Privacy

Privacy Policy

Full text

Foo AI Corp. (the “Company”) establishes and discloses the following privacy policy under Article 30 of the Personal Information Protection Act (PIPA) in order to protect the personal information of data subjects and to handle related grievances promptly.

Griing is an AI English learning service for adults aged 18 and over. The AI coach is generative artificial intelligence and is not a person. The Company does not accept sign-up by children under 14, and actively blocks use by anyone under 18.

1. Purposes of processing personal information

PurposeDetails
Sign-up, member management, identity verificationConfirming adults aged 18 and over, blocking children under 14, preventing fraudulent use, account recovery
Providing the AI English learning serviceConversation, correction, accumulation and review of expression assets, weekly reports, processing of voice replies
Payment and subscription managementPaid subscription payment, auto-renewal, refunds, retention of transaction records
Sending notificationsLearning briefings (functional), transaction and policy notices (system), promotional information (with consent)
Safety and crisis responseSafe responses and referral to specialized institutions when expressions of self-harm or suicide are detected
Service improvementError analysis, quality evaluation (use of conversation logs for model improvement requires separate consent and is subject to opt-out)
Meeting legal obligationsRetention of records required by law, such as the Electronic Commerce Act and the Information and Communications Network Act

2. Personal information items processed

CategoryItemsCollection method
Required (member)Mobile identity verification information (name, date of birth, gender, domestic or foreign national status, DI (duplicate join verification information); CI is not retained), email or social login identifierIdentity verification agency integration
Required (service)English conversation text, correction results, expression assets, List of Facts (name, occupation, goals, interests, 5 to 10 items), learning history and review, self-assessed levelGenerated during use
OptionalVoice replies (only the transcript is stored, original audio 0 days), voice corpus (with opt-in consent)User input
Automatically generated(App) device identifier, push token, access IP and logs, app usage events (conversation content is not included, only hashed identifiers)
(Web) referral cookie (griing_ref), anonymous analytics identifier (griing_aid), page usage events
Automatically collected
PaymentSubscription status, payment method token (original card details are not retained, the payment gateway handles them), transaction historyAt the time of payment

Policy of not storing original voice audio: a voice reply is deleted immediately after speech-to-text (STT) conversion and is not stored on the server. If audio temporarily remains because the conversion pipeline failed, it is automatically destroyed within 24 hours at most.

Automatic collection devices on the web (cookies and local storage): the marketing web attributes the inbound source using the first-party cookie griing_ref (an opaque value that holds an invitation or referral code, retained for 30 days). Only where the built-in analytics feature is active, the anonymous identifier griing_aid (a random value stored in the browser that persists until the user deletes it) and usage events such as page views and clicks are processed with a first-party analytics tool, and the overseas transfer to that tool follows Section 7. These values do not identify an individual and are not used for cross-site tracking for advertising purposes. A user may delete or block cookies and local storage in the browser settings at any time to refuse collection, and refusing does not restrict use of the Service.

3. Processing of sensitive information and unique identifying information

  • The Company does not collect sensitive information such as health, psychiatric treatment, or sex life as a purpose. Where sensitive information enters a conversation, that utterance is excluded from expression assets, review, and use for model improvement, and is not stored separately.
  • The Company does not provide speaker identification, voice authentication, or voice cloning features, and does not extract or process biometric information (feature points) from voice. Voice is processed only as text, limited to the purpose of pronunciation and expression learning.
  • The Company does not process resident registration numbers. Identity verification is performed on a DI basis through an identity verification agency.

4. Retention and use period of personal information, and destruction

ItemRetention periodBasis
Conversations, corrections, expression assets, List of Facts, learning progress, level, scoresWhile the membership is active. After deletion is requested, erased from the operational database within 72 hours (accounts under a legal hold excepted). Backups and restore copies expire on their own once the backup retention window (23 days or less) passesPIPA §21
Original voice audio0 days (deleted immediately after transcription) / 24 hours for residue in the pipelineOperating policy
Voice corpus (opt-in)Until consent is withdrawn. Destroyed within 30 days after withdrawalConsent form
Identity verification records (time, method, DI)6 months after withdrawalDispute preparedness
Payment and contract records5 yearsElectronic Commerce Act §6
Records of consumer complaints and dispute handling3 yearsElectronic Commerce Act §6
Crisis, safety, and minor-signal event records (pseudonymized)Kept for up to 3 years, then converted into de-identified statistics with the original text destroyed (records on hold for a dispute or lawsuit are excepted until it ends)Safety and litigation preparedness
Permission and access audit logs (pseudonymized, append-only)Kept for 3 to 5 years, then destroyedSecurity and dispute preparedness
Access logs (IP and similar)3 monthsEnforcement Decree of the Protection of Communications Secrets Act
Training data for model improvement (reflecting opt-out)Until the purpose is achieved, after pseudonymizationPIPC guidance

Method of destruction: electronic files are deleted in an unrecoverable manner, and printed materials are shredded or incinerated. The bulk erasure from the operational database within 72 hours of withdrawal runs as an automated batch, and a pseudonymized audit record of each run is kept. Backups and restore copies are not deleted separately; they expire once the backup retention window passes. Accounts under a legal hold (a dispute, an investigation, or a tax obligation) are held back from destruction until that obligation ends.

5. Provision of personal information to third parties

The Company does not provide the personal information of data subjects to third parties. The following cases are exceptions.

  • Where the data subject has consented in advance
  • Where there is a special provision in law
  • Where it is necessary for the urgent life, bodily, or property interests of the data subject or a third party (PIPA §15(1)(5)): where an urgent risk such as self-harm or suicide is detected and the person can be identified, the Company may provide the minimum necessary information to an investigative or rescue agency (112, 119, and so on). The fact and scope of the provision are recorded, and whether notice is given afterwards follows applicable law.

6. Entrustment of personal information processing

Entrusted partyEntrusted work
Supabase Inc.Database, authentication, storage (storage location: Seoul region)
Railway / infrastructure hostingApplication server operation
Identity verification agency (one of PortOne identity, NICE, PASS, and so on)Mobile identity verification and age verification
PortOne (domestic payments) · Paddle.com Market Ltd. (overseas payments)Payment and subscription processing
Expo / FCM and APNsSending push notifications

7. Overseas transfer of personal information

The Company transfers personal information overseas as follows, for AI processing, infrastructure, payment, and similar purposes.

RecipientCountryItems transferredPurpose of useRetention period
Google LLC (Gemini)United StatesEnglish conversation text, List of FactsAI correction and response generationImmediately upon processing (not stored)
OpenAI, L.L.C.United StatesVoice transcript text, conversation text (moderation)STT, content safety checksSame as above
Anthropic, PBCUnited StatesConversation textAI response generation (fallback)Same as above
Supabase Inc.United States entity (data is stored in the Seoul region)All items, including member, conversation, and payment dataData processing and storageThe retention period table in Section 4
Paddle.com Market Ltd.United KingdomPayment and subscription information (email, transaction history)Overseas payment processing and tax (Merchant of Record)5 years (by law)
Expo (Expo Push)United StatesPush tokenPush deliveryThe validity period of the token
PostHog, Inc.United StatesEvent name, non-PII event properties (screen, step, error code and the like), analytics identifier (web: a random value stored in the browser; app: the member identifier), inbound referral code, and access IP. Conversation text, learning text and voice are not transferredAnalysis of service usage and feature reach, error detectionPer the retention setting of the PostHog project
  • Right to refuse the transfer: a data subject may refuse the overseas transfer, but use of core features such as AI conversation and correction may be restricted as a result. Refusal may be exercised by withdrawing membership or through the customer center.
  • The overseas transfer above is based on Article 28-8(1)(3) of the Personal Information Protection Act (entrustment of processing or storage necessary to perform a contract, disclosed in this privacy policy), and the transfer takes place without separate consent by virtue of this disclosure.
  • Separately, to meet app store (Apple) policy, the Company also provides an explicit consent screen for third-party AI data sharing at sign-up.

8. Rights of data subjects and how to exercise them

A data subject may exercise the following rights at any time.

RightHow to exercise itHandling deadline
Request for access and correctionApp settings or emailWithin 10 days
Deletion (withdrawal)Withdrawal within two taps in the app settingsService access is blocked as soon as the request is received, the operational database is erased within 72 hours (accounts under a legal hold excepted), and backups expire once the retention window passes
Individual correction or deletion of a List of Facts entryThe memory management screen in the appImmediately
Request to suspend processingCustomer centerWithout delay
Opt-out of use for model improvementToggle in the app settingsImmediately (excluded from the next training batch)

9. Personal information of children under 14

The Company does not accept membership sign-up by children under 14. If age verification at the sign-up stage confirms that an applicant is under 14, the Company immediately stops the sign-up and destroys the collected information without delay.

10. Measures to secure the safety of personal information

Access privilege management, access control, retention of access records (an append-only audit log), encryption, protection against malicious code, and physical access control. Sensitive data such as crisis event logs is stored separately, access is limited to two people, and access records are kept.

11. Chief Privacy Officer (CPO) and remedies for infringement of rights

Chief Privacy OfficerJEEHO SONG (contact@griing.com)
Grievance handling and inquiriescontact@griing.com · +82-2-581-3001

Other reports and counseling on infringement of personal information: Personal Information Dispute Mediation Committee (1833-6972), Privacy Infringement Report Center (118), Supreme Prosecutors’ Office (1301), National Police Agency (182).

12. Changes to this privacy policy

A change to this policy is announced from 7 days before it takes effect. However, a change unfavorable to data subjects (an expansion of the items collected, the purposes of use, provision to third parties, or overseas transfer, and so on) is announced from 30 days in advance, and consent is obtained again where necessary.