Privacy Policy

1. Scope and Age Notice

This Privacy Policy applies to the "CUDDLES" mobile app for parents/guardians.

This app does not use the microphone function, and its screens are not designed for children to directly enter or provide personal information.

However, service data such as a child's voice and conversations may be generated, transmitted, and stored on our servers through a plush toy (device) linked to the guardian's account. In such cases, the processing, storage, and deletion of that data are subject to the choice and control of the guardian (legal representative), for example via in-app deletion features.

This app does not target children under the age of 14 (in the Republic of Korea) or under the age of 13 (in the United States) as direct service users, and where required by local laws, we comply with guardian consent and notice procedures.

2. Personal Information We Collect

(1) Account Registration / Account Management
Email address, password (hashed), nickname

(2) Automatically Collected Information (Service Operation)
Device information (OS / model / app version), access IP, access date and time, app usage event logs, push tokens, advertising identifiers (AAID / IDFA)

(3) Children's Conversation Data (via Device Linking)
- Source: Plush toy (device) → linked to guardian's account
- Content: Transcripts (text) of a child's voice and conversations
- Management: The guardian can optionally delete this data immediately from within the app

We do not currently collect any additional items beyond the above. Any future changes will be announced in advance and will be subject to required consents.

3. Purposes of Use

• Member identification and account management, service provision, maintenance, and improvement
• Customer support and error analysis (including ensuring stability and preventing misuse)
• Providing personalization and history based on children's conversation data (e.g., maintaining previous conversation context)
• (With optional consent) Notices, events, and marketing communications
• In-app advertising (AdMob) delivery and performance measurement (depending on personalized / non-personalized ad settings)

4. Retention and Destruction

• Account information: Destroyed without delay upon membership withdrawal
• Access logs / event logs: Retained for the minimum period required by applicable laws, and destroyed within a maximum of 3 years in accordance with our internal policy
• Children's conversation data: Destroyed immediately upon the guardian's choice to delete; if not deleted, destroyed when the purpose of service provision is achieved or when the account is deleted
• Transaction / payment records (in-app purchases): Retained for up to 5 years in accordance with applicable laws such as e-commerce regulations
• Destruction method: Electronic files are destroyed using technical methods that prevent recovery or reproduction; paper documents are destroyed by shredding, incineration, or similar physical methods

5. Provision to Third Parties (AdMob / Google Ads)

In principle, the Company does not provide users' personal information to third parties. However, the following third-party disclosures may occur for the purpose of serving in-app advertisements.

• Third party: Google LLC (AdMob / Google Ads)
• Purpose: In-app ad delivery and performance measurement (personalized / non-personalized advertising)
• Items provided: Advertising identifier (AAID / IDFA), device and app information, approximate IP / region, ad impression and click events, etc.
• Retention / Use period: In accordance with the third party's policies

※ You can change your consent to receive personalized ads at any time under App Settings > Privacy / Advertising.

6. Entrusted Processing (Processors)

To improve service quality, we entrust personal information processing tasks as follows.

7. Overseas Storage (Cross-Border Transfer)

To operate the service, we use Google Cloud Platform (including Firebase) infrastructure, and user information may be stored and processed on servers located in the United States.

• Recipient: Google LLC (GCP / Firebase)
• Country of transfer: United States
• Items transferred: Account information, service logs, children's conversation data (when linked), etc.
• Timing / Method of transfer: Real-time network transfer during service use

8. Payment (In-App Purchase) Notice

Paid purchases are processed through app store payment systems such as the Apple App Store and Google Play. The Company does not store sensitive payment information such as card numbers.

9. User Rights and How to Exercise Them

Users may request access to, correction of, deletion of, or suspension of processing of their personal information.

• Children's conversation data can be deleted immediately by the guardian from within the app.
• Account deletion can be performed directly from within the app.
• For any other requests, please contact support@cuddles-anc.com.

10. Security Measures

Transport encryption (TLS), one-way hashing of passwords, minimization of access privileges, access log management, and compliance with GCP / Firebase security policies.

11. Data Protection Officer and Contact

• Data Protection Officer: Hyunbae Jeon (CEO, Cuddles ANC Inc.)
• Email: support@cuddles-anc.com
• Phone: +82-32-818-3226

12. Notice and Amendments

If there are any additions, deletions, or modifications to this Policy, we will notify users via an in-app announcement starting at least 7 days before the effective date. For material changes to user rights, we will provide notice at least 30 days in advance.