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Privacy Policy

손손 (the "Company") establishes and discloses this Privacy Policy under Article 30 of Korea's Personal Information Protection Act (개인정보 보호법) in order to protect the personal information of users of the PenPick service and to handle related complaints promptly.

This is an English translation provided for convenience. If it differs from the Korean original, the Korean original prevails. Read the Korean original

Effective  October 15, 2026·Privacy officer  privacy@penpick.app
At a glance
The only personal information processed is the email address, name and profile picture received from the external account (currently Google) and the works created in the Service. No separate member information is requested.
The Service is currently in its beta period and takes no payments. When paid payments begin, the payment agent that processes them and the personal information it processes will be added to this Policy first.
Data is stored in Google Cloud's Taiwan (asia-east1) region. Storage, processing or provision overseas is described in Article 6.
When a user deletes their account, the data is irreversibly deleted after a 7-day grace period; only the payment records that the law requires to be kept are retained.

This summary is provided for readability only; the full text below governs.

Contents
01Article 1 (Personal Information Processed and How It Is Collected)02Article 2 (Purposes of Processing Personal Information)03Article 3 (Retention and Use Periods of Personal Information)04Article 4 (Provision of Personal Information to Third Parties)05Article 5 (Outsourcing of Personal Information Processing)06Article 6 (Transfer of Personal Information Overseas)07Article 7 (Destruction of Personal Information)08Article 8 (Rights and Obligations of Data Subjects and How to Exercise Them)09Article 9 (Children Under 14)10Article 10 (Installation, Operation and Refusal of Devices That Automatically Collect Personal Information)11Article 11 (Measures to Ensure the Security of Personal Information)12Article 12 (Chief Privacy Officer)13Article 13 (Remedies for Infringement of Rights)14Article 14 (Changes to This Policy)
01

Article 1 (Personal Information Processed and How It Is Collected)

The Company processes only the minimum personal information needed to provide the Service. Member information is received from the provider of the external account the user signs in with; other information is entered by the user or generated automatically in the course of using the Service.

Category
Items
Collection method
Member information (required)
The external account's email address, name and profile picture, and the unique account identifier assigned by the provider
Received from the provider when the user signs in with an external account (currently Google)
User settings
Language, time zone and market (country) settings
Estimated from browser information, then changeable by the user
Works and content
Work titles, notes (title, description, body), lines, chapters
Entered or created by the user in the Service
Subscription information
The plan and subscription status (start date and time, period of use, whether cancelled)
Generated by the Service when a plan is started or cancelled
AI connection
The name and registration information (redirect address) of connected apps, the date and time of connection and of last use, and the names the user gives personal keys. Access tokens and personal keys are kept only as transformed values (hashes), not in their original form.
Generated when the user allows an AI connection or creates a personal key
Usage records
Access dates and times, IP address, browser and device information, error logs
Generated automatically when the Service is used
02

Article 2 (Purposes of Processing Personal Information)

The Company processes personal information only for the following purposes. If a purpose changes, the Company takes the necessary measures, such as obtaining separate consent under Article 18 of the Personal Information Protection Act.

  • —Identifying members, signing in, managing accounts, and preventing sign-ups by children under 14
  • —Providing the Service, including storing, synchronizing and displaying works and content
  • —Giving outside AI services that the user connects access to the canvas (AI connection)
  • —Applying and communicating the usage limit of each plan (the number of works), and preventing misuse
  • —Processing the start and cancellation of plans, and sending notices about plans (including notices of the official launch and of the end of the free period)
  • —(Optional) Sending an email about the official launch — only if the user has agreed, and the consent can be withdrawn in settings at any time
  • —Responding to inquiries, making announcements, and giving notice of changes to the terms and policies
  • —Ensuring the stability of the Service, responding to outages, and carrying out security checks
  • —Analyzing usage statistics in a form that cannot identify individuals, and improving the Service
03

Article 3 (Retention and Use Periods of Personal Information)

The Company destroys personal information without delay once the purpose of its collection and use has been achieved. Member information and works are retained until account deletion (when the 7-day grace period in Article 7 has passed).

However, the following information is kept for the periods below under the relevant laws and then destroyed.

Retained item
Period
Legal basis
Records of contracts, withdrawals of offers and the like
5 years
Act on the Consumer Protection in Electronic Commerce (전자상거래 등에서의 소비자보호에 관한 법률)
Records of payments and of the supply of goods and the like
5 years
Act on the Consumer Protection in Electronic Commerce
Records of consumer complaints and dispute handling
3 years
Act on the Consumer Protection in Electronic Commerce
Access records (sign-in dates and times, IP addresses)
3 months
Protection of Communications Secrets Act (통신비밀보호법)
Pseudonymized email addresses of deleted accounts (hash values, to prevent abuse through re-registration)
1 year after the deletion is processed (when the grace period in Article 7 has passed), then deleted automatically
Company internal policy
04

Article 4 (Provision of Personal Information to Third Parties)

The Company does not provide users' personal information to third parties beyond the scope of the purposes in Article 2, except in the following cases.

Recipient
Purpose and items provided
Retention and use period
Outside AI services the user connects (for example Claude or ChatGPT)
Reading and writing works at the user's request — The content of the requested works, notes, events and chapters (After the user allows an AI connection or creates a personal key, when that AI reads or writes the canvas at the user's request)
According to that service's policy
  • —Outside AI services the user connects (for example Claude or ChatGPT): As a service the user chose, it processes the information under its own privacy policy. The connection can be removed at any time in Settings › Connections, and access stops immediately when it is removed.
  • —Other cases where the user has given separate consent
  • —Where the law has a special provision, or where an investigative agency or court requests it in accordance with the procedures and methods set by law
05

Article 5 (Outsourcing of Personal Information Processing)

The Company outsources the processing of personal information as follows in order to provide the Service. Under Article 26 of the Personal Information Protection Act, the outsourcing contracts set out, among other things, the prohibition on processing for purposes other than those outsourced, measures to ensure security, restrictions on re-outsourcing, and management and supervision. If the Company changes or adds a processor, it discloses this in this Policy under Article 14.

Processor
Outsourced work
Items outsourced
Google LLC (Firebase, Google Cloud)
Server operation, database and file storage, login authentication
All items in Article 1
Resend, Inc.
Sending payment and subscription emails
Email address and the content of the notice (plan name and price, billing period, payment and refund amounts)
Google LLC (Google Analytics)
Analyzing service usage statistics
Pages visited, feature-use events, browser and device information, internal service identifiers (excluding email and the content of works)
06

Article 6 (Transfer of Personal Information Overseas)

For the operation of the Service, the Company transfers personal information overseas (storage, processing and provision) as follows under Article 28-8 of the Personal Information Protection Act. Transfers take place over the network when the Service is used. Users may refuse the overseas transfer, but because the Service is stored and operated overseas, a user who refuses cannot use the Service (the collection of usage statistics can be refused separately in the way described in Article 10). Users may notify their refusal by email to the Chief Privacy Officer.

Recipient (country, contact)
Items transferred and purpose
Retention and use period
Google LLC (Firebase, Google Cloud) Taiwan (asia-east1 region), United States Contact: googlekrsupport@google.com privacy.google.com
All items in Article 1 — Server operation, database and file storage, login authentication
Until account deletion or the end of the outsourcing
Resend, Inc. United States Contact: support@resend.com resend.com/legal/privacy-policy
Email address and the content of the notice (plan name and price, billing period, payment and refund amounts) — Sending payment and subscription emails
Until the end of the outsourcing (sending records kept in the service are deleted after 3 months)
Google LLC (Google Analytics) United States Contact: googlekrsupport@google.com privacy.google.com
Pages visited, feature-use events, browser and device information, internal service identifiers (excluding email and the content of works) — Analyzing service usage statistics
Up to 14 months
07

Article 7 (Destruction of Personal Information)

The Company destroys personal information without delay once its retention period has passed or the purpose of processing has been achieved. Electronic files are deleted in a way that cannot be recovered, and paper documents are shredded or incinerated.

When a user requests account deletion, a 7-day grace period begins, during which the user can withdraw the request on the Settings screen. When the grace period has passed, the Company deletes the member information, works and usage records, and deletes the sign-in account. Only the items retained under the law in Article 3 and the pseudonymized email address remain.

When a user deletes a note, event, chapter or relationship in the Service, it is kept in a marked-as-deleted state for 30 days so that the deletion can be undone, and is then deleted completely. Content marked as deleted is excluded from subsequent screens and from what a connected AI reads.

When a user permanently deletes a work, the Company deletes the entire work without delay. Works moved to the trash are permanently deleted after 30 days.

The Company backs up its database regularly for recovery from failures, and keeps backups for up to 30 days before deleting them automatically. Information deleted through account deletion or by the user may remain in backups made before the deletion; these copies are deleted when their retention period ends. If data is restored from a backup in the meantime, information that had already been deleted is deleted again immediately after the restoration.

08

Article 8 (Rights and Obligations of Data Subjects and How to Exercise Them)

Users may at any time request from the Company access to, correction or deletion of, or suspension of processing of their personal information, or withdraw their consent (delete their account).

Users can check their member information and delete their account themselves on the account settings screen of the Service, and can request the exercise of other rights by email to the Chief Privacy Officer. The Company takes action within 10 days of the day it receives a request and notifies the user of the outcome.

Rights may also be exercised through the user's legal representative or a person the user has authorized. In that case, a power of attorney in the form annexed to the Notice on Personal Information Processing Methods (개인정보 처리 방법에 관한 고시) must be submitted.

Requests for access or for suspension of processing may be restricted under Article 35(4) and Article 37(2) of the Personal Information Protection Act, and deletion cannot be requested for information that other laws designate as subject to collection.

09

Article 9 (Children Under 14)

The Service is intended for people aged 14 or older, and the Company does not collect the personal information of children under 14. If the Company learns that a child under 14 has signed up, it deletes the account and information without delay.

10

Article 10 (Installation, Operation and Refusal of Devices That Automatically Collect Personal Information)

The Company uses a session cookie to keep users signed in. This cookie lasts for 5 days after sign-in and is deleted when the user signs out. If this cookie is refused, the user cannot stay signed in.

The Company uses Google Analytics to collect information on usage behavior. The items collected are pages visited, feature-use events (creating a note, creating a work and so on), browser and device information, and internal service identifiers; email addresses, names and the content of works are not among the items collected. The Company does not use the behavioral information it collects for personalized advertising.

Users can refuse statistics collection by refusing cookie storage in their browser settings, or by installing the Google Analytics opt-out browser add-on provided by Google.

11

Article 11 (Measures to Ensure the Security of Personal Information)

The Company takes the following measures under Article 29 of the Personal Information Protection Act and the Standards for Measures to Ensure the Security of Personal Information (개인정보의 안전성 확보조치 기준).

  • —Administrative measures: minimizing the number of personal information handlers, establishing and implementing an internal management plan, and managing and supervising those to whom processing is outsourced
  • —Technical measures: encryption in transit (TLS), encryption of stored data (the cloud provider's encryption at rest), minimizing access rights, using the external account provider's authentication for sign-in, and keeping access records
  • —Physical measures: the servers run in Google Cloud's data centers, and the Company has no physical access to them
12

Article 12 (Chief Privacy Officer)

To oversee work related to the processing of personal information and to handle user complaints and provide remedies for damage, the Company designates the Chief Privacy Officer below. Users may direct all inquiries, complaints and requests for remedies related to personal information to the Chief Privacy Officer, and the Company will respond without delay.

  • —Name: 손승우
  • —Position: CEO
  • —Email: privacy@penpick.app
13

Article 13 (Remedies for Infringement of Rights)

Users who need to report or seek advice about an infringement of personal information may contact the following institutions. Users who object to the Company's handling, or to the Company's disposition on the exercise of rights under Articles 35, 36 and 37 of the Personal Information Protection Act, may file an administrative appeal under the Administrative Appeals Act (행정심판법).

  • —Personal Information Infringement Report Center (개인정보침해 신고센터), Korea Internet & Security Agency (KISA, 한국인터넷진흥원): 118 (from Korea, no area code), privacy.kisa.or.kr
  • —Personal Information Dispute Mediation Committee (개인정보 분쟁조정위원회): 1833-6972, www.kopico.go.kr
  • —Supreme Prosecutors' Office Cyber Investigation Division (대검찰청 사이버수사과): 1301 (from Korea, no area code), www.spo.go.kr
  • —Korean National Police Agency Cyber Bureau (경찰청 사이버수사국): 182 (from Korea, no area code), ecrm.police.go.kr
14

Article 14 (Changes to This Policy)

This Policy applies from October 15, 2026. If content is added, deleted or modified because of changes in the law or the Service, the Company announces it in the Service from 7 days before the effective date; changes that significantly affect users' rights, such as changes to the items collected or the purposes, are announced from 30 days before the effective date and notified to users individually by email or other means.

The same procedure is followed when the table in Article 1 is updated, for example when an external account provider is added.

If the Company replaces or adds a processor (Article 5) or a recipient of personal information overseas (Article 6) with another business that performs the same work, it reflects the change in this Policy and discloses it before the change, as long as the items and purposes of the personal information processed do not increase. Where there is a reason the Company could not foresee, or a reason that requires an immediate change in order to keep providing the Service — such as the end of that business's service, termination of the contract, an outage, or a requirement of law or of a supervisory authority — the Company reflects the change without delay after making it and announces it in the Service.

Changes that increase the items or purposes of the personal information processed, or that require users' consent under the law, follow the procedure in paragraph 1, and the necessary consent is obtained. Previous versions of this Policy are provided on request by email to the Chief Privacy Officer.

Please send inquiries about personal information, and requests for access, correction, deletion or suspension of processing, to the Chief Privacy Officer (privacy@penpick.app). The Company will respond within 10 days of the day it receives a request.