Privacy Policy

[Company name] (the “Company”) collects only the minimum personal information necessary to provide the Service. Members can sign up only with Kakao Login or Google Login, and the Company does not receive or store passwords. The name and profile photo provided by Kakao or Google are kept only in login records, and only the nickname chosen by the member is shown within the Service.

• Sign-up

  ItemsKakao: member number, profile nickname, profile photo, Kakao Account email (if the member agrees to provide it) / Google: account identifier, email, name, profile photo

  When collectedWhen first starting with Kakao or Google

• Getting started

  ItemsNickname, year of birth, native language, and records of consent to the Terms of Service, the collection of personal information and the AI conversation notice

  When collectedWhen first starting

• Profile (optional)

  ItemsStatus message

  When collectedWhen the member enters it

• Conversations

  ItemsMessages sent by the member, persona settings, memories the AI has organized from conversations, closeness and number of conversations

  When collectedWhen using the Service

• Payments

  ItemsOrder number, purchased product, amount, payment status and date and time

  When collectedWhen making a payment

• Adult verification

  ItemsWhether the member is verified and the date and time of verification [Items to be finalized upon integration with an identity verification agency]

  When collectedWhen completing adult verification

• Collected automatically

  ItemsAccess logs, device and browser information, cookies that keep members logged in, ad impression and click records

  When collectedWhen using the Service

Payment method information, such as card numbers, is processed directly by the payment service provider and is not stored by the Company.

Please be careful not to include other people's personal information or sensitive information in conversations. What you tell a persona is used to build the conversation's context and memories.

• Identifying members, sign-up and login, confirming age eligibility and restricting adult features
• Generating AI chat responses, maintaining conversation context, and providing memory organization and closeness features
• Processing payments for paid services, managing balances such as energy and coins, and processing refunds
• Operating the Market, and calculating and paying out creator revenue
• Maintaining a safe environment, including handling reports, preventing prohibited conduct and providing crisis information
• Improving service quality and analyzing costs and usage (processed as statistics in a form that cannot identify individuals)

The Company does not provide members' conversations to outside parties for AI training.

To create persona replies, the Company sends the information needed for the conversation to AI model providers and entrusts them with processing it.

• Anthropic, PBC

  Entrusted taskGenerating AI chat responses, organizing conversation memories

  Information sentPersona settings, recent conversation content, saved memories, the name the persona uses for the member

  CountryUnited States

• [Payment service provider]

  Entrusted taskPayment processing

  Information sentOrder number, product name, amount, member identifier

  CountryRepublic of Korea

• Supabase, Inc.

  Entrusted taskOperating database and authentication infrastructure

  Information sentAll information arising from use of the Service (storage)

  Country[Region to be confirmed]

• [Hosting provider]

  Entrusted taskWeb service hosting

  Information sentAccess logs

  Country[To be confirmed]

Each message sent to an AI provider is encrypted in transit over the network. The provider's data retention period and whether data is used for training are subject to [Provider policy to be confirmed].

If you do not want your information transferred overseas, you can stop using the Service and request deletion of your account. However, because AI conversation is the core feature of the Service, it is difficult to use the Service without overseas transfer.

Review note · Legal review needed on the overseas transfer notice items under the Personal Information Protection Act (개인정보 보호법) (date, time and method of transfer, retention and use period, how to refuse and the consequences of refusing) and on whether consent is required.

The Company does not provide members' personal information to third parties. Exceptions are where the member has consented, or where an investigative agency or other authority requests it through lawful procedures under applicable laws.

Conversations and memories with a persona added as a friend from the Market are not disclosed to anyone, including the creator who made that persona. Creators can see only aggregate information, such as the number of friends, ratings and the total number of conversations.

If you leave a rating on the Market, the score and content of the rating are visible to other members, and you are shown as “Friend” instead of your nickname.

The Company destroys personal information without delay when a member leaves the Service or the purpose of collection has been achieved. However, information that must be retained under applicable laws is stored separately for the periods below.

• Records of contracts, withdrawals of purchase, etc.

  Period5 years

  Legal basisAct on the Consumer Protection in Electronic Commerce, etc. (전자상거래 등에서의 소비자보호에 관한 법률)

• Records of payments and the supply of goods, etc.

  Period5 years

  Legal basisAct on the Consumer Protection in Electronic Commerce, etc.

• Records of consumer complaints or dispute resolution

  Period3 years

  Legal basisAct on the Consumer Protection in Electronic Commerce, etc.

• Access logs

  Period3 months

  Legal basisProtection of Communications Secrets Act (통신비밀보호법)

When a chat room is deleted, the messages in that room are deleted immediately. Memories organized by the AI can be deleted separately in Memory notes, and all of them are deleted together when the account is deleted. Electronic files are erased using methods that make them unrecoverable.

Review note · Need to finalize the retention period for memories that remain when a friend is removed (archived), the backup retention period, and how Market ratings and creator payout records are handled after a member leaves the Service.

Members may at any time request access to, correction or deletion of their personal information, or suspension of its processing.

• Editing your profile: You can change your nickname and status message under [More].
• Deleting memories: You can delete memories organized by the AI one at a time in a chat room's Memory notes.
• Deleting conversations: Deleting a chat room deletes the messages in that room.
• Deleting your account: For now, account deletion is handled on request at [Customer support contact], and an in-app deletion feature is being prepared. Deleting your account deletes all of your friends, conversations, memories, and remaining energy and coins, and this cannot be undone.

Children under 14 cannot sign up for the Service. If the Company becomes aware that information of a child under 14 has been collected, it deletes the information without delay.

The Company uses cookies to keep members logged in. Settings such as the screen theme are stored only in the member's browser storage and are not sent to the Company.

Ads in the Service are not personalized ads that track members' interests, and records are used only to count impressions and clicks. You can refuse cookies in your browser settings, but if you do, you will not stay logged in.

• Encryption of all communications (HTTPS) and one-way encryption of passwords
• Row-level access control in the database so that members can view only their own information
• Keeping the number of staff who process personal information to a minimum, managing access rights and keeping access records
• Processing payments and balance changes only on the server, and recording every change

For inquiries, complaints or requests for remedies regarding the processing of personal information, please contact the person below.

• Chief privacy officer: [Name] · [Position]
• Contact: [Email] · [Phone number]

If you need counseling or dispute resolution regarding infringement of personal information, you can contact the organizations below.

• Personal Information Dispute Mediation Committee

  Contact1833-6972 · www.kopico.go.kr

• Personal Information Infringement Report Center

  Contact118 · privacy.kisa.or.kr

• Supreme Prosecutors' Office

  Contact1301 · www.spo.go.kr

• Korean National Police Agency

  Contact182 · ecrm.police.go.kr

When this policy changes, the Company posts a notice within the Service from 7 days before the change takes effect, and gives notice from 30 days before for important changes, such as changes to the items collected or the purposes of use.

This policy takes effect on [Effective date].