PhotoKip - Privacy Policy

# Privacy Policy

**ConnectionValue Inc.** (hereinafter the "Company") establishes and discloses this Privacy Policy in accordance with applicable laws, including the Personal Information Protection Act, to protect users' personal information and to promptly and smoothly handle related grievances.

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## 1. Personal Information Collected and Collection Methods

### 1.1 Personal Information Directly Collected by the Company

PhotoKip (hereinafter the "App") **does not require account registration or login**. Collections, categories, photos, videos, titles, descriptions, media memos, and similar content saved by users in the App are **stored only on the user's device** and are not transmitted to the Company's servers.

However, if a user directly contacts the Company by email or another method, the following information may be collected.

| Collected Items | Purpose | Retention Period |
|-----------------|---------|------------------|
| Email address, inquiry details, attachments | Customer support, troubleshooting, dispute response | Until the inquiry is handled and for any period required by applicable laws |

### 1.2 Information Stored on the Device but Not Transmitted to Company Servers

The following information is stored in the user's device internal storage to provide the App's core features. The Company cannot access or restore this information.

| Stored Items | Purpose |
|--------------|---------|
| Collection names, descriptions, colors, bookmarks, categories | Organizing informational photos and videos |
| Photos, videos, thumbnails, media memos | Collection management and viewing |
| Filenames, MIME types, capture dates, added dates, resolution, file size, video duration, shooting location information when included in photos or videos, and other media metadata | Search, sorting, detailed information display, and original media management |
| App settings such as language, theme, camera launch setting, and gallery view setting | Maintaining the App environment |

### 1.3 Information That May Be Automatically Collected During Service Use

During use of the App, the following information may be automatically collected and processed through third-party SDKs or service providers.

| Collected Items | Purpose | Collected/Processed By |
|-----------------|---------|------------------------|
| Advertising identifiers (ADID/IDFA), app instance or installation identifiers, app set IDs or vendor identifiers, IP address, device model, OS version, app version, language and region information | Personalized and non-personalized advertising, ad performance measurement, app analytics, fraud prevention | Google AdMob, Firebase Analytics, Amplitude |
| App usage events such as screen views, button taps, feature usage, search, sorting, bookmarks (excluding the raw search query, and including query length and result counts), purchase and restore events, ad and affiliate link clicks | Service improvement, statistical analysis, feature stabilization | Firebase Analytics, Amplitude |
| App crash logs, error information, performance information, device state | App stability improvement and bug fixes | Firebase Crashlytics |
| Push notification tokens such as APNs/FCM tokens, push subscription status, notification receipt and click information, first and last session time, session count, usage duration, device OS, language, timezone, country, app version, application identifier, carrier, device model, IP address | Sending push notifications and managing notification settings | OneSignal |
| In-app purchase information, product IDs, purchase and restore history, Premium access activation status, RevenueCat anonymous app user ID, advertising and device identifiers such as IDFA/IDFV/Google advertising ID, IP address, Meta anonymous ID, ATT consent status | Managing Premium lifetime access, restoring purchases, subscription conversion and ad performance measurement | RevenueCat, Apple App Store, Google Play |
| Firebase installation ID, app version, platform information, remote configuration values | App update notices, maintenance management, feature configuration | Firebase Remote Config |
| Meta anonymous ID, App Events such as app activation and install events, advertising identifiers, ATT/ad tracking authorization status | Meta ad performance measurement, subscription conversion attribution, reflecting ad tracking consent | Meta Platforms, RevenueCat |
| Affiliate ad impression and click information | Displaying affiliate ads and measuring ad performance | Coupang Partners, Firebase Analytics, Amplitude |
| Ad consent status, iOS app tracking authorization status | Determining whether personalized ads can be provided and complying with platform policies | Google AdMob, Meta Platforms, Apple App Tracking Transparency |

The App does not upload the actual contents of photos, videos, titles, descriptions, or memos saved by users to Company servers. However, if a user uses a sharing feature to directly send content to an external app or third party, the privacy policy of that external service applies.

### 1.4 Device Access Permissions

The App uses the following device access permissions.

| Permission | Purpose | Required |
|------------|---------|----------|
| Camera | Capturing photos and videos to add to collections | Optional |
| Microphone | Recording audio when capturing videos | Optional |
| Photos/Gallery | Selecting existing photos and videos, showing the in-app media grid, saving to the device gallery, and deleting originals selected by the user | Optional |
| Location (iOS) | Preserving shooting location information included in photos and videos as collection metadata | Optional |
| Notifications | Receiving push notifications | Optional |
| Internet | Integration with external services such as ads, app analytics, error collection, remote configuration, push notifications, in-app purchases, and purchase restoration | Required |

Photos and videos selected or captured via camera or gallery, and any shooting location information included in those media files, are **stored only in the user's device internal storage** and are not transmitted to Company servers.

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## 2. Purpose of Collection and Use of Personal Information

The Company uses collected personal information for the following purposes.

| Purpose | Details |
|---------|---------|
| Service provision | Managing informational photo and video collections, maintaining app settings, and providing Premium features |
| Customer support | Responding to inquiries, checking errors, and handling disputes |
| Service improvement | Improving features through analysis of app usage statistics |
| App stability | Resolving issues through analysis of crash logs and error information |
| Advertising | Displaying ads and providing personalized ads through Google AdMob |
| Affiliate advertising | Displaying affiliate ads such as Coupang Partners and measuring performance |
| Push notifications | Sending service-related notifications and announcements |
| Purchase management | Verifying Premium lifetime access status and restoring purchases |
| Legal and policy compliance | Complying with App Marketplace policies, ad consent requirements, and privacy laws |

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## 3. Provision of Personal Information to Third Parties and External Services

The Company does not provide local content such as photos, videos, titles, descriptions, or memos saved by users in the App to third parties. However, the following third-party services required for app operations may collect and process user information.

| Recipient | Items Provided or Processed | Purpose | Retention Period |
|-----------|-----------------------------|---------|------------------|
| Google LLC (Firebase Analytics) | Device information, app usage events, app instance or installation identifiers, advertising identifiers | Service analysis and improvement | Per Google's Privacy Policy |
| Google LLC (Firebase Crashlytics) | Crash logs, error information, device state, performance information, Crashlytics/Firebase installation identifiers | App stability improvement | Per Google's Privacy Policy |
| Google LLC (AdMob) | Advertising identifiers, IP address, device/account identifiers, device information, ad consent status, ad impression and click information, user interactions, diagnostic and performance information | Ad display, personalized and non-personalized ads, ad performance measurement, fraud prevention | Per Google's Privacy Policy |
| Amplitude Inc. | Device information, app usage events and event properties, app installation or device identifiers | Product analytics and service improvement | Per Amplitude's Privacy Policy |
| OneSignal Inc. | Push notification tokens, push subscription status, notification receipt and click information, session and usage duration information, device OS, language, timezone, country, app version, application identifier, carrier, device model, IP address | Sending and managing push notifications | Per OneSignal's Privacy Policy |
| RevenueCat Inc. | In-app purchase information, product IDs, purchase and restore history, Premium access activation status, RevenueCat anonymous app user ID, advertising and device identifiers, IP address, Meta anonymous ID, ATT consent status | Premium lifetime access management, purchase restoration, subscription conversion and ad performance measurement | Per RevenueCat's Privacy Policy |
| Meta Platforms, Inc. | Meta anonymous ID, App Events such as app activation and install events, advertising identifiers, ATT/ad tracking authorization status, subscription conversion events through RevenueCat | Meta ad performance measurement, subscription conversion attribution, reflecting ad tracking consent | Per Meta's Privacy Policy |
| Apple Inc. / Google LLC | In-app payment information, purchase history, purchase status related to App Marketplace accounts | App Marketplace payment processing and refunds | Per each App Marketplace policy |
| Coupang Corp. (Coupang Partners) | Affiliate ad impression and click-related information | Displaying affiliate ads and measuring performance | Per Coupang's Privacy Policy |

For details on how each third-party service processes personal information, please refer to their respective privacy policies.

- Google: <https://policies.google.com/privacy>
- Amplitude: <https://amplitude.com/privacy>
- OneSignal: <https://onesignal.com/privacy_policy>
- RevenueCat: <https://www.revenuecat.com/privacy>
- Meta: <https://www.facebook.com/privacy/policy/>
- Apple: <https://www.apple.com/legal/privacy>
- Google Play: <https://policies.google.com/privacy>
- Coupang: <https://privacy.coupang.com/ko/center/coupang/>

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## 4. International Transfer of Personal Information

Some third-party services used by the App are provided by overseas companies, and personal information may be transferred internationally during use of the Service.

| Recipient | Destination Country | Transferred Items | Purpose | Timing and Method | Retention Period |
|-----------|---------------------|-------------------|---------|-------------------|------------------|
| Google LLC | United States, etc. | Device information, IP address, advertising identifiers, app instance or installation identifiers, app usage events, crash logs, user interaction, diagnostic and performance information, ad information | App analytics, error improvement, advertising, fraud prevention | Network transmission through SDKs while using the App | Per Google's policy |
| Amplitude Inc. | United States, etc. | Device information, app usage events, app installation or device identifiers | Product analytics and service improvement | Network transmission through SDKs while using the App | Per Amplitude's policy |
| OneSignal Inc. | United States, etc. | Push notification tokens, push subscription status, notification-related information, session, device and app information, IP address | Sending and managing push notifications | Network transmission through SDKs when configuring notifications or using the App | Per OneSignal's policy |
| RevenueCat Inc. | United States, etc. | In-app purchase information, product IDs, purchase and restore history, Premium access activation status, RevenueCat anonymous app user ID, advertising and device identifiers, IP address, Meta anonymous ID, ATT consent status | Purchase status verification, purchase restoration, subscription conversion and ad performance measurement | Network transmission through SDKs when launching the App, purchasing, or restoring | Per RevenueCat's policy |
| Meta Platforms, Inc. | United States, etc. | Meta anonymous ID, App Events such as app activation and install events, advertising identifiers, ATT/ad tracking authorization status, subscription conversion events through RevenueCat | Meta ad performance measurement and subscription conversion attribution | Network transmission through SDKs or RevenueCat integrations when launching, activating, purchasing, restoring, or measuring ad performance | Per Meta's policy |
| Apple Inc. / Google LLC | United States, etc. | Payment information, purchase history, App Marketplace account-related purchase status | In-app payment processing and refunds | Transmission through App Marketplace systems during purchase or restoration | Per each App Marketplace policy |

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## 5. Personalized Advertising and Affiliate Advertising

The App provides advertising through Google AdMob. Depending on the user's consent status, device settings, App Marketplace policies, and local laws, personalized or non-personalized ads may be displayed.

- **Information that may be collected**: Advertising identifiers (ADID/IDFA), app usage events, ad impression and click information, IP address, app set IDs or vendor identifiers, device information, diagnostic and performance information, Meta anonymous ID, app activation events, ATT/ad tracking authorization status
- **How to opt out of ad personalization**:
  - Android: Settings > Google > Ads > opt out of ad personalization or reset the advertising ID
  - iOS: Settings > Privacy & Security > Tracking > disable "Allow Apps to Request to Track"
- **Ad consent management**: Depending on region and policy, Google's ad consent form may be displayed.
- **Premium lifetime access**: Ads inside the App are removed when Premium lifetime access is purchased.

The App may display affiliate ads such as Coupang Partners. If a user clicks an affiliate ad, the user may be taken to an external website or app, and the terms and privacy policy of that external service will apply after the transition.

The App may use the Meta SDK and RevenueCat's integration with Meta to measure ad performance related to app activation, installs, and subscription conversions.

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## 6. Retention and Use Period of Personal Information

### 6.1 Data Stored on Device

Collection data saved by users in the App (photos, videos, titles, descriptions, memos, categories, media metadata, etc.) is kept only on the device. **When the App is uninstalled, app data stored on the device may be permanently deleted.** The Company cannot access or restore this data.

### 6.2 Inquiry Information

If a user contacts the Company, the email address, inquiry details, and attachments are retained for the period necessary to handle the inquiry and respond to disputes, and then destroyed. However, such information may be retained for a period required by applicable laws.

### 6.3 Automatically Collected Data

The retention period for data collected through third-party services follows each service provider's privacy policy or App Marketplace policy.

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## 7. Procedures and Methods for Destroying Personal Information

### 7.1 Data on Device

- **App deletion**: Uninstalling the App may delete collection data and app settings stored on the device.
- **Individual deletion**: Users can delete collections or individual photos and videos within the App.
- **Original deletion**: If a user explicitly chooses to do so, original photos or videos in the device gallery may be deleted after being saved in the App. Users should choose carefully because original deletion may affect device gallery data.

### 7.2 Inquiry Information

The Company destroys inquiry information whose retention period has expired or whose processing purpose has been achieved in a way that cannot be restored.

### 7.3 Third-Party Service Data

- **Advertising ID reset or ad personalization opt-out**: Users can reset the advertising ID or restrict personalized ads in device settings.
- **Push notification opt-out**: Push notifications can be disabled in App settings or device settings.
- **Purchase information**: Purchase information stored by App Marketplaces and RevenueCat is managed according to each service's policy.
- **Per-service deletion requests**: Data collected by third-party services can be requested for deletion according to each service's policies.

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## 8. Users' Rights and How to Exercise Them

Users may exercise the following rights in accordance with applicable privacy laws.

1. **Request information about personal data processing**: Confirm the items of personal information collected and the purpose of use.
2. **Request correction or deletion of personal information**: Request correction or deletion of inquiry information directly provided to the Company.
3. **Delete data on the device**: Delete local data using in-app deletion features or by uninstalling the App.
4. **Opt out of ad personalization**: Refuse personalized ads through device settings or an ad consent form.
5. **Opt out of push notifications**: Refuse push notifications through App settings or device settings.
6. **Manage App Marketplace purchase information**: Manage purchase history and refund requests through Apple App Store or Google Play accounts.

Because the Company cannot access collection data stored only on the user's device, users must view, modify, or delete such data directly in the App or on the device. For exercising the above rights or inquiries regarding personal information, please contact the Privacy Officer below, and we will take prompt action.

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## 9. Measures to Ensure the Security of Personal Information

The Company takes the following measures to securely manage users' personal information.

1. **Local storage principle**: Users' photos, videos, and collection content are stored only in the device's internal storage and are not transmitted to Company servers.
2. **Minimum collection principle**: Only the minimum information necessary for service operation is collected and processed.
3. **Permission minimization**: Camera, microphone, gallery, and notification permissions are requested when needed for a feature.
4. **Secure communication**: HTTPS and other encrypted communication methods are used when communicating with third-party services.
5. **Access restriction**: Inquiry information directly collected by the Company is accessed only within the scope necessary for business purposes.

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## 10. Protection of Children's Personal Information

The App is available to users of all ages, but the Company does not intentionally collect personal information from children under the age of 14. If we become aware that personal information of a child under 14 has been collected, we will take reasonable steps to delete such information.

If a legal guardian has inquiries regarding the processing of a child's personal information, please contact the Privacy Officer below.

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## 11. Privacy Officer

The Company designates a Privacy Officer as follows to oversee personal information processing and to handle user complaints and remedies.

| Item | Details |
|------|---------|
| Company | ConnectionValue Inc. |
| Representative | Hyeonseung Kim |
| Privacy Officer | Hyeonseung Kim |
| Email | [email protected] |
| Address | 4F, 401-38, 31-11 Yesul-gil, Dong-gu, Gwangju, Republic of Korea |

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## 12. Remedies for Rights Infringement

Users may contact the following organizations for dispute resolution or consultation regarding personal information infringement.

| Organization | Contact | Website |
|-------------|---------|---------|
| Personal Information Dispute Mediation Committee | 1833-6972 | <https://www.kopico.go.kr> |
| Personal Information Infringement Report Center | 118 | <https://privacy.kisa.or.kr> |
| Supreme Prosecutors' Office Cyber Investigation Division | 1301 | <https://www.spo.go.kr> |
| National Police Agency Cyber Bureau | 182 | <https://ecrm.cyber.go.kr> |

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## 13. Changes to This Privacy Policy

This Privacy Policy is effective from the enforcement date. If there are additions, deletions, or modifications due to changes in laws or services, we will notify users through in-app notices or other methods designated by the Company at least 7 days prior to implementation. However, changes that do not materially affect user rights or urgent changes required for legal or policy compliance may be notified after they take effect.

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**Effective Date**: March 27, 2025  
**Last Updated**: June 17, 2026