 days, and may keep them for up to 2 years if it determines a usage policy violation. Under its terms with the Company, it does not use them to train AI models.
If you do not want your personal information transferred overseas, you can choose not to request a transfer, register a code, or send inquiries by email. In that case, you will not be able to use the transfer service or email inquiries. When launched, the app checks with Cloudflare's servers for new film packs and app settings. If you do not want the access logs from this check transferred, you can use the app with your device's internet connection turned off. In that case, you will not be able to receive new film packs or app settings, but you can still use the shooting and editing features and the films you have already received.
Prospective Partner Photographers can refuse the overseas transfer by requesting that processing be stopped as described in Section 11. The Company then sends no more of that photographer's information to Anthropic and stops contact; the record to avoid contacting again (third row of the table in Section 1) stays on the Cloudflare server. Other information is deleted according to Section 2, or immediately on a deletion request.
7. App Permissions
| Permission | Purpose | When requested |
|---|---|---|
| Camera | Shooting with films | When the camera screen is opened for the first time |
| Microphone | Recording audio for videos | When video recording is started for the first time |
| Photo Library access (iPhone) | Loading photos and videos to edit, saving results and organizing the FilmN album | When photos are loaded or saved for the first time |
| Storage (Android 9 and earlier) | Saving results | When saving for the first time |
On Android, photos and videos to edit are selected from the system photo picker, so the app does not request permission to read photos, and on Android 10 and later, no permission is needed to save either. If you deny a permission, you can still use other features (if you deny the microphone, videos are recorded without sound), and you can change permissions at any time in the Settings app.
8. Cookies and Other Automatic Collection Tools
The app and the transfer request page do not use cookies or tracking tools for advertising or analytics.
9. Security Measures
- Administrative measures: Handling of personal information is limited to one person, the Representative.
- Technical measures: Data transmitted between the app or web pages and the server is encrypted (HTTPS), and administrator functions are restricted to authenticated operators. Purchase history screenshots and Prospective Partner Photographers' profile screenshots are kept in non-public storage, and information past its retention period is automatically deleted. Work notification emails the Company sends to its operator do not include Prospective Partner Photographers' accounts or analysis.
- Physical measures: Servers are operated in Cloudflare data centers, and physical security, such as access control, follows Cloudflare's security policies.
10. Children's Personal Information
The Service is not directed at children under the age of 14, and the Company does not knowingly collect children's personal information.
11. Users' Rights and How to Exercise Them
Users may request access to, correction of, deletion of, and suspension of processing of their personal information processed by the Company. For transfer request information, if you send a request to the contact in Section 12 that includes your request number and the email address used for the request, the Company will process it within 10 days and notify you of the result. Requests may also be made through a legal representative or an authorized agent.
For Android transfer requests, whether a code is issued, put on hold, or rejected is decided without human involvement, based on the result of the Google Play order lookup. For 60 days after a code is issued, the refund status is checked, and codes for refunded orders are automatically suspended. If you would like an explanation of the result or a review of it, please send a request to the contact in Section 12. The Company will check it directly and let you know without delay.
Photographers who received a partnership proposal can reply "stop" by Instagram message (in Korean, "수신거부"; in Japanese, "停止") to stop receiving proposals, and the Company will notify you of the result within 14 days. If you ask where the Company obtained your information (source), the purpose of processing, or about your right to request that processing be stopped, the Company will tell you right away. To access, correct, or delete your information or stop its processing, send a request with your Instagram username by Instagram message or to privacy@filmn.info; it will be handled within 10 days and you will be notified of the result. You can also make a request through an authorized representative. The record to avoid contacting again (third row of the Prospective Partner Photographers table in Section 1) is kept.
12. Chief Privacy Officer
- Name: Junmo Lee
- Position: Representative
- Contact: privacy@filmn.info
13. Remedies for Infringement of Rights
If you need consultation or dispute resolution regarding the infringement of personal information, you can contact the following organizations.
- Personal Information Dispute Mediation Committee (개인정보분쟁조정위원회): 1833-6972 (no area code needed), www.kopico.go.kr
- Personal Information Infringement Report Center, Korea Internet & Security Agency (개인정보침해신고센터, 한국인터넷진흥원): 118 (no area code needed), privacy.kisa.or.kr
- Supreme Prosecutors' Office (대검찰청): 1301 (no area code needed), www.spo.go.kr
- Korean National Police Agency (경찰청): 182 (no area code needed), ecrm.police.go.kr
14. Changes to This Policy
If the Company changes this Policy, the changes will be posted in app update notices and on the web page (https://link.filmn.info/privacy) at least 7 days before they take effect, and will also be reflected in the app (My Page → Terms of Service · Privacy Policy).
- Effective date: October 23, 2026
- Previous Privacy Policy: version effective October 16, 2026 (available by email on request)
Business Information
- Business name: FilmN (필름엔)
- Representative: Junmo Lee
- Business registration number: 671-67-00580
- Mail-order business registration number: 2023-Gyeongbuk Pohang-0994 (2023-경북포항-0994)
- Address: 12 Bongcheon-ro 14-gil, Gwanak-gu, Seoul, Republic of Korea (서울특별시 관악구 봉천로14길 12)
- Email: support@filmn.info
- Hosting service provider: Cloudflare, Inc.