Privacy Policy

Article 1 (Items of Personal Information Collected and Methods of Collection)

1. Sign-up

   When users agree to the collection of personal information and enter their personal information themselves during the sign-up process or while using the service, the relevant information will be collected.

   When users register using a social media login service, the service may provide information such as a unique user identifier, display name, email address, profile photo, and phone number. The specific items collected may vary depending on the policies of each social media login service and the user’s consent.

   If a user does not agree to the collection of personal information, they will not be able to sign up for an account and may be restricted from using some of the services. The items collected are as follows:

   Sign-up Method	Items Collected	Purpose of Collection	Retention Period
   Traditional Sign-up	Email address, password, gender, and year of birth	To enable services and to conduct analysis for providing customized services and improving the services	One year after deletion of account
   Sign-up Using Social Media Account	Social media account user’s unique identifier, display name, email address, profile photo, etc. (depending on the policies of each service)

2. Payment

   Personal information may be collected by the personal information trustee (payment providers) during the payment process done in-app or through an external website, but the Company does not keep any information related to the payment.

   For web-based payments, the payment service provider (Paddle.com Market Ltd.) directly collects and processes the information necessary for payment, and the Company does not store any payment information.

3. Customer Support

   In the process of providing customer support through the customer center, personal information may be collected via web pages, email, messenger service (Channel.io Live Chat), telephone, etc.

   This information includes the user's email address, details of the customer support interaction (including text, images, videos), etc.

4. Marketing and Advertising

   After obtaining consent from users, personal information may be collected through campaigns, promotions, surveys, etc. conducted for marketing purposes. In addition, the Company uses a unique identifier to send study reminders and service-related notifications via the official accounts of the messaging services provided by the Company. Users may block the official account at any time to stop receiving such messages. In the event that additional personal information needs to be collected, further consent will be obtained after informing users of the items to be collected, the purpose of collection and use, and the retention period at the time of collection.

5. History of Using the Service

   Automatically-generated information, such as device information, may be collected in the process of using the mobile application.

   This information includes: IP address, cookies, history of using the service, device information, and/or advertising ID.

6. Voice Data

   When using pronunciation evaluation and speaking features, the user’s voice may be recorded and used for pronunciation analysis and the improvement of speech recognition algorithms.

   Recorded voice files, pronunciation evaluation results

7. AI Features

   When using the AI-powered question-and-answer feature within the app, the questions entered by the user may be collected and used to generate responses and improve the service.

8. Messaging Service Integration

   If a user subscribes to the Company’s official channel (account) on a messaging service by adding it as a ‘friend’ or when a user sends a message directly to the Company through a messaging service, the user’s unique identifier and phone number associated with the service may be collected. This information is used to send marketing communications such as promotions, events, discounts, and service-related information. Users may block the channel or disconnect it at any time to stop the collection and use of such information.

Article 2 (Purpose of Collecting and Using Personal Information)

1. For fulfilling a contractual obligation regarding providing services and processing payments occurring therefrom:

   To provide content, deliver goods, send invoices, process identity verification, and enable purchases and payments

2. For managing accounts:

   To check users for their subscriptions, identify individuals, prevent any abusive or unauthorized use, confirm the user's intent to subscribe, check the user's age, confirm the legal guardian's agreement to the collection of personal information for children under the age of 14, sending notifications via messaging services, provide customer support, and inform users of notices

3. For use in marketing and advertisements:

   To provide information on the service, conduct marketing and advertising activities, provide personalized advertising through third-party advertising platforms, provide services and display advertisements according to demographic characteristics, compile statistics on users' use of services, send advertising information related to special promotional events (including marketing communications via messaging services about promotions, events, and service-related notifications), and conduct customer surveys

Article 3 (Consent to Collection of Personal Information)

Article 4 (Period of Retention and Use of Personal Information)

1. When retaining personal information based on the Company's policies:

   1. Retention period in the case of deletion of an account:

      -Grounds for retention: To prevent abusive users from signing up again, or for cooperation in defamation disputes and/or investigations

      -Retention period: One year after deletion of the account

2. When retaining personal information based on the laws of the Republic of Korea:

   1. Records of contracts or cancellations of contracts:

      - Grounds for retention: Act on the Consumer Protection in Electronic Commerce

      - Retention period: Five years

   2. Records on payment and provision of goods, etc.:

      - Grounds for retention: Act on the Consumer Protection in Electronic Commerce

      - Retention period: Five years

   3. Records of consumer complaints or dispute handling:

      - Grounds for retention: Act on the Consumer Protection in Electronic Commerce

      - Retention period: Three years

   4. Records on identity verification:

      - Grounds for retention: Act on Promotion of Information and Communications Network Utilization and Information Protection

      - Retention period: Six months

   5. Records on visiting history:

      - Grounds for retention: Act on Promotion of Information and Communications Network Utilization and Information Protection

      - Retention period: Three months

Article 5 (Disposal Procedures and Methods for Personal Information)

1. Procedure

   1. Once its purpose has been fulfilled, the information entered by the user during sign-up, etc. is transferred to a separate database (separate filing cabinet in case of paper) and it is deleted or otherwise destroyed after being stored for a certain period of time (see Article 4 Period of Retention and Use of Personal Information) in accordance with the information protection grounds established by the Company's policies and other relevant laws and regulations of the Republic of Korea.
   2. Personal information will not be used for any other purposes except for when it needs to be used in accordance with the laws and regulations of the Republic of Korea.

2. Methods

   1. Personal information printed on paper is destroyed by shredding or incineration.
   2. Personal information stored in the form of electronic files will be deleted in such a way that the records cannot be reproduced.

Article 6 (Consignment of Collected Personal Information)

The Company entrusts the processing of personal information as set out below in order to facilitate the smooth handling of personal information. In the event of any changes to the entrusted tasks or service providers, the Company will disclose such changes through this Privacy Policy without delay.

Article 6-2 (Cross-Border Data Transfers)

The Company is a Korean corporation. Users’ personal information is transferred to and processed in the Republic of Korea.

The Republic of Korea provides comprehensive personal information protection through the Personal Information Protection Act (PIPA).

Article 7 (Rights of Users and Legal Guardians and Exercising Their Rights)

1. A user or legal guardian may view or correct their registered personal information at any time and retract their agreement to the Privacy Policy by deleting the account.
2. In the event that a user or legal guardian requests to correct an error in their personal information, the Company will not use or provide their personal information until the correction is completed.
3. The Company shall process personal information that has been modified or deleted upon the request of a user or legal guardian as specified in "Article 4 (Period of Retention and Use of Personal Information)" and shall not allow it to be viewed or used for any other purposes.
4. A user or legal guardian may inquire about any related matters by emailing the Chief Privacy Officer.

Users’ Rights Under Applicable Laws

In accordance with applicable laws, including Taiwan’s Personal Data Protection Act (PDPA), users have the following rights regarding their personal information:

• Right to Access: Users may request access to their personal information retained by the Company.
• Right to Rectification: Users may request correction of inaccurate or incomplete personal information.
• Right to Erasure: Users may request deletion of their personal information by deleting their account within the app.
• Right to Restrict Processing: Users may request the suspension of the collection, processing, or use of their personal information.
• Right to Withdraw Consent: Users may withdraw consent to the collection and use of their personal information at any time.

Collected personal information (including the unique identifiers of messaging service users) may be provided to the Company’s marketing automation partners (overseas subcontractors such as Braze Inc. and Amplitude, Inc.). To withdraw consent to this, users may submit a request via privacy@epop.ai or through the customer support center. For messaging services, users may refuse to receive messages by blocking the Company’s official account within the relevant service.

Article 8 (Installation, Management, Refusal of Automatic Collection for Personal Information)

1. Cookies

   In order to provide users with personalized and customized services, the Company uses "cookies" to store and retrieve users' information from time to time.
   A cookie is a very small text file that the server, used to run the website, sends to the user's browser and is stored on the hard disk of the user's computer. When the user revisits the website, the website server reads the cookies stored on the user's hard disk to maintain the user's preferences and provide customized services.
   Users have a choice about the installation, management, and refusal of cookies. Therefore, users can accept all cookies, confirm each time a cookie is stored, or reject the storage of all cookies by setting options in the web browser.
   However, if the user refuses to install cookies, it may become inconvenient to use the web pages and it may be difficult to use some services that require users to log in.

2. Advertising ID

   The company may collect and utilize advertising IDs (Android’s AAID or iOS’s IDFA) in order to provide customized services and personalized advertising within the mobile application.
   Advertising IDs are used to provide users with advertising and/or information that matches the interests of individual users based on application usage data analysis. Users may opt out of personalized advertising by adjusting their mobile device settings. However, this may result in the display of advertisements that are less relevant to the user’s interests.

   Android: Settings → Security & Privacy → More Privacy Settings → Ads → Ad privacy → Turn off “Allow app-suggested ads”

   iOS: Settings → Privacy & Security → Tracking → Turn off “Allow Apps to Request to Track”

Article 9 (Technical and Administrative Measures to Protect Personal Information)

1. The Company minimizes the number of employees handling personal information, emphasizes the importance of compliance with the Privacy Policy through training of the employees in charge, and implements the following technical and administrative measures to protect personal information:

   1. The Company is fully equipped with firewalls and security systems to prevent hacking.
   2. The Company installs SSL certificates to protect information when sending and receiving personal information.
   3. Access to personal information is strictly limited to only the relevant employees and those for whom handling personal information is unavoidable when performing their own duties, and all other employees are prevented from accessing it.
2. The user's personal information is protected by a password. An account's password can only be known by the user themself, and thus checking and changing personal information is possible only by the person who knows the password. The Company shall not be held responsible for any leakage of personal information due to user negligence.

Article 10 (Personal Information of Children Under 14)

Article 11 (Privacy Officer)

Chief Privacy Officer

Name - Park Jongheum

Organization - EpopSoft Inc.

Position – CCO

Privacy Officer

Name - Kim Woojun

Organization - EpopSoft Inc.

Position - CEO

Email address - privacy@epop.ai

Addendum