1. Privacy Policy

Saju KKINI (the “Service”) values User privacy and publishes this Privacy Policy to process personal data lawfully and securely under the Korean Personal Information Protection Act and other applicable laws.

This English version is provided for convenience. If it differs from the Korean version, the Korean version governs to the extent permitted by mandatory local law.

Article 1. Purpose and Scope

This Policy applies to personal-data processing involved in the Saju KKINI app and related account management, authentication, saju analysis, meal recommendations, meal and lifestyle records, reports, points, rewarded advertising, purchase and subscription verification, notifications, and customer support. Data is processed only as needed for stated purposes. Material changes to purposes, items, or methods receive any notice or consent required by law.

Article 2. Definitions

1. “User” means anyone who uses the Service, whether registered or not.
2. “Member” means a User who completes registration and uses an account.
3. “Guest” means a User who accesses permitted features without creating or signing into an account.
4. “Data Subject” means the person to whom entered birth, allergy, food, meal, or other information actually relates.
5. The Member and Data Subject may be the same or different persons—for example, an adult Member lawfully using the Service for a family member.
6. Applicable data-subject rights and protections are not excluded merely because the Data Subject differs from the Member.

Article 3. Basic Processing Principles

The Service processes personal data only on a lawful basis. Data needed to create or perform a contract—including registration, login, requested analysis, recommendations, records, reports, and purchased services—is processed only as necessary. Where separate consent is required, the Service separately explains the purpose, items, retention period, right to refuse, and consequences before obtaining consent. Publishing this Policy does not itself constitute consent where separate consent is required.

Article 4. Personal Data Processed

The Service may process the following data according to the features used.

1. Account and authentication

• Email address, Member identifier, display name, login provider, and authentication status
• Google account data needed for Google login, authentication, and Member identification

2. Saju analysis and personalization

• Date of birth; solar or lunar calendar type
• Birth time or an indication that it is unknown; gender
• Birth country and region
• Region identifier, coordinates, and time zone used for time and regional calculations
• Saju analysis results, traditional-analysis values, and personalization derived from them

3. Residence and localization

• Country and region of residence
• Region identifier, coordinates, and time zone used to identify the selected region and reflect local time and food availability

This data supports recommendations that consider regional food culture, ingredient availability, time zones, and feature availability. It is based on the region registered by the User. Any future feature using current-location permission will provide a separate permission and processing notice.

4. Food and meals

• Food and ingredient preferences and exclusions
• Foods selected or eaten, recommendations shown, and whether a recommendation was followed
• Meal name, time, and schedule
• Explicit records that a meal was skipped
• User-selected reactions or circumstances related to a meal
• Meal notes and free text

5. Allergy data

The Service may process registered allergenic foods, ingredients, or food groups to exclude related candidates from recommendations. Because allergy data may be sensitive health data, it is processed only after separate consent specifically for sensitive-data collection and use.

• Items: registered allergenic foods, ingredients, and food groups
• Purpose: exclusion of relevant foods and improved allergy-related recommendation safety
• Retention: until the Member deletes the data, withdraws consent, or account deletion is completed, unless law requires longer retention
• Refusal: core features not requiring allergy registration may remain available, but allergen-based exclusion may not be provided

After consent, Members may add, edit, or delete items within the same purpose without repeating identical consent each time.

6. Lifestyle and situational records

• User-selected or entered lifestyle and meal circumstances
• User-recorded states or reactions such as stress or overeating
• Free-text notes

If actual content becomes formally processed sensitive information, the Service applies any separate consent or other procedure required by law. The Service does not ask Users to enter unnecessary disease information, political views, religion or beliefs, sexual-life information, or other sensitive content in free-text fields.

7. Reports and AI analysis

• Recommendations and candidates
• Saju analysis and interpretations
• Values needed to create reports
• Issued report summaries, details, date, target period, status, and quality-check results
• Minimum meal, lifestyle, restriction, and analysis data needed for AI processing

8. Points, rewards, and advertising

• Point accrual, use, recovery, and adjustment history
• Participation in attendance, roulette, rewarded ads, and other rewards
• Transaction and event identifiers used to verify rewards
• Rewarded-ad verification status and transaction identifiers

When the Google Mobile Ads SDK is used, Google may process IP address, app launches, taps, video views, diagnostics, advertising ID, app set ID, and similar device or account identifiers for ad delivery, measurement, analytics, security, and fraud prevention.

9. Purchases and subscriptions

• Product or subscription identifier
• Order and transaction identifier
• Purchase token or verification information
• Purchase date and access period
• Subscription, renewal, cancellation, and refund status

Google Play processes detailed payment-method information such as card numbers; the Service does not directly store it.

10. Notifications and device data

• Push token, installation identifier, platform, notification time zone and settings
• Service and marketing notification choices
• Error and incident records and technical data needed to operate the app

Article 5. Collection and Processing Methods

Data may be provided directly during registration, login, settings, saju, food, meal, allergy, and lifestyle features; received within User-authorized scope from Google login or Google Play; generated or processed automatically for operation, security, notifications, or advertising; or sent in minimized form to external AI processors to produce a requested recommendation, analysis, or report.

Article 6. Processing Purposes

Data is processed for account registration, authentication and management; saju analysis and personalization; meal recommendations; allergy and exclusion handling; regional localization; meal and lifestyle record management; personalized reports; Premium and one-time product fulfillment; points and reward verification; notifications; advertising and rewarded ads; customer support and dispute handling; security and fraud prevention; quality improvement, analytics and feature development; and production of the statistics described in Article 10.

Article 7. Users Under 18

Registration and all Member and Guest use are intended only for persons aged 18 or older. Persons under 18 may not use the Service. Users must provide truthful eligibility information and must not use another person’s information or account to bypass age restrictions. If underage use is discovered, the Service may apply restrictions required by law, external-service terms, and the Terms of Service. The Service is not operated to solicit persons under 18 as Members or Users.

Article 8. Information About Another Data Subject

An adult Member may use features for themselves or another person, such as a family member, only where the Member has lawful authority to have that information processed under this Policy. That person does not become a Member or User merely because information about them is entered.

If the Data Subject is under 14 and consent is legally required, the Service applies a process to obtain and verify consent from the child’s legal representative. This does not grant the child an account or permission to use the Service. Separate sensitive-data consent is also obtained through the legal representative where required for allergy or similar data. Outside Korea, applicable local child-privacy and parental-consent rules may require additional procedures or feature restrictions.

Article 9. Local Guest and Free-Member Records; Premium Synchronization

Meal and lifestyle records created by Guests and unpaid Members are stored locally on the device. They are not automatically uploaded or used in Premium reports or server-based cumulative personalization. Records created while Premium is active are linked to the account and synchronized to the server; offline records may be temporarily stored and synchronized later.

Device-only data may be lost when the app is deleted, the device changes, storage is reset, or the device fails. At registration or login, a User may choose whether existing guest records continue as local records for that account. This choice does not automatically upload them or include them in server reports. Guest and multiple-account local records are kept in separate namespaces and are not reassigned without an explicit choice. Guests remain protected by applicable privacy law.

Article 10. Analytics and Statistical Information

Within applicable law, the Service may analyze and aggregate meal choices, recommendation acceptance, lifestyle records, and usage patterns by criteria actually collected, such as age group, gender, or region. The Service may produce statistical information from which no individual can reasonably be identified even when other information is considered. This does not mean merely removing a name or email from row-level or re-identifiable data.

Such non-identifiable statistics may be used for quality improvement, product development, research, trend analysis, market research, other business purposes, or provided to third parties while remaining non-identifiable. Deleting an account removes account-linked personal and individual usage data under the stated process, but previously created non-identifiable aggregate statistics may remain. Raw or re-identifiable data is not retained merely by labeling it “statistics.”

Article 11. Third-Party Disclosure

The Service does not sell personal data to third parties without consent. Disclosure may occur only with separate prior consent, where specifically required or permitted by law, or as otherwise lawfully authorized. Non-identifiable statistics described in Article 10 are handled separately from individual personal data.

Article 12. Processors and External Services

The Service uses the following external services:

1. Supabase, Inc.

• Purpose: authentication, database, server functions, storage, and Service-data processing
• Data: identifiers and information needed to operate saju, meal, lifestyle, recommendation, report, point, and subscription features
• Primary database region: Seoul, South Korea (ap-northeast-2)

2. Google LLC

• Services: Google Sign-In, Google Play Billing, Firebase Cloud Messaging, Google Mobile Ads, and Gemini API
• Purpose: authentication, purchase and subscription verification, push notifications, advertising and rewarded ads, and AI meal recommendations, analysis, and reports
• Data: minimum account identifiers, purchase information, push tokens, ad and device information, and Service data needed for the relevant AI request

3. OpenAI OpCo, LLC

• Service: OpenAI API
• Purpose: saju analysis and AI interpretation features
• Data: minimum analysis data needed for the feature, such as saju results already calculated by the Service

The Service minimizes direct identifiers such as email addresses and Member IDs in requests sent to external AI processors where those identifiers are unnecessary.

Article 13. International Transfers

Data may be processed outside the User’s country where permitted by Article 28-8 of the Korean Personal Information Protection Act or another applicable legal basis and as necessary to provide requested features and perform the Service contract. Separate notice and consent are provided where legally required.

The primary database is in Seoul, South Korea. Users outside Korea may therefore have data transferred to Korea. Some information may also be processed in other countries through Supabase support and Edge Functions or Google and OpenAI global infrastructure.

1. Supabase, Inc.

• Recipient: Supabase, Inc. and its service subprocessors
• Contact: privacy@supabase.io
• Locations: the Seoul primary database and, depending on Edge Function execution, support, or reprocessing, Korea, Japan, India, Singapore, Australia, Canada, the United States, Germany, Switzerland, Ireland, the United Kingdom, France, or Brazil
• Data: identifiers, authentication and request data, and minimum saju, meal, lifestyle, recommendation, report, and subscription data needed for the server function
• Purpose: authentication, database and server operation, request processing, security, and incident response
• Timing and method: encrypted network transfer when the relevant function is used
• Retention: as needed to provide the Service and under Supabase contractual and processing policies
• Choice and effect: Users may contact n.director@noonsaju.com or stop using the relevant server feature; refusing essential processing may prevent login, synchronization, AI recommendations, or reports

2. Google LLC

• Recipient: Google LLC and processors acting for Google
• Locations: the United States and other locations used by Google for the relevant service, as updated by Google
• Data: saju analysis, food, meal and lifestyle records, food restrictions, language and country data, and AI input and output needed for Gemini; plus data needed for Google Sign-In, Google Play, FCM, and Google Mobile Ads
• Purpose: Gemini recommendations, analysis and reports; login; purchase verification; push; advertising and rewarded ads; and security
• Timing and method: encrypted network transfer when the feature is used
• Retention: until the purpose is fulfilled and under Google’s applicable contracts and policies. Prompts and responses in paid Gemini API services are not used for product improvement and may be logged for a limited period for abuse monitoring, safety, security, and legal compliance
• Choice and effect: Users may stop an optional feature, withdraw relevant consent, or contact n.director@noonsaju.com; refusal may make the relevant Gemini, Google login, push, advertising, or Google Play feature unavailable

3. OpenAI OpCo, LLC

• Recipient: OpenAI OpCo, LLC and API subprocessors
• Contact: privacy@openai.com
• Locations: the United States and API processing locations published by OpenAI, which may include Korea, Japan, Singapore, Australia, Brazil, Canada, India, Indonesia, the United Kingdom, and parts of Europe
• Data: minimum analysis data and AI input and output needed for saju analysis and interpretation
• Purpose: AI analysis and interpretation, safety, and abuse prevention
• Timing and method: encrypted network transfer when the feature is used
• Retention: API input and output may currently be retained for abuse monitoring for up to 30 days, except where longer retention is legally required
• Choice and effect: Users may avoid the AI feature or contact n.director@noonsaju.com; refusal may make OpenAI-powered saju analysis and interpretation unavailable

The Policy will be updated, or any required notice and consent obtained, if processors, transfer locations, or the actual processing structure materially changes.

Article 14. Retention

Personal data is generally retained until its purpose or lawful need ends and is then deleted. A Member deletion request is subject to the seven-day waiting process in Article 23 and the Account Deletion Policy. Transaction and dispute records required by law are separated from general Service data and retained only for the required purpose.

Separately, a minimal deletion audit record—including the request identifier, a one-way hash of the user identifier, request date, and final deletion date—is retained for three years after final deletion to verify processing and handle deletion-related errors, disputes, and security. It is not used to restore the account or provide personalization and is deleted after that period.

Article 15. Destruction

When no longer needed, personal data is deleted under applicable law. Electronic data is made unavailable in the normal Service environment. Data legally required to be retained is separated and deleted at the end of the period. If deleted data remains temporarily in technical cloud backups, it is not used for normal service or discretionary restoration and is removed under the provider’s backup and deletion cycle.

Article 16. Data-Subject Rights

Under applicable law, Data Subjects may request access, correction, deletion, restriction, suspension, or withdrawal of consent. Members may directly review or edit certain information and may request account deletion through the app or public deletion page. Withdrawing consent for sensitive data such as allergies may cause the information to be deleted and related personalization to stop.

A Data Subject other than the Member, or their legal representative, may contact n.director@noonsaju.com where applicable law recognizes the request. The Service reasonably verifies identity and authority before responding within the required period.

Rights outside Korea

Depending on applicable local law, Users or Data Subjects may have additional rights, including:

Where the Service engages in processing legally defined as sale, sharing, targeted advertising, or an equivalent activity, it provides required choices. Users are not unlawfully discriminated against for exercising rights. Stricter local requirements for sensitive or health-related data take precedence.

Article 17. Notifications and Marketing

Based on device choices, the Service may send non-advertising notifications such as daily energy notices to Members or Guests. For Guests, it may process only the minimum device data needed, such as installation ID, push token, platform, time zone, and notification settings.

Daily energy, meal and service notifications, and promotional event or benefit messages are managed separately. Marketing push or electronic advertising is sent only to Users who separately opt in where law requires. Consent to a non-advertising notification is not treated as marketing consent. Users can change notification choices in the relevant feature or settings, and refusal of marketing does not improperly restrict unrelated core features.

Article 18. Automatically Processed Device and Advertising Data

For operation, security, push, error handling, advertising, and rewarded ads, the Service or external SDKs may automatically process installation ID, push token, platform, time zone, IP address, app interactions, diagnostics, advertising ID, and app set ID. The exact information handled by Google Mobile Ads depends on the SDK feature, device settings, and Google policy.

Users may change push permission in the app or operating system and manage advertising ID and personalization through Android and Google privacy settings. Some non-personalized advertising may remain visible. Material changes to automatically processed information or purposes receive legally required notice.

Article 19. Security

The Service applies reasonable technical and organizational measures appropriate to its data and scale to prevent loss, theft, leakage, alteration, and damage. Measures include authentication and access management, per-user access restrictions, protected server communications, administrator access controls, logging, and incident response.

Article 20. Privacy Officer

• Service: Saju KKINI
• Operator and Privacy Officer: Eunseon Kim
• Email: n.director@noonsaju.com

Requests concerning access, correction, deletion, sensitive-data consent withdrawal, account deletion, or privacy complaints may be submitted through this contact.

Article 21. Changes to This Policy

This Policy may be amended when law, Service features, external processors, or processing methods change. Changes materially affecting User rights or processing receive notice through the app or public webpage in the manner and period required by law.

Article 22. Generative AI and Automated Results

Some meal recommendations, analyses, and reports use generative AI or automated analysis. Because of the technology, wording or parts of a result may vary even with the same input. The relevant feature or screen identifies AI-based results so Users can recognize them.

Article 23. Account Deletion

Members may request deletion through the in-app account-deletion feature or public account-deletion page. Before acceptance, the Service verifies account ownership through a recent authentication check, re-login, registered-email verification, or another provided method.

After a valid request, the account enters pending-deletion status for seven days from the request date. During that period, the Member may sign in and explicitly cancel the request; merely opening the app or signing in does not cancel it automatically. When the period ends, the account and linked server personal data and individual usage records are processed for permanent deletion and generally cannot be restored. Legally retained transaction or dispute records and already-created non-identifiable statistics are handled under their separate rules.

Effective date: September 5, 2026