# Neona Terms of Service

## 1. Service Overview

"Neona" is a conversational AI agent platform that allows users to select agents with various personas and engage in voice conversations. Neona is a personalized, interactive media service that lets you have voice conversations with AI characters represented through animation. Free credits are provided by default, and credits are deducted based on conversation time. You may purchase additional credits to continue conversations.

By using Neona, you are deemed to have agreed to these Terms. If you do not agree to these Terms, please do not use the service. Matters concerning the collection and use of personal information are set forth separately in the Privacy Policy, which you should read before using the service.

**Company Information:** The Neona service is provided by our team (hereinafter "the Company," "we," or "us"). We may revise or update these Terms from time to time during the operation of the service. If there are material changes to the Terms, we will notify you in advance through in-app notices, email, or similar means. The most current Terms will always be posted in the app or on the website, and you can verify the most recent revision date via the "Last Updated" date at the top of the Terms. If you continue to use the service after the revised Terms take effect, you will be deemed to have agreed to the changes. If you do not agree to the revised Terms, please discontinue use of the service, and you may request account deletion if necessary.

## 2. Eligibility (Age and Requirements)

- **Minimum Age:** The minimum age to use Neona is 14 years old. By using the service, you represent and warrant that you are at least 14 years old. Children under 14 are not permitted to use the service. If you are a minor under the laws of your jurisdiction of residence (e.g., under 18 in most cases), we recommend that you use the service with the consent and under the supervision of a parent or legal guardian. Parents and legal guardians are encouraged to review the Terms and policies together with the minor regarding their use of Neona.
- **Other Eligibility Requirements:** You must have the authority to agree to be legally bound by these Terms. If you reside in a country or region where use of certain services is prohibited by law, or if you have previously been banned from using the service, you may not use Neona. The service is provided for personal, non-commercial use only; commercial use or transfer of accounts to third parties is not permitted.

## 3. Account Registration and Security

To use the main features of Neona, you may need to create a user account. In connection with account registration and management, you agree to and must comply with the following:

- **Accurate Information:** When registering, you must provide accurate and up-to-date information. For example, please enter a valid email address and username correctly. You may not use another person's identity or select a username that is inappropriate or offensive to others. If your membership information (such as email) changes, please update it as soon as possible.
- **Account Security:** You are responsible for maintaining the confidentiality of your account (ID) and password. Do not share your password with others. The Company is not responsible for unauthorized access or misuse of your account resulting from your own negligence, so please set and manage a secure password.
- **Responsibility for Account Activity:** You are responsible for all activity that occurs through your account. You may not permit third parties to use your account, nor transfer or lend your account. If you become aware of any unauthorized use of your account or security breach, please notify the Company immediately (e.g., suspicious logins, stolen password). You may be held liable for damages resulting from failure to notify the Company promptly.
- **One Account Per Person:** In general, creating multiple accounts per person is not encouraged, and to prevent abuse of the service, only one account per person may be permitted. If multiple accounts are unavoidably created, these Terms apply equally to each account.

The Company reserves the right to take action such as restricting, suspending, or deleting accounts that violate these Terms or applicable laws, when deemed necessary. For details, please refer to the "Termination of Service" section.

## 4. Handling of Personal Information

Neona values users' personal information, and matters concerning the processing of personal information are governed by the Privacy Policy. These Terms provide a brief overview of personal information handling; for details, please refer to the separate Privacy Policy document.

- **Collection and Use of Personal Information:** When you use Neona, the Company collects and uses the minimum personal information necessary to provide the service. For example, we collect your email address and password when you sign up, and we temporarily process your voice data to provide voice conversation features. Collected personal information is used only within the scope of service operation, feature improvement, and customer support.
- **Provision and Sharing with Third Parties:** As a general principle, the Company does not provide or share your personal information with third parties without your prior consent. However, in exceptional cases—such as when requested through legitimate legal procedures (e.g., warrants from investigative agencies), or when necessary for entrustment of service operations (e.g., data storage via server hosting providers)—information may be transmitted to the minimum extent in accordance with applicable laws.
- **Cookies and Tracking:** Neona may use cookies or similar technologies when necessary for user convenience. These are used solely for purposes such as maintaining login status or saving user preferences, and are not used for external advertising tracking.
- **Retention and Destruction of Personal Information:** Personal information is destroyed without delay once the purpose of collection and use has been achieved. However, information that must be retained for a certain period under applicable laws will be stored separately for that period and then destroyed. For example, records related to e-commerce may be retained for up to five years.
- **User Rights:** You may exercise rights under applicable laws at any time, including the right to access, correct, delete, or request suspension of processing of your personal information. These rights can be exercised through in-service features or customer support.

## 5. Service Changes and Termination

If there are changes to service content, the Company will notify users at least 7 days before the changes take effect through in-service notices, email, app push notifications, and similar means.
In the case of service termination, users will be notified at least 30 days in advance through notices, individual notifications, and pop-up windows upon service access. Upon service termination, unused credits may be used until the termination date, and for unused credits above a certain amount, cash refunds or conversion options to other services may be provided.
After service termination, personal information will be destroyed immediately after the mandatory retention period required by law has passed, and the destruction method and schedule will be announced. Where necessary, information may be anonymized and used solely for statistical purposes.

## 6. Intellectual Property

### a. Ownership of Rights

- All intellectual property rights, including copyright (encompassing moral rights and all economic rights such as reproduction, distribution, public transmission, and creation of derivative works, as well as related neighboring rights) in the content provided by the Company, belong to the Company. All content provided by the Company, including voice and video content, may be changed or discontinued at any time at the Company's discretion.
- Ownership of content that users create or post while using the service (including characters, regardless of form; hereinafter "User Content") belongs to the user. When a user posts User Content on the service or makes it available to other users, the user grants the Company a worldwide, royalty-free, non-exclusive license to store, reproduce, modify, translate, display, distribute, and publicly transmit the User Content, and to create and use derivative works to the extent necessary for such purposes, for the purposes of operating and displaying the service, translating and localizing User Content, promoting and marketing the service, and improving the service. If the Company transfers its business relating to the service due to a merger, division, business transfer, or a comparable event, the above license may be transferred to the party succeeding to that business. The Company may sublicense the above rights, to the extent necessary to achieve the above purposes, to parties entrusted with tasks such as translation and advertising; provided that, in such cases, the Company takes necessary measures to ensure that such entrusted parties do not use User Content beyond the scope of the entrusted tasks. User Content that a user keeps private is used only to the extent necessary to provide the service. The user agrees not to exercise moral rights with respect to the above uses.
- Ownership of output generated by a user's conversations with characters created by the Company or by other users (hereinafter "Conversation Output") belongs to the user; provided that rights to the character itself are not included. Conversation Output is not disclosed to other users, including the user who created the character, and the Company uses it only to the extent necessary to provide the service. The license in the preceding paragraph does not apply to Conversation Output.

### b. Translation of User-Created Characters and Multilingual Availability

- The Company may translate or adapt characters that users have publicly shared on the service (including the content that constitutes the character, such as the character's name, description, prompts, greeting, opening scenes, and hashtags) into other languages, and publish them in service areas directed at users of those languages (such as discovery, recommendations, and search). Such translation and publication take place only within the scope of providing the service.
- Whether a character may be published in translation is managed directly by the user through the per-character "Allow Translation" setting. The default setting value and how to change it are explained in the character creation and editing screens within the service.
- Translated versions credit the original creator and are managed in linkage with the original character. Usage generated on translated versions, such as conversations, is counted toward the original creator's activity records, and may be included in the calculation of any creator reward program operated by the Company.
- In the course of translation, some expressions may be partially modified or localized to reflect linguistic and cultural differences. The Company makes reasonable efforts to ensure that the intent and settings of the original character are preserved.
- If a user turns off Allow Translation, no new translated versions will be created or published thereafter. Takedown of already-published translated versions may be requested through the in-app support channel (Contact Us), and the Company will take action without undue delay absent special circumstances.
- Ownership of user-generated content, including translated versions, is governed by subsection a of this Section.

## 7. Disclaimer and Warranty Disclaimer

### 7.1 Disclaimer

- The Company shall not be liable for service interruptions or delays due to causes beyond its control, such as server issues, cyber terrorism, or acts of God, and these shall not be deemed violations of the Terms.
- In the event of service issues, the Company will notify users via website notices, system notifications, or registered contact information.
- If a user posts illegal content or infringes on the rights of others, the user shall bear full responsibility for any resulting damages.
- If a third party makes a claim against the Company due to a user's actions, the Company may, after compensating the third party, claim the full amount from the user.
- The Company shall not be liable for damages caused by third parties or force majeure events such as hacking, viruses, war, or court orders.
- When the Company discovers illegal activity, it may take action such as suspending or deleting accounts or reporting to investigative authorities without notice, and assets within the account will not be returned.

### 7.2 Warranty Disclaimer

- Neona is provided "As Is" and "As Available," and does not guarantee complete performance or accuracy.
- Because AI character responses are based on algorithms, they may contain inaccurate or inappropriate content and should not be considered professional advice.
- The Company makes no warranties whatsoever that the service will be provided without interruption, that all bugs will be resolved, or regarding legally guaranteed merchantability and fitness for purpose.
- Users use the service at their own judgment and responsibility, and all responsibility for the results lies with the user.

## 8. Limitation of Liability and Indemnification

### 8.1 Limitation of Liability

- To the maximum extent permitted by law, the Company and its affiliates shall not be liable for damages related to use of the service.
- Liability for indirect, incidental, special, consequential damages, loss of opportunity, loss of data, or damage to reputation is excluded.
- Even if liability is recognized, the Company's total liability for damages shall not exceed the amount received from the user during the most recent 12 months. If there has been no paid payment, the Company's liability shall be zero.
- Exceptions apply to willful misconduct, gross negligence, and harm to life or body where legal limitation is not possible.

### 8.2 Indemnification

- If a user violates the Terms or posts illegal content and infringes on the rights of third parties, the user shall bear full responsibility for all resulting damages and legal costs.
- When damages occur, the Company will attempt resolution through prior consultation and may exercise legal rights of recourse if necessary.

## 9. Dispute Resolution

- The Company shall not be liable for direct, indirect, incidental, special, or consequential damages, including damages arising from improper use or failure to update information.

For disputes related to these Terms, the Company may cooperate with laws and judicial authorities to protect its rights.
The governing law for these Terms is the laws of the Republic of Korea, and related laws (Electronic Commerce Act, Information and Communications Network Act, Copyright Act, etc.) shall be observed.

## 10. Amendment of Terms and Other Matters

### 10.1 Amendment of Terms

- When amending the Terms, the Company will notify users via in-site notices, pop-up messages, email, text messages, and similar means.
- In the case of postal delivery, notice is deemed to have been received 5 days after dispatch.
- If these Terms conflict with specific provisions, the specific conditions shall prevail. Even if part of the Terms becomes invalid, the remaining provisions shall remain in effect.

### 10.2 Other

- Issues related to the Terms shall be resolved through negotiation between the Company and users, and if users violate the Terms, the Company may take necessary measures such as account suspension.

## 11. Contact Information

For inquiries regarding the Terms of Service, please contact us at the following:

- **Company Name:** Neosapience, Inc.
- **Email:** help@neonachat.io
- **Phone:** +82-70-4112-4548
- **Address:** 5F, Daehwa Building, 20 Yeongdong-daero 96-gil, Gangnam-gu, Seoul (Samseong-dong), Republic of Korea

These Terms of Service take effect from August 21, 2026. Previous versions of the Terms of Service can be viewed below.

- July 17, 2026 – August 20, 2026 ([link](https://d1ie8xu1e1jyyf.cloudfront.net/terms/3-en.md))
- January 22, 2026 – July 16, 2026 ([link](https://d1ie8xu1e1jyyf.cloudfront.net/images/202601/08f374cc-1915-4f9f-831a-227538698884.md))
- August 14, 2025 – January 21, 2026 ([link](https://d1ie8xu1e1jyyf.cloudfront.net/images/202601/dfad9848-5929-4edb-bedc-52b9c8f288f9.md))

---

# Privacy Policy

Neosapience, Inc. (hereinafter "the Company") establishes and discloses the following Privacy Policy pursuant to Article 30 of the Personal Information Protection Act (PIPA) of Korea, in order to inform data subjects of the procedures and standards under which their personal information is processed, and to handle grievances related to the Neona AI service promptly and smoothly.

### 1. Purposes of Processing Personal Information

The Company processes personal information for the following purposes and does not use it for any purpose other than those stated below. If the purpose of use changes, the Company will take necessary measures, such as obtaining separate consent, in accordance with Article 18 of the Personal Information Protection Act (PIPA) of Korea.

1) **Membership Registration and Management**

Personal information is processed for the purposes of confirming the intent to register as a member, identifying users in connection with the provision of membership-based services, restricting registration by children under 14 years of age, providing simplified (social) login, maintaining and managing membership status, and delivering various notices and notifications.

2) **Service Provision**

Personal information is processed for the purposes of providing AI character conversations and voice/video content services, managing usage records, processing payments and settlement, informing users of new features and service updates, and providing events/promotions.

3) **Service Analysis and Improvement**

Personal information is processed for the purposes of analyzing service usage, performing demographic analysis, and improving the service.

4) **Complaint Handling**

Personal information is processed for the purposes of verifying the identity of the complainant, confirming the details of the complaint, making contact and giving notice for fact-finding, and communicating the results of the handling.

### 2. Personal Information Items Processed and Retention Periods

The Company collects and uses personal information of data subjects on the following legal bases.

1) **Personal information items processed without the consent of the data subject**

The following personal information items are processed without the consent of the data subject.

| Legal Basis | Category | Purpose of Processing | Items Processed | Retention Period |
| :-: | :-: | :-: | :-: | :-: |
| Article 15(1)(4) of the Personal Information Protection Act (PIPA) of Korea (execution and performance of a contract) | Membership registration (social login) | Membership registration and management | [Required] UID, email address (Google account or Apple account) | Until membership withdrawal |
| Article 15(1)(4) of the Personal Information Protection Act (PIPA) of Korea (execution and performance of a contract) | Contact Us (complaint handling) | Handling of member inquiries and support | (Required) UID, email address | 3 years (Article 6 of the Act on Consumer Protection in Electronic Commerce) |
| Article 15(1)(4) of the Personal Information Protection Act (PIPA) of Korea (execution and performance of a contract) | Payment processing and settlement for credit purchases | Service provision | [Web payments] (credit/debit card) card number (16 digits), (KakaoPay/Toss Pay/PAYCO) payment completion information; [App payments] in-app payment completion information | 5 years (Article 6 of the Act on Consumer Protection in Electronic Commerce) |

2) **Personal information items processed with the consent of the data subject**

The following personal information items are processed with the consent of the data subject.

| Legal Basis | Category | Purpose of Processing | Items Processed | Retention Period |
| :-: | :-: | :-: | :-: | :-: |
| Article 15(1)(1) of the Personal Information Protection Act (PIPA) of Korea (consent of the data subject) | Events/promotions | Service provision | (Required) Email address | Until membership withdrawal or withdrawal of consent |

3) **Retention periods required by statute**

Even after membership withdrawal or loss of membership status, the Company retains personal information for the statutory retention periods required by applicable laws in the following cases.

| Legal Basis | Category | Retention Period |
| :-: | :-: | :-: |
| Article 6 of the Act on Consumer Protection in Electronic Commerce and Article 6 of its Enforcement Decree | Records on display and advertising | 6 months |
| Article 6 of the Act on Consumer Protection in Electronic Commerce and Article 6 of its Enforcement Decree | Records on contracts or withdrawal of offers | 5 years |
| Article 6 of the Act on Consumer Protection in Electronic Commerce and Article 6 of its Enforcement Decree | Records on payment and the supply of goods, etc. | 5 years |
| Article 6 of the Act on Consumer Protection in Electronic Commerce and Article 6 of its Enforcement Decree | Records on consumer complaints or dispute resolution | 3 years |
| Article 85-3 of the Framework Act on National Taxes | Books and supporting documents relating to all transactions prescribed by tax law | 5 years |
| Article 15-2 of the Protection of Communications Secrets Act and Article 41 of its Enforcement Decree | Website visit records (log records, access IP addresses, etc.) | 3 months |

4) **Notice regarding facial images and biometric information**

The Company provides features that generate AI-based content using images uploaded by users (e.g., photos containing faces). Accordingly, the Company makes the following clear disclosures.

- The Company does not collect or analyze facial recognition information or biometric information (hereinafter "face data").
- Images uploaded by users are processed as ordinary image files and are not used for any purpose other than providing the service, such as content generation, quality improvement, and error response.
- The Company does not identify individuals through such images, nor does it perform facial recognition, tracking, or similar functions.
- Facial images and the resulting content are not provided to third parties and are not used for any external analysis purposes.
- Information related to facial images is not stored indefinitely and is retained only for the minimum period necessary to provide the service.

### 3. Processing of Personal Information of Children Under 14

① The Company restricts membership registration for customers under 14 years of age, for whom the consent of a legal representative would be required.

### 4. Rights and Obligations of Users and Legal Representatives, and How to Exercise Them

① Users and their legal representatives may at any time request the Company to allow access to, transmit, correct, or delete their personal information, to suspend its processing, or to withdraw consent (hereinafter "exercise of rights").

② Rights may be exercised against the Company in writing or by telephone, email, fax, the internet, or similar means, and the Company will take action without delay.

- Data subjects may at any time directly view, correct, delete, suspend the processing of, or withdraw consent regarding their personal information in "My Info > Member Information" within the service, or request access through "Contact Us."

③ Rights may also be exercised through an agent, such as the user's legal representative or an authorized delegate. In such cases, a power of attorney in the attached form must be submitted.

④ A user's right to request access to or suspension of processing of personal information may be restricted.

⑤ Deletion of personal information may not be requested where that personal information is specified as subject to collection under other laws.

⑥ The Company verifies whether the person exercising rights is the data subject or a legitimate agent.

⑦ Users may exercise their rights through the department below. The Company will respond within 10 days from the date it receives a request to exercise rights.

▶ Department for Receiving and Handling Requests to Exercise Personal Information Rights

- Department: Security Team
- Contact: +82-2-2155-4585, privacy@neosapience.com

### 5. Outsourcing of Personal Information Processing

① For the smooth handling of personal information tasks, the Company outsources personal information processing as follows.

| Outsourcee (Processor) | Outsourced Task |
| :-: | :-: |
| OpenRouter, Inc. | AI conversation generation and content translation (LLM) |
| Langfuse | LLM logging and observability |
| Typecast (Neosapience) | Speech synthesis (TTS) |
| PixAI | Character image generation |
| Hedra | Video generation |
| LiveKit, Inc. | Real-time voice/video chat |
| Amazon Web Services, Inc. | Cloud infrastructure and media (S3) storage |
| MongoDB | Data storage |
| Google LLC (Firebase) | Authentication, push notifications (FCM), and social login |
| Mixpanel, Inc. | Service usage behavior analysis |
| Functional Software, Inc. (Sentry) | Error monitoring |
| Toss Payments Co., Ltd. | Card payment gateway (web; KRW, Korea) |
| Apple Inc. | iOS in-app purchases and subscription management |
| Google LLC (Google Play) | Android in-app purchases and subscription management |
| AppsFlyer Ltd. | Install attribution and deep linking |
| AB180 Inc. (Airbridge) | Attribution and deep linking |
| Slack Technologies (Salesforce) | Internal operational notifications |

② When concluding outsourcing contracts, the Company specifies in the contract or other documents matters concerning the prohibition of processing personal information for purposes other than performing the outsourced task, technical and administrative protection measures, restrictions on sub-outsourcing, management and supervision of the processor, and liability including damages, and supervises whether the processor handles personal information safely.

③ Where a processor sub-outsources the Company's personal information processing tasks, it obtains the Company's consent, and the sub-processor and the details of the sub-outsourced tasks are disclosed through this Privacy Policy.

④ If the details of the outsourced tasks or the processor changes, the Company will disclose this without delay through this Privacy Policy.

⑤ Cases where personal information processing is outsourced overseas are described in "8. Overseas Collection and Transfer of Personal Information."

### 6. Destruction of Personal Information

In principle, the Company destroys personal information without delay once the purpose of its processing has been achieved. The procedures, timing, and methods of destruction are as follows.

① The Company destroys personal information without delay when it becomes unnecessary, such as upon the expiration of the retention period, achievement of the purpose of processing, discontinuation of the relevant service, or closure of the business.

② Where personal information must continue to be preserved under other laws despite the expiration of the retention period consented to by the user or the achievement of the purpose of processing, the personal information is moved to a separate database (DB) or preserved in a different storage location.

※ The items of personal information preserved under other laws, the legal basis for preservation, and the preservation periods can be found in "2. Personal Information Items Processed and Retention Periods."

③ The procedures and methods for destroying personal information are as follows.

a. Destruction procedure: The Company selects the personal information for which grounds for destruction have arisen, and destroys the personal information with the approval of the Company's Personal Information Protection Officer.

b. Destruction method: The Company destroys personal information recorded and stored in electronic file format so that the records cannot be reproduced, and destroys personal information recorded and stored on paper documents by shredding or incineration.

### 7. Installation, Operation, and Refusal of Automatic Personal Information Collection Devices

① The Company collects and uses cookies, IP addresses, and access device information in order to provide personalized services.

a. A cookie is a very small text file sent by a web server to the user's browser and stored on the user's computer hard drive. When the user visits the website again, the server reads the contents of the cookie stored on the user's PC to maintain the service settings configured by the user.

b. An IP address is online address information assigned by an internet network provider to devices, such as PCs, that connect to the internet.

c. Access device information is information that can be identified through the software used to operate the device.

② The Company uses cookies for the purpose of analyzing site visits and usage patterns, purchased items, items of interest, and the like, in order to provide differentiated information tailored to the user's tastes and interests.

③ Users have a choice regarding cookies. By configuring options in the web browser, users may allow all cookies, require confirmation each time a cookie is stored, or refuse the storage of all cookies. However, refusing the storage of cookies may cause difficulties in using some services.

a. How to block cookie collection in web browsers

| Web Browser | How to Block Cookie Collection |
| :-: | :-: |
| Chrome | Settings > Privacy and security > Delete browsing data |
| Edge | Settings > Cookies and site permissions > Manage and delete cookies and site data |
| Safari | Settings > Privacy > Cookies and website data |

b. How to block cookie collection in mobile browsers

| Web Browser | How to Block Cookie Collection |
| :-: | :-: |
| Chrome | Settings > Privacy and security > Delete browsing data |
| Edge | Settings > Advanced > Block all cookies |
| Safari | Settings > Browsing history > Clear browsing history |

### 8. Overseas Collection and Transfer of Personal Information

The Company transfers personal information collected from service users overseas as described below; if you refuse the overseas transfer, use of the service is not possible.

Legal basis: Article 28-8(1)(3)(a) of the Personal Information Protection Act (PIPA) of Korea (overseas transfer of personal information)

| Personal Information Items Transferred | Destination Country | Timing and Method of Transfer | Recipient | Purpose of Use | Retention and Use Period |
| :-: | :-: | :-: | :-: | :-: | :-: |
| Chat conversation content (entire messages) | United States | Transferred on an ongoing basis over an encrypted network during service use | OpenRouter, Inc. | AI conversation generation | Until membership withdrawal or withdrawal of consent |
| Chat messages, traces, session IDs | Germany (EU) | Transferred on an ongoing basis over an encrypted network during service use | Langfuse | LLM logging and observability | Until membership withdrawal or withdrawal of consent |
| Image generation prompts | Japan | Transferred on an ongoing basis over an encrypted network during service use | PixAI | Character image generation | Until membership withdrawal or withdrawal of consent |
| AI-generated output (image and voice data) | United States | Transferred on an ongoing basis over an encrypted network during service use | Hedra | Video generation | Until membership withdrawal or withdrawal of consent |
| Voice/video streams | United States | Transferred on an ongoing basis over an encrypted network during service use | LiveKit, Inc. | Real-time voice/video chat | Until membership withdrawal or withdrawal of consent |
| All personal information collected during service use, generated media | United States | Transferred on an ongoing basis over an encrypted network during service use | Amazon Web Services, Inc. | Data storage and cloud infrastructure | Until membership withdrawal or withdrawal of consent |
| All member information, conversations, payment records, etc. | United States | Transferred on an ongoing basis over an encrypted network during service use | MongoDB | Data storage | Until membership withdrawal or withdrawal of consent |
| Email, social identifiers, device identifiers, push tokens | United States | Transferred on an ongoing basis over an encrypted network during service use | Google LLC (Firebase) | Authentication, push notifications, statistics | Until membership withdrawal or withdrawal of consent |
| User ID, access logs, usage events, sessions | United States | Transferred on an ongoing basis over an encrypted network during service use | Mixpanel, Inc. | Usage behavior analysis | Until membership withdrawal or withdrawal of consent |
| IP address, device/OS, logs, (depending on settings) user identification information | United States | Transferred on an ongoing basis over an encrypted network during service use | Functional Software, Inc. (Sentry) | Error monitoring | Until membership withdrawal or withdrawal of consent |
| Apple ID, purchase history, device identifiers | United States | Transferred on an ongoing basis over an encrypted network during service use | Apple Inc. | iOS in-app purchases and subscriptions | Until membership withdrawal or withdrawal of consent |
| Google account, purchase history, device identifiers | United States | Transferred on an ongoing basis over an encrypted network during service use | Google LLC (Google Play) | Android in-app purchases and subscriptions | Until membership withdrawal or withdrawal of consent |
| Advertising identifiers, app events | Israel/United States | Transferred on an ongoing basis over an encrypted network during service use | AppsFlyer Ltd. | Install attribution | Until membership withdrawal or withdrawal of consent |

### 9. Personal Information Protection Officer and Grievance Handling Department

① The Company designates a Personal Information Protection Officer as follows, who bears overall responsibility for personal information processing and for handling user complaints and providing remedies related to personal information processing.

▶ Personal Information Protection Officer

- Name: Junchul Cho
- Title: CTO/CISO (concurrent)
- Contact: privacy@neosapience.com

▶ Personal Information Protection Department

- Department: Security Team
- Contact: privacy@neosapience.com

② Users may direct all inquiries, complaints, and requests for remedies related to personal information protection arising from the use of the Company's services (or business) to the Personal Information Protection Officer and the department in charge. The Company will respond to and handle user inquiries without delay.

### 10. Remedies for Infringement of Users' Rights and Interests

Users who wish to obtain relief from personal information infringement, such as dispute resolution or consultation, may file reports or seek consultation with the following agencies.

1. **Personal Information Dispute Mediation Committee:** 1833-6972 (no area code) (www.kopico.go.kr)
2. **Personal Information Infringement Report Center:** 118 (no area code) (privacy.kisa.or.kr)
3. **Korean National Police Agency:** 182 (no area code) (ecrm.police.go.kr)
4. **Supreme Prosecutors' Office Cyber Crime Investigation Unit:** 1301 (no area code) (www.spo.go.kr)

### 11. Measures to Ensure the Security of Personal Information

The Company takes the following measures to ensure the security of personal information.

1. **Administrative Measures:** Establishment and implementation of an internal management plan, regular employee training, operation of a dedicated organization
2. **Technical Measures:** Management of access rights to personal information processing systems, installation of access control systems and other related protective measures, network isolation measures, encryption of personal information, storage and inspection of access records, installation, operation, and updating of security programs, and inspection and remediation of vulnerabilities in personal information processing systems
3. **Physical Measures:** Access control to computer rooms, data storage rooms, and similar facilities; storage of important documents in secure locations with locking devices; safety measures against disasters and calamities

### 12. Changes to the Privacy Policy

If there are additions, deletions, or modifications to this Privacy Policy, prior notice will be given through "Announcements" at least 7 days before the revision.

However, where there are significant changes to user rights, such as changes to the items of personal information collected or the purposes of use, notice will be given at least 30 days in advance, and user consent may be obtained again if necessary.

This Privacy Policy takes effect from July 17, 2026. Previous versions of the Privacy Policy can be viewed below.

- January 22, 2026 – July 16, 2026 ([link](https://d1ie8xu1e1jyyf.cloudfront.net/images/202601/08f374cc-1915-4f9f-831a-227538698884.md))
- August 14, 2025 – January 21, 2026 ([link](https://d1ie8xu1e1jyyf.cloudfront.net/images/202601/dfad9848-5929-4edb-bedc-52b9c8f288f9.md))

**[Entity Collecting and Using Personal Information]**

- Neosapience, Inc. (Business Registration Number: 883-86-00767)