Article 1 (Consent to Collection and Use of Personal Information)

Hyo Dev ("the Company") establishes and discloses this Privacy Policy in accordance with the Act on Promotion of Information and Communications Network Utilization and Information Protection, Personal Information Protection Act, etc., to protect your personal information and process related grievances quickly and smoothly. This policy applies to all apps operated by the Company (including Martie, Luent, Lity, NyangnyangSaju, etc.) and complies with COPPA (Children's Online Privacy Protection Act) for users under the age of 13.

Article 2 (Items of Personal Information Collected and Collection Methods)

1. The Company collects the following personal information for membership registration, performance of service contracts, settlement of fees for service provision, and other services.

1) Membership registration and management
- Required: Login ID, Password, Email address, Nickname, Field of expertise
- For children under 13: Parent or legal guardian’s email address and consent confirmation
2) The following personal information may be automatically generated and collected during service use.
- IP address, Device identifier, Service usage history, Visit history, Bad usage history, etc.
3) When using paid subscriptions and in-app purchases: Subscription and payment history, Payment unique identifiers (e.g., Apple receipt, purchase history, etc.)

2. Collection methods:
Through the app (sign-up), phone consultation via customer center, online consultation via email, separate process for parental consent for children under 13, and automatic collection via payment systems when using subscriptions or in-app purchases.

Article 3 (Purpose of Collecting and Using Personal Information)

The Company collects your personal information for the following purposes and does not use it for purposes other than those stated. If the purpose changes, separate consent will be obtained as required by the Personal Information Protection Act.

Purpose: Membership registration and management, Provision of goods or services, Provision and management of paid subscriptions and in-app purchases

Items: Login ID, Password, Email address, Nickname, Field of expertise, IP address, Device identifier, Service usage history, Visit history, Bad usage history, etc. (For children under 13, includes parental consent information), Subscription and payment history, Payment unique identifiers (Apple receipt, purchase history, etc.)

Retention period: Until account deletion, or completion of supply/payment, Subscription and in-app purchase history is retained for a certain period according to relevant laws and destroyed thereafter.

If required by law, data may be retained until the statutory period ends:
- Act on Consumer Protection in Electronic Commerce: Ad/Display records (6 months), Contract/withdrawal/payment/supply records (5 years), Complaint/dispute records (3 years)
- Protection of Communications Secrets Act: Internet log (3 months)
- Electronic Financial Transactions Act: Transaction records (5 years)

Article 4 (Protection of Personal Information for Children Under 13)

1. When collecting personal information from children under 13, the Company obtains consent from a parent or legal guardian, confirming the parent’s email address and consent.

2. Parents or legal guardians may request access, correction, or deletion of the child’s personal information at any time via the designated manager (Dept: Operations Team, Contact: Hyochan Jang, Email: hyo@hyo.dev).

3. The child’s personal information is protected in compliance with COPPA and will not be provided to third parties without consent.

Article 5 (Rights and Obligations of Users and Exercise Methods)

Users may view, correct, or delete their personal information or withdraw their membership at any time via the manager (Dept: Operations Team, Contact: Hyochan Jang, Email: hyo@hyo.dev).

You may request access/correction by letter, phone, or email. We will act promptly.

If a correction request is made, the information will not be used or provided until corrected. If incorrect information has been provided to a third party, the result of the correction will be communicated promptly.

Article 6 (Cookies)

The Company does not collect cookies.

Article 7 (Destruction of Personal Information)

1. The Company promptly destroys personal information when the retention period expires or processing purpose is achieved.

2. If retention is required by law, data is stored separately.

3. Destruction process and methods:
1) Selection of personal information for destruction and approval by the manager.
2) Electronic files are permanently deleted; paper documents are shredded or incinerated.

4. Subscription and payment information (purchase history, receipts, etc.) is retained for a statutory period and then promptly destroyed.

5. Requests for destruction may be made to the manager (Dept: Operations Team, Contact: Hyochan Jang, Email: hyo@hyo.dev).

Article 8 (Measures to Ensure Security of Personal Information)

The Company takes the following measures:
- Managerial: Internal policies, regular employee training
- Technical: Access control, encryption, security programs
- Physical: Control of access to server/data rooms

Article 9 (Personal Information Manager)

1. The following manager is responsible for overall personal information protection and handling complaints:
- Name: Hyochan Jang
- Dept: Operations Team
- Email: hyo@hyo.dev

2. Contact for inquiries, complaints, or relief related to personal information.

Article 10 (Remedies for Infringement)

You may contact the following agencies for relief or counseling:
- Personal Information Infringement Report Center: privacy.kisa.or.kr, 118
- Personal Information Dispute Mediation Committee: privacy.kisa.or.kr, 118
- Supreme Prosecutors’ Office Cyber Crime: 02-3480-3573 (www.spo.go.kr)
- National Police Agency Cyber Bureau: 1566-0112 (www.netan.go.kr)

Article 11 (Changes to this Privacy Policy)

1. Changes, deletions, or additions to this policy will be announced at least 7 days prior; important changes 30 days prior.

2. This Privacy Policy is effective as of March 5, 2025.

Article 12 (Processing of Subscription and Payment Information)

1. The Company may collect subscription and payment history, unique identifiers (e.g., Apple receipt) to provide subscription and in-app purchase services.

2. Payment processing is handled through Apple App Store or Google Play. Only essential information is stored.

3. Payment information is retained only for the period required by law and destroyed after that period.

4. The Company may provide payment/subscription history to authorities if legally required.