Privacy Policy

Effective Date and Time: September 14, 2026, 00:39:54 UTC

Truein Tech Co., Ltd. (the “Company”) operates CSSP EasyPhone (the “Service”) and complies with the Personal Information Protection Act and other applicable personal information protection laws.

This Privacy Policy explains the categories of personal information the Company processes in the course of providing the Service, the purposes of use, retention periods, provision to third parties, outsourcing of processing, cross-border transfers, and the rights of data subjects and how to exercise them.

Article 1 (Definitions)

Terms used in this Policy have the following meanings.

Article 2 (Purposes, Categories, and Retention Periods of Personal Information)

The Company processes personal information within the scope necessary to provide the Service as follows.

1. Categories collected for general Service use and device registration

2. Access to device features for mobile app functions (OS app permissions)

The Company uses Android OS permissions to access certain features and data on the user’s device. These access permissions may be allowed or denied directly by the user in the operating system (OS) settings, and when allowed they are processed only temporarily within the stated purposes of collection and use.

Article 3 (Methods of Collecting Personal Information)

The Company collects personal information by the following methods.

Article 4 (Processing of Smartphone Users (Protected Persons)’ Personal Information and Functional Consent Notice)

App UI usage history of a Smartphone User (Protected Person), and Ordinary Message matching information that the user has shared with the guardian, is personal information about that Smartphone User (Protected Person). When the app is installed on the Smartphone User (Protected Person)’s device and the user logs in for the first time, the Company informs the user of the following and obtains consent.

1. Matters regarding provision to guardians

2. Functional consent item (collection and upload of smartphone usage pattern action logs)

This item is not an Android OS mandatory permission prompt. It is a Service functional consent that the user expressly chooses on login or in-app settings screens.

Members must not view or use a Smartphone User (Protected Person)’s information without their consent, or beyond the original Service purposes. Members must have lawful authority to install and link the app on such user’s device, and the Company may request confirmation of this authority and consent when necessary.

Article 5 (Provision to Third Parties and Payment Service Providers)

As a rule, the Company does not provide personal information to third parties beyond the scope stated in this Policy. Exceptions apply where the data subject has given prior consent, where a special provision of applicable law exists, or where permitted by law to prevent an imminent risk to life or body.

If the user consents to cookie use on the web advertising landing page, the Company provides personal information to a third party as follows in order to use conversion data to measure advertising performance.

The Company does not provide email addresses or Member identifiers (user_id) to Meta in the provision above. If the user declines cookie use, conversion data is not provided to Meta.

If the Member consents when using the how-to inquiry (Ask an agent directly) feature on web customer support, the Company provides personal information to a third party as follows in order to respond to the inquiry.

The Company does not provide the email address to Crisp unless it has obtained consent to use the how-to inquiry feature. Refusing consent still allows use of other customer-support features such as 1:1 inquiry.

Payments are processed through Paddle.com Market Limited, the Merchant of Record, and related payment affiliates. Payment method information such as credit card numbers, card expiration dates, and card security codes is transmitted directly from the user’s browser or Paddle payment screen to Paddle. The Company does not collect or store full payment method information. For payment confirmation, subscription management, and refund processing, the Company receives from Paddle the transaction information it needs, such as the payment ID, purchased product, payment amount, and payment/refund status and date/time.

Article 6 (Outsourcing of Personal Information Processing)

To provide the Service smoothly, the Company outsources personal information processing to external processors as follows.

When entering into outsourcing contracts, the Company specifies in writing, in accordance with applicable law, matters concerning personal information protection, prohibition of processing for other purposes, technical and administrative safeguards, restrictions on re-outsourcing, management and supervision of processors, and liability for damages, and manages and supervises processors’ personal information processing.

Article 7 (Cross-border Transfer of Personal Information)

In using hosting, data backup, real-time relay, notification, overseas payment, advertising-performance measurement, and live-chat services necessary to perform the Service agreement, the Company transfers personal information abroad.

1. Cloudflare

2. Backblaze B2

3. LiveKit

4. Google Firebase

5. Paddle

6. Meta

7. Crisp

Article 8 (Statutory Retention of Personal Information)

Even after membership withdrawal or a request for deletion of personal information, if information must be retained under applicable law, the Company stores that information separately from other personal information for the statutory period.

Article 8-2 (Retention of Personal Information to Prevent Abuse)

To prevent abuse of the Service (including duplicate use of free trials and repeated payment cancellations and refunds within 14 days) and to block unlawful use of the Service, the Company retains the following minimum identifying information even after membership withdrawal.

Article 9 (Procedures and Methods for Destruction of Personal Information)

When personal information becomes unnecessary because the retention period has expired, the purpose of processing has been achieved, or membership has been withdrawn, the Company destroys that personal information without delay.

Upon membership withdrawal, as a rule personal information other than payment/transaction records that must be retained separately under applicable law and the email hash retained under Article 8-2 to prevent abuse is deleted immediately from the production system. However, if the Member opts in during withdrawal to “temporary retention for account recovery within 30 days,” the data is stored securely and separately for 30 days from the withdrawal date and then destroyed.

Backup snapshots stored in Backblaze B2 for failure and disaster recovery are automatically deleted in an unrecoverable manner 30 days after creation. When restoring the production system, membership withdrawal and deletion history are re-applied so that permanent destruction is maintained. Real-time video and audio streaming data generated during video-assistant calls is not stored and is completely extinguished immediately upon relay.

Article 10 (Use of Cookies and Local Storage)

The Company uses cookies and local storage as follows.

Users may accept or decline in the cookie notice on the web landing page.

Article 11 (Rights of Data Subjects and How to Exercise Them)

Article 12 (Photos/Videos and Third-Party Personal Information)

Members (Guardians) or Smartphone Users (Protected Persons) should upload only photos and videos necessary for use of the Service. If uploaded materials contain third-party personal information, lawful authority or consent must be obtained. The Company does not use photos or videos that users upload for display on Service screens for advertising, marketing, sale, or AI model training. Images attached to customer-support (1:1 inquiry) submissions may, after personal information is masked as stated in Article 2, be used in de-identified form to improve Service quality and advance the technology.

Article 13 (Safeguards for Personal Information)

The Company takes the following technical and administrative measures so that collected personal information is not lost, stolen, leaked, altered, or damaged.

Article 14 (Privacy Officer and Contact)

The Company designates a personal information protection officer as follows to oversee personal information processing and handle related inquiries and requests to exercise rights.

Company NameTRUIN TECH CO.,LTD.
Privacy Officer / DepartmentCEO (Choi Hyong Chol) / Personal Information Protection Team
Email[email protected]
Phone070-4098-7461
Address603-75, 18, Mugunghwa-ro, Ilsandong-gu, Goyang-si, Gyeonggi-do, Republic of Korea

Article 15 (Remedies for Infringement of Rights)

Data subjects may contact the following organizations for consultation, reporting, or dispute mediation regarding personal information infringement. These organizations are separate from the Company. For inquiries and rights requests regarding the Company’s personal information processing, please first contact the Company’s personal information protection department.

Article 16 (Changes to This Privacy Policy)

This Privacy Policy takes effect on September 14, 2026, 00:39:54 UTC.