ZemTalk Privacy Policy

Effective date: October 10, 2026 · Version 1.1.0

Usomnia Co., Ltd. (the "Company") values the personal information of Members who use the ZemTalk service (the "Service") and complies with applicable laws, including the Personal Information Protection Act (「개인정보 보호법」) and the Act on the Protection, Use, etc. of Location Information (「위치정보의 보호 및 이용 등에 관한 법률」). This Policy is intended to inform you of what personal information the Company processes, why, and how.

1. Items of Personal Information Collected and Methods of Collection

A. Upon Sign-up

• Sign-up is done only through phone number verification. A member identifier (unique ID) and an automatically generated nickname are created at sign-up. We do not receive any information from other services such as social login providers.

B. Upon Phone Number Verification

• Required: mobile phone number, verification result (date and time of verification)
• The phone number is encrypted when sent from the app to the server, and the server stores only the encrypted value, an irreversible hash value for duplicate checking, and the last 4 digits for on-screen display.

C. Upon Profile Registration

• Required: nickname, gender, date of birth (for age verification and display), country, language(s) used, profile photo
• Optional: interests, additional profile photos, self-introduction

D. In the Course of Using the Service

• Location information: the device's location (latitude and longitude, with precision reduced to approximately 10 m when stored on the server) and location change history — if you have granted location permission
• Location sharing information: if you have used location sharing in a chat room, the coordinates, address/place name and map image of the selected location
• Posts: Moments (text and photos), chat messages (text, photos, voice and files), chat request messages
• Translation information: if you have used AI translation, the messages submitted for translation, the translation results, and the number of uses
• Paid service information: app marketplace transaction identifiers (transaction ID, etc.), products purchased, dates and times of purchase, renewal, expiration and refund, subscription status, history of Points granted and used (payment method information such as card numbers is processed by the app marketplace and is not collected by the Company)
• Usage records: report and block history, service usage records, access records (login date and time, IP address)
• Device information: device identifier, device model and manufacturer, operating system version, app version, push notification token, device language and region settings

E. Upon Customer Inquiries

• Name, contact details (phone number or email), content of the inquiry and attached materials

F. Methods of Collection

Personal information is entered directly by Members on the app's sign-up and usage screens, provided by app marketplaces upon payment, or automatically generated and collected in the course of using the Service.

2. Purposes of Use of Personal Information

1. Member identification, sign-up and login, management of the Member's own account, restriction of use by persons under the age of 18
2. Confirmation of one account per person through phone number verification, prevention of duplicate sign-ups and fraudulent use
3. Disclosure of Profiles, provision of location-based functions such as displaying nearby Members and Moments and displaying distances, delivery of location sharing messages requested by Members
4. Provision of chat requests, 1:1 chat, Basic translation and AI translation, and notifications such as new message alerts
5. Confirmation of payments for paid services, granting and management of Points and Plus, processing of subscription renewals, cancellations and refunds, handling of payment-related disputes
6. Processing of reports, prevention of fraudulent use, fraud and illegal acts and imposition of restrictions on use, handling of disputes
7. Improvement of service quality, error analysis, compilation of usage statistics (in a form that does not identify individuals)
8. Delivery of announcements, response to customer inquiries
9. Provision of marketing and advertising information (only for Members who have given separate consent)

3. Retention and Use Period of Personal Information

The Company destroys personal information without delay upon a Member's withdrawal. However, in the following cases, the information is retained for the period indicated:

• Member identification information, phone number hash values and records of restrictions on use for the prevention of fraudulent use: 1 year after withdrawal
• Access records (login date and time, IP address): 3 months (Protection of Communications Secrets Act (「통신비밀보호법」))
• Records confirming the use and provision of location information: 6 months (Act on the Protection, Use, etc. of Location Information)
• Records of contracts, payments, withdrawals of subscription and refunds in connection with the use of paid services: 5 years; records of consumer complaints and dispute resolution and records of customer inquiries: 3 years (Act on the Consumer Protection in Electronic Commerce (「전자상거래 등에서의 소비자보호에 관한 법률」))
• Where retention is required under applicable laws, such as at the request of investigative agencies: the period prescribed by the relevant laws

Moments cease to be visible to other Members when deleted by the Member or in accordance with criteria set by the Service, and chat messages, photos and shared locations sent to other Members before withdrawal may remain in the chat history of the other Members.

4. Provision of Personal Information to Third Parties

The Company does not provide Members' personal information to third parties. However, exceptions apply where the Member has given prior consent, or where provision is based on law or requested by an investigative agency in accordance with the procedures prescribed by law.

Due to the nature of the Service, a Member's Profile (nickname, photos, age, gender, country, interests), approximate distance and Posts are disclosed to other Members. When a Member uses the location sharing function, the location selected by the Member (coordinates, address/place name, map image) is delivered to the chat partner chosen by the Member.

5. Entrustment of Personal Information Processing and Overseas Transfer

The Company entrusts the processing of personal information as follows for the smooth provision of the Service. Service data is stored on servers located in the Republic of Korea (Seoul), and only the information necessary for the tasks marked as overseas in the table below is processed overseas.

Overseas transfers take place over the network when the relevant function is used. The retention period lasts until the purpose of processing is achieved or the entrustment agreement ends, and trustees may retain data for a certain period in accordance with their own policies for purposes such as monitoring abuse of their services. The content of AI translation requests is transmitted solely for the purpose of translation processing.

Members may refuse overseas transfers. Notifications can be turned off in the device or app settings, and Basic translation, which is processed on the device, can be used instead of AI translation. However, if notifications are turned off, you will not receive new message alerts, and if you refuse phone number verification, sign-up and use of the Service will be restricted.

Payments for paid services are processed by Apple Inc. (App Store) and Google LLC (Google Play) in accordance with their respective privacy policies, and the Company receives only the transaction information necessary to confirm payment.

6. Procedures and Methods for Destruction of Personal Information

Personal information whose retention period has ended or whose purpose of processing has been achieved is destroyed without delay. Electronic files are deleted using methods that make recovery impossible, and photos, files and map images stored on servers are deleted from storage.

7. Rights of Members and How to Exercise Them

1. Members may view and modify their personal information in the app at any time, and may request suspension of processing and deletion of their personal information by withdrawing their membership.
2. The provision of location information can be turned off at any time in the device settings, and notifications in the device or app settings.
3. For other requests for access, correction, deletion or suspension of processing, please contact the Chief Privacy Officer below, and action will be taken without delay.

8. Personal Information of Persons Under the Age of 18

The Service may be used only by persons aged 18 or older, and the Company does not knowingly collect personal information from persons under the age of 18. If it is confirmed that a user is under the age of 18, the relevant account and personal information will be deleted.

9. Measures to Ensure the Security of Personal Information

• Encryption in transit (HTTPS/TLS) and access rights management
• Encrypted transmission and encrypted storage of phone numbers
• Access control based on authentication tokens, retention of access records
• Minimization of personnel who process personal information

10. Automatic Collection Devices

The Company does not use web cookies. However, the device identifier and push notification token are stored for app operation and sending notifications, and the notification token is no longer used once the app is deleted or the user logs out.

11. Processing of Location Information

Location information is used only to display nearby Members and Moments, calculate distances, and deliver location sharing messages requested by Members. In the nearby Members function, only an approximate distance, not the exact location, is displayed to other Members, and in the location sharing function, the location directly selected by the Member is delivered only to the chat partner chosen by the Member. Details on the processing of location information are governed by the Location-Based Services Terms.

12. Chief Privacy Officer

• Name: Kim Myunghwan
• Position: CEO
• Phone: 010-3254-7990
• Email: contact@usomnia.co.kr

For reports or consultations regarding infringement of personal information, you may contact the Personal Information Infringement Report Center (118 without area code, privacy.kisa.or.kr), the Personal Information Dispute Mediation Committee (1833-6972, www.kopico.go.kr), and others.

13. Changes to this Policy

If this Privacy Policy is changed, we will notify you through in-app announcements from 7 days before the effective date, and in the case of changes that are material to Members' rights, from 30 days before.

14. Language

This Privacy Policy has been prepared in Korean, and in the event of any discrepancy between content translated into another language and the Korean content, the Korean content shall prevail.

Addendum

This Privacy Policy takes effect on October 10, 2026. The previous Policy (version 1.0.0) is replaced by this Policy.