Privacy Policy

Last updated: 2026-05-27 · Effective: 2026-05-27

This Privacy Policy explains how 더부크 ("we", "us", "the Service") collects, uses, stores, and protects your personal information when you use the Korly mobile application. We follow the Personal Information Protection Act of the Republic of Korea ("PIPA"), the EU General Data Protection Regulation ("GDPR") where applicable, and other relevant privacy laws.

1. Data Controller and Contact

The data controller of your personal information is 더부크 (the "Operator"). Business information is provided at the bottom of this page.

Data Protection Officer (DPO): 김영호 (representative), korly.dev@gmail.com. The DPO is responsible for handling privacy questions, complaints, and your data rights requests.

2. Information We Collect

We do not collect sensitive personal information (e.g., race, religion, political views, health, biometrics) or resident registration numbers.

3. Legal Basis (GDPR users)

• Performance of a contract — providing the Service you signed up for (account, learning features, subscription).
• Consent — marketing communications, advertising tracking, optional features. You can withdraw consent at any time.
• Legitimate interests — service security, fraud prevention, product analytics in aggregated form.
• Legal obligation — record retention required by tax and consumer-protection laws.

4. How We Use Your Information

• Provide and personalize the learning experience (recommend articles, track progress, schedule flashcards).
• Authenticate you and keep your account secure.
• Send transactional notifications (subscription renewals, important account events, daily learning reminders).
• Diagnose crashes and improve product quality.
• Display advertising to free-tier users and measure its effectiveness.
• Process subscription purchases and comply with consumer-protection laws.
• Detect, prevent, and respond to fraud, abuse, or violations of our Terms of Service.

We do not use your personal data to train AI models. The Service uses third-party AI APIs (e.g., Google Vertex AI) to process publicly sourced articles for learning, not your personal content or activity.

5. Marketing Communications

We send marketing messages (new features, promotions, learning tips) only to users who have explicitly opted in. Marketing consent is collected separately from this Privacy Policy on a per-channel basis (push notifications, email). See the Marketing Communications Consent document for details. You can withdraw consent at any time in app Settings or via the unsubscribe link in marketing emails.

6. Automated Decision-Making

We use algorithms to recommend content based on your reading history, level, and saved items. These recommendations do not produce legal effects or significantly affect you. You may opt out by adjusting your filters in the app or contacting us.

7. How We Share Your Information

We do not sell your personal information. We share data only with service providers that operate Korly on our behalf, under contracts that require appropriate safeguards:

8. International Transfers

Many of our service providers process data in the United States or across global edge networks. By using the Service, you consent to the transfer of your personal information to these countries as required for the providers above. For users in Korea, this constitutes consent under PIPA Article 28-8 (cross-border transfer). For users in the EU/EEA/UK, transfers rely on the EU Standard Contractual Clauses or equivalent safeguards.

9. Data Retention and Deletion

We retain your personal data while your account is active. When you delete your account (Settings → Account → Delete Account), we delete or anonymize your personal data within 30 days, except for records we must keep by law:

• Payment and transaction records — 5 years (Electronic Commerce Act, Korea)
• Records of consumer complaints — 3 years
• Access logs — 3 months (Communications Privacy Act)

10. Your Rights

Depending on your jurisdiction, you have the following rights:

• Access — request a copy of personal data we hold about you.
• Rectification — correct inaccurate or incomplete data.
• Deletion — delete your data ("right to be forgotten").
• Restriction — limit how we process your data in certain situations.
• Portability — export your data in a machine-readable format.
• Objection — object to processing based on legitimate interests or for direct marketing.
• Withdraw consent — for any processing based on consent, at any time.
• Complain — to your supervisory authority (e.g., Personal Information Protection Commission in Korea, your local data protection authority in the EU).

To exercise these rights, contact the DPO at korly.dev@gmail.com. We respond within 10 days for Korean residents (PIPA) and within 30 days for EU/EEA residents (GDPR). We may need to verify your identity before fulfilling the request.

11. Children's Privacy

Korly is intended for users aged 14 and above, in line with the Korean Information and Communications Network Act. We do not knowingly collect personal information from children under 14. The app's sign-up flow requires confirmation of age. If you believe a child under 14 has provided us with personal information, contact us immediately so we can delete it.

12. Advertising and Tracking (iOS)

On iOS 14.5 and later, we request your permission through Apple's App Tracking Transparency (ATT) framework before using your advertising identifier (IDFA). If you decline, ads remain available but are not personalized. You can change this choice at any time in iOS Settings → Privacy & Security → Tracking. On Android, you can reset or limit ad personalization in your device's Google Settings.

13. Security

We use industry-standard safeguards including TLS encryption in transit, encryption at rest through our service providers, access controls, and regular security review of our infrastructure. No method of transmission over the internet is completely secure, but we work to protect your data.

14. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated through the app or by email at least 7 days before they take effect. The "Last updated" date at the top of this page reflects the most recent revision.

15. Contact

Questions, requests, or complaints about this Privacy Policy:

korly.dev@gmail.com

If you are not satisfied with our response, you may contact the Personal Information Protection Commission of Korea (privacy.go.kr), the Korea Internet & Security Agency (kisa.or.kr), or your local supervisory authority.