Privacy Policy
Version 1.1
Numenore LLC (hereinafter referred to as the "Company") complies with applicable laws and regulations, including the Personal Information Protection Act (PIPA) of the Republic of Korea, in operating the BultagiCom service (hereinafter referred to as the "Service"). The Company hereby establishes and publicly discloses this Privacy Policy to protect the personal information of its users.
Article 1 (Categories of Personal Information Collected)
The Company collects the following personal information for the purpose of providing the Service.
1. Information Collected at Registration
- Required items: Email address, password, username (ID), display name
- Optional items: Profile image, bio
2. Information Collected via Social Login
- Google Login: Email, name, profile image
3. Information Automatically Collected During Service Use
- IP address, cookies, date and time of access, service usage records, device information
Article 2 (Purposes of Collection and Use of Personal Information)
The Company uses the collected personal information for the following purposes.
- User Management: Identity verification for membership-based services, personal identification, prevention of unauthorized use by fraudulent members, verification of intent to register, age verification
- Service Provision: Delivery of content, provision of personalized services, identity authentication
- Service Improvement: Development of new services, statistical analysis, enhancement of service quality
- Customer Support: Processing of inquiries and complaints, delivery of notices, preservation of records for dispute resolution
Article 3 (Retention and Use Period of Personal Information)
The Company shall destroy personal information without delay once the purposes of collection and use have been fulfilled. However, the following information shall be retained for the periods specified below.
1. Retention Pursuant to Internal Company Policy
- Records for the prevention of unauthorized use: 30 days after account deletion
2. Retention Pursuant to Applicable Laws and Regulations
| Retained Information | Legal Basis | Retention Period |
|---|---|---|
| Records relating to contracts or withdrawal of offers | Act on Consumer Protection in Electronic Commerce (전자상거래법) | 5 years |
| Records relating to payment settlements and supply of goods | Act on Consumer Protection in Electronic Commerce (전자상거래법) | 5 years |
| Records relating to consumer complaints or dispute resolution | Act on Consumer Protection in Electronic Commerce (전자상거래법) | 3 years |
| Records relating to labeling and advertising | Act on Consumer Protection in Electronic Commerce (전자상거래법) | 6 months |
| Website access logs | Protection of Communications Secrets Act (통신비밀보호법) | 3 months |
Article 4 (Procedures and Methods for Destruction of Personal Information)
1. Destruction Procedures
Information entered by users shall be transferred to a separate database after the purpose of collection has been fulfilled, and shall be destroyed after being stored for a designated period in accordance with internal policies and applicable laws and regulations.
2. Methods of Destruction
- Electronic files: Deleted using technical methods that render the records irreproducible
- Printed documents: Destroyed by shredding or incineration
Article 5 (Provision of Personal Information to Third Parties)
As a general principle, the Company does not provide users' personal information to external parties. However, the following cases shall constitute exceptions.
- Where the user has provided prior consent
- Where required by the provisions of applicable laws and regulations, or where a request is made by an investigative authority in accordance with the procedures and methods prescribed by law for investigative purposes
Article 6 (Entrustment of Personal Information Processing and Use of External Services)
The Company entrusts the processing of personal information and utilizes external services as follows for the operation of the Service.
1. Cloud Infrastructure (Data Storage and Processing)
| Entrusted Party | Entrusted Tasks | Server Location |
|---|---|---|
| Amazon Web Services (AWS) | Service infrastructure operation, data storage and processing | Republic of Korea (Seoul Region, ap-northeast-2) |
Account and service data is generally stored in the AWS Seoul Region (ap-northeast-2). When an external AI provider is used for a feature described below, the text required for that feature may be processed temporarily outside the Republic of Korea.
2. YouTube API Services
The Service uses YouTube API Services for the collection and display of YouTube content. The Google Privacy Policy applies to the use of YouTube API Services. Users may manage or revoke API access permissions for their Google accounts through the Google Security Settings page.
3. AI Processing (Numenore-Hosted AI and Google Gemini)
The Service uses AI operated by Numenore and Google Gemini AI for content verification, summarization and translation, AI newsletter generation, tone transformation of user posts and comments, and review of user reports. Depending on the feature, this processing may include titles, summaries and bodies of public sources as well as text submitted by users in posts, comments and reports. Account data such as email addresses, Google account identifiers and profile information is not intentionally included in AI requests. Personal information that a user writes directly in submitted text may, however, be included in the processing.
Numenore-hosted AI runs on access-restricted Numenore infrastructure. Required text may be sent to Google when an external provider is selected or when Gemini fallback is enabled during an outage of the hosted AI. Image generation or analysis may also use Google services separately. In those cases, the Google Privacy Policy and the Google AI Service Terms apply.
4. Other
In the event that additional entrustment becomes necessary in the future, the Company shall notify users of the entrusted parties and the scope of entrusted tasks, and shall obtain prior consent where required.
Article 7 (Rights of Users and Legal Representatives and Methods of Exercise)
- Users may view or modify their registered personal information at any time.
- Users may withdraw their consent to the collection and use of personal information (account deletion) at any time.
- In the case of children under the age of 14, a legal representative may request to view, modify, delete, or suspend the processing of the child's personal information.
- The above rights may be exercised through the settings menu within the Service or by contacting the Privacy Officer in writing or by email. Such requests shall be processed without delay.
Article 8 (Installation, Operation, and Rejection of Automatic Personal Information Collection Devices)
1. Purposes of Cookie Use
- Analysis of user access frequency and visit times
- Improvement of services through understanding of usage patterns
- Provision of personalized services
2. Installation, Operation, and Rejection of Cookies
Users have the right to choose whether to allow the installation of cookies. Users may allow or reject cookies through their web browser settings. However, refusing cookies may result in difficulties in using certain features of the Service.
Article 9 (Measures to Ensure the Security of Personal Information)
The Company implements the following measures to ensure the security of personal information.
- Administrative measures: Establishment and implementation of an internal management plan, regular employee training
- Technical measures: Management of access permissions to personal information processing systems, application of encryption technologies (password hash encryption, SSL/TLS encryption for data in transit), installation of security software
- Physical measures: Access controls for server rooms, data storage facilities, and similar areas
- Data storage: All user data is stored in the AWS Seoul Region (ap-northeast-2, Republic of Korea) using encrypted storage
Article 10 (Privacy Officer)
The Company has designated the following individual as the Privacy Officer, who is responsible for overseeing all matters relating to the processing of personal information, and for handling user complaints and remedying damages arising in connection with the processing of personal information.
| Category | Details |
|---|---|
| Name | Kim Hyunjung (김현정) |
| Title | Director |
| privacy@numenore.biz |
For reports or consultations regarding personal information infringement, please contact the following organizations.
- 개인정보침해신고센터 (Personal Information Infringement Report Center) (https://privacy.kisa.or.kr / Tel: 118)
- 대검찰청 사이버수사과 (Supreme Prosecutors' Office Cyber Investigation Division) (https://www.spo.go.kr / Tel: 1301)
- 경찰청 사이버안전국 (National Police Agency Cyber Bureau) (https://cyberbureau.police.go.kr / Tel: 182)
Article 11 (Amendments to the Privacy Policy)
This Privacy Policy shall take effect from the effective date stated below. In the event of any additions, deletions, or corrections to the content of this policy in accordance with applicable laws and regulations, the Company shall provide notice through public announcements at least seven (7) days prior to the implementation of such changes.
Effective Date: February 8, 2026