PRIVACY POLICY

KOYLABS Inc. (the “Company”) collects the following minimum personal information and learning data to provide the ‘TOPIK BUDDY’ service.

Article 1 (Personal Information Items Collected and Method of Collection)

  1. [Personal Identification Information]: Unique User ID (id), Nickname (name), Account Email (email).
  2. [Learning Configuration Information]: Target TOPIK level (target_level), Scheduled exam date (exam_date).
  3. [Learning Behavior Data]: Estimated vs. actual time spent per question (solvingTime), User choices (userChoice), and incorrect answer patterns.
  4. [Paid Service Payment]: Card issuer name, card number, and payment approval information. (※ Collected through a payment gateway (PG); the Company does not directly access or store sensitive financial data).
  5. [Automatically Collected Information]: IP address, cookies, service usage records, device information, and access logs.

Article 2 (Purpose of Collection and Use of Personal Information)

The Company utilizes the collected personal information for the following purposes:

  1. Member identification, identity verification, and service operation.
  2. Provision of AI-customized curricula and learning history management.
  3. Provision of educational content and question banks, and responding to customer inquiries.
  4. Provision of event and marketing information (limited to those who have consented).
  5. Enforcement of measures against violations of laws or the Terms of Service.
  6. Service improvement, statistical analysis, and provision of user-customized features.

Article 3 (Retention and Use Period of Personal Information)

In principle, personal information is destroyed without delay upon the Member's withdrawal from the service. However, certain information required by law will be retained for the following periods:

  • Records on contracts or withdrawal of subscription: 5 years (Act on the Consumer Protection in Electronic Commerce).
  • Records on payment and supply of goods: 5 years (Act on the Consumer Protection in Electronic Commerce).
  • Records on consumer complaints or dispute resolution: 3 years (Act on the Consumer Protection in Electronic Commerce).
  • Records on website access (Log files): 3 months (Protection of Communications Secrets Act).

Article 4 (Anonymization and Utilization of Learning Data for AI Optimization)

① The Company may utilize learning behavior data (time spent, incorrect answer types, learning trends, etc.) generated during the service for statistical analysis and the enhancement of TOPIK BUDDY’s Computerized Adaptive Testing (CAT) recommendation algorithms.

② In this process, the Company strictly removes all personally identifiable information (e.g., nicknames, emails) and performs complete “Anonymization,” ensuring that specific individuals cannot be identified without additional information.

③ Anonymized data does not constitute “personal information” under the Personal Information Protection Act and is therefore excluded from destruction obligations. Such data may be retained permanently, provided it is handled through lawful and secure methods. The Company shall not attempt to re-identify anonymized data under any circumstances.

Article 5 (Provision and Entrustment of Personal Information to Third Parties)

① In principle, the Company does not provide user information to third parties unless prior consent is obtained or it is required by law (e.g., warrant submission to investigative agencies).

② For seamless service provision, the Company entrusts personal information processing to the following external providers, managed securely through contracts:

  • Amazon Web Services (AWS): Data storage and infrastructure operations.
  • Sentry: Server error monitoring and management.
  • Google Analytics: Service usage statistics and management.
  • PostgreSQL (DB): Database construction and storage.
  • Firebase Admin (FCM): Sending push notifications.

Article 6 (Procedure and Method of Destruction)

When the purpose of collection is achieved or the retention period expires, the information is destroyed immediately.

  • Electronic files: Deleted using technical methods that make recovery impossible.
  • Hard copies: Shredded using a paper shredder or incinerated.

Article 7 (Rights of Users and How to Exercise Them)

Users may exercise the following rights regarding their personal information at any time:

  1. Request to access, correct, or delete personal information.
  2. Request suspension of processing.
  3. Withdrawal of consent and membership termination. Requests can be made through the My Page settings within the app or via email to the Customer Center (support@koy.company).
  4. Marketing Consent and Withdrawal: Users may consent to receive marketing information (events, promotions, etc.). Consent grants access to customized events and useful study tips. Refusal to consent does not restrict the use of basic service features. Consent can be updated at any time in My Page settings.

Article 8 (Installation and Refusal of Automatic Collection Devices)

The Company provides customized services through “Cookies.” Users may refuse to store cookies via their browser or device settings. (※ Blocking cookies may restrict certain features, such as “Stay Logged In” or personalized question recommendations).

Article 9 (International Transfer of Information)

As TOPIK BUDDY operates globally, collected information may be transferred to and stored in Amazon Web Services (AWS) overseas data centers (Destination: Osaka, Japan / AWS Region: ap-northeast-3). The Company ensures through contracts that information is handled with a level of security equivalent to domestic standards.

Article 10 (Privacy Officers and Contact Information)

The Company has designated the following officers to oversee personal information protection:

Article 11 (Amendments to the Privacy Policy)

This policy is subject to change based on relevant laws or internal policy updates. Any changes will be announced in advance through the service’s initial screen or via email.

Effective Date: April 27, 2026