Privacy Policy
Effective date: [시행일] · Pre-launch version · effective after legal review
This is a translation. If it differs from the Korean original, the Korean version prevails.
세온안 (the "Company") processes Users' personal information in the naONu service as described below, in accordance with the Personal Information Protection Act. In particular, photos showing faces are used only to generate the videos requested by the User and are deleted after 30 days.
1. Personal Information Processed, Purposes and Retention Periods
| Item | Purpose | Retention period |
|---|---|---|
| (Required) Login information: Kakao, Google or Apple account identifier, email (if provided), nickname | Sign-up and login, identity verification, account management, notices | Until account deletion |
| (Required, when generating) Face photos and full-body photos | AI video generation requested by the User (applying the face and body to the person in the video) | 30 days from upload, or deleted immediately upon account deletion |
| Videos and stills created, options selected | Providing the Library, sharing and gifting, regeneration and refunds on failure | Until the User deletes them or deletes the account |
| Creator Challenge videos and song titles, and Recipes uploaded by the User | Review; when published, providing them to other Users and generating videos; paying rewards | Until the User takes them down or deletes the account |
| Credit and payment records (product, amount, payment date and time, store transaction ID) | Payment confirmation, refunds, settlement, dispute handling | Under the Act on the Consumer Protection in Electronic Commerce: contract and payment records 5 years; consumer complaint and dispute records 3 years |
| Device identifier (a random value per app installation), ad viewing and mission completion records, invite code records | Preventing fraudulent use (duplicate rewards, duplicate sign-ups), ad and mission rewards, invitation rewards | 1 year |
| Access logs (IP, access time, app version), usage statistics (app opens, video views and share counts) | Security, incident response, service improvement | Under the Protection of Communications Secrets Act: access logs 3 months; statistics are kept after being aggregated so that individuals cannot be identified |
| (Optional) Notification token (your phone's push address), notification language | Video ready / failed notifications | Until you turn off notifications, delete the app, or close your account |
| App error logs (error message, screen where it occurred, phone OS and version, app version) | Fixing errors, service stability | 1 year |
| (Optional) Text and attached screenshot sent via "Send feedback" in the app, OS and app version | Replies, service improvement | 3 years after the reply |
| (Optional) Email address and content of inquiries | Responding to inquiries | 3 years after the response |
The Company does not use face photos to identify Users (facial recognition) or for other purposes such as AI training. Accordingly, face photos are not processed as biometric information for identity verification. The Company does not collect Users' resident registration numbers.
2. How Personal Information Is Collected
We receive it from the social login provider at sign-up and login, from photos the User takes or selects when creating videos, and automatically during use of the Service (access logs, device identifiers, advertising identifiers).
3. Provision to Third Parties
The Company does not provide personal information to third parties without the User's consent or a legal basis. In gifting and shooting with friends, the nickname and message sent by the User are shown to the recipient.
4. Outsourcing of Processing
| Recipient | Tasks outsourced |
|---|---|
| NAVER Cloud Corp. | Operation of servers, databases and file storage |
| Toss Payments Co., Ltd., Kakao Pay Corp. | Web payment processing |
| Apple, Google | In-app purchases, social login |
| Kakao Corp. | Social login |
| App install mission ad network (name to be listed here after contract) | Providing missions and confirming completion |
5. Transfer Overseas
To create videos, photos and scene descriptions must be sent to overseas AI engine companies. The transfer takes place over an encrypted network (HTTPS) each time the User requests video generation.
| Recipient (country) | Items | Purpose | Retention period |
|---|---|---|---|
| Features & Labels, Inc. — fal.ai (USA) | Photos, scene descriptions, original challenge and meme videos | AI video and image generation | Deleted within a short period after generation is complete, in accordance with each company's policy |
| Higgsfield AI (USA, when connected) | Photos, scene descriptions, original videos | AI video generation | Same as above |
| 650 Industries, Inc. — Expo push service (USA), Google — Firebase Cloud Messaging, Apple — APNs | Notification token, notification text (video title) | Delivering ready notifications to your phone | In accordance with each company's policy after delivery |
| Google LLC — AdMob (USA) | Advertising identifier, ad viewing records | Serving ads, confirming rewards | In accordance with Google's policy |
How to refuse and its effect: If you do not want your information transferred overseas, you may choose not to create videos or delete your account. However, since video generation is possible only through overseas engines, refusing the transfer means you cannot use the video generation features. You can turn off the advertising identifier in your phone's settings (opt out of personalized ads).
6. Information Visible to Other Users
- The title, description, song title and nickname of published Recipes and Creator Challenges, and Creator Challenge videos.
- Recipe covers are AI posters; scenes from the author's video are shown only if the author consents.
- The sender's nickname and message in gifts and shooting with friends.
7. Automatic Collection Tools
The app does not use cookies. It uses the phone's advertising identifier (ADID/IDFA) to serve ads and confirm rewards, and on iPhone it uses the IDFA only if consent has been given through App Tracking Transparency (ATT). You can turn it off at any time in your phone's settings.
8. Destruction
When the retention period ends or the purpose has been achieved, files in storage and database records are deleted so that they cannot be recovered. Expired photos are deleted by an automatic daily cleanup job. Payment records that must be kept by law are stored separately and deleted once the period expires.
9. Users' Rights and How to Exercise Them
- You can delete photos, videos, Recipes and Creator Challenges, and delete your account, at any time in the app.
- You may request access to, correction, deletion or suspension of processing of your personal information, or withdraw consent, by email to the address below, and the Company will notify you of the result within 10 days.
- You may also make requests through an agent; in this case, please send a power of attorney with the request.
10. Children Under 14
The Company does not accept sign-ups from persons under 14 years of age. If the Company learns that a person under 14 has signed up, it will delete the account and information.
11. Security Measures
- Administrative: The number of people who handle personal information is kept to a minimum, and access rights are managed.
- Technical: Encryption in transit (HTTPS), photo files accessible only through short-lived signed URLs, protected administrator login with access logs, separate storage of passwords and keys, and removal of metadata from videos sent to engines.
- Physical: The access controls of NAVER Cloud data centers apply.
12. Chief Privacy Officer and Grievance Handling
신동근(대표) · enkingka@gmail.com · enkingka@gmail.com
Reports and consultation on personal information infringement: Personal Information Infringement Report Center (privacy.kisa.or.kr, 118 without area code), Personal Information Dispute Mediation Committee (www.kopico.go.kr, 1833-6972), Supreme Prosecutors' Office (www.spo.go.kr, 1301), Korean National Police Agency (ecrm.police.go.kr, 182)
13. Changes to This Privacy Policy
If this Privacy Policy is changed, the Company will give notice in the app and on the website from 7 days before the effective date (30 days for material changes). This Privacy Policy takes effect on [시행일].
세온안 · 대표 신동근 · 사업자등록번호 156-02-03279 · 통신판매업 신고번호 제2024-경남창녕-0079호 · 경상남도 창녕군 남지읍 남고길 65, 101동 6층 601호(남지이원웰스타) · Contact enkingka@gmail.com