InsuLab Privacy Policy

Effective Date: September 1, 2025

This privacy policy takes effect on September 1, 2025.

InsuLab (the ‘Company’) establishes this policy to protect the personal data of users of the AI language learning service (‘Service’) provided by the Company and to comply with relevant laws and regulations, including the Personal Information Protection Act and the Information and Communications Network Act.

1. Personal Data We Collect

  • When registering and creating an account
    • Google Sign-In: email, name, profile photo, Google UID
    • Apple Sign-In: Apple ID, email, name (optional)
    • User-selected nickname
  • When using the Service
    • Voice recordings
    • Device information (OS, version) and in-app usage logs
  • For payments and billing
    • RevenueCat purchase history
    • Subscription status, renewal information, credit balance
    • App Store / Google Play purchase records

2. Purpose of Processing Personal Data

  • Account registration, login, and account management
  • Providing AI learning services (conversation generation, pronunciation evaluation, role-play, etc.)
  • Storing and sharing user-generated content
  • Service operations, log analysis, statistics, and feature improvements
  • Managing payments, settlements, and refunds for paid services
  • Responding to customer inquiries, handling reports, and resolving disputes

3. Retention and Use Period of Personal Data

Personal DataRetention PeriodLegal Basis
Login records3 monthsProtection of Communications Secrets Act
Display and advertising records6 monthsAct on Consumer Protection in Electronic Commerce
Consumer complaints and dispute records3 yearsAct on Consumer Protection in Electronic Commerce
Contract and withdrawal records5 yearsAct on Consumer Protection in Electronic Commerce
Payment and supply records5 yearsAct on Consumer Protection in Electronic Commerce
All other collected personal dataDeleted immediately upon membership withdrawal (except where retention is required by law)

4. How We Collect Personal Data

  • Direct input during MojiMoji app registration and Service use
  • Information provided during Google / Apple login
  • Automatic collection through integrated services such as Firebase and RevenueCat
  • Automatically generated device and log data while using the app

5. Overseas Transfer of Personal Data

RecipientCountryDataPurposeRetention
Google Firebase (BigQuery, Firestore, etc.)Seoul & United StatesAccount, learning, and usage dataData storage, analysis, and authenticationDeleted immediately upon membership withdrawal (except statutory retention)
OpenAI, L.L.C.United StatesConversation content, voice transcriptsGPT, Whisper, and TTS processingDeleted immediately after processing (logs are anonymized)
RevenueCat, Inc.United StatesPurchase information, subscription statusIn-app purchase managementUntil membership withdrawal or statutory retention period
Google AdMobUnited StatesAdvertising ID, device informationAd deliveryUntil membership withdrawal or statutory retention period
RailwaySingaporeServer logs, request dataApp server operationsUntil membership withdrawal or statutory retention period

6. Outsourcing of Personal Data Processing

VendorDelegated Tasks
Google FirebaseData storage, authentication, and analytics
OpenAIConversation generation and speech recognition/synthesis
RevenueCatIn-app purchase management
Google AdMobAd placement
Apple / Google StoresPayment processing
RailwayServer operations

7. Personal Data Destruction Procedures and Methods

  • Data is destroyed without delay once the purpose is fulfilled
  • Electronic files: permanently deleted using irrecoverable methods
  • Paper documents: shredded or incinerated

8. Measures to Ensure the Security of Personal Data

  • SSL/TLS encrypted communication
  • Encrypted storage of sensitive data (FlutterSecureStorage)
  • Application of Firebase Security Rules and App Check
  • Regular security audits and backups
  • Minimum access privileges and regular internal training

9. Use of Cookies and Similar Technologies

  • Used for automatic login, traffic analytics, and personalized services
  • Mobile apps utilize device identifiers (such as advertising IDs)
  • Refusing cookies/identifiers may limit certain features

10. Rights of Data Subjects

Users may exercise the following rights at any time.

  • Access, correction, and deletion: available in the app under My Page > Account Settings
  • Request to suspend processing or delete the account: contact customer support or email mojimoji.official.kr@gmail.com
  • Processing timeline: We respond within 30 days of receipt and notify the result

11. Data Protection Officer

  • Officer: Insu Oh
  • Position: CEO
  • Email: mojimoji.official.kr@gmail.com

12. Complaint Handling and Remedies

Users may contact the following organizations for consultation or to file a complaint about personal data breaches.

  • Personal Information Infringement Report Center (dial 118 / privacy.kisa.or.kr)
  • Personal Information Dispute Mediation Committee (1833-6972 / www.kopico.go.kr)
  • Supreme Prosecutors’ Office Cyber Investigation Division (1301 / www.spo.go.kr)
  • Korean National Police Agency Cyber Bureau (182 / ecrm.cyber.go.kr)

13. Children’s Personal Data

  • The Company does not allow users under the age of 14 to register and does not knowingly collect their personal data.