Lubble Privacy Policy

Lubble (“Lubble,” hereinafter the “Company”) values users’ personal information and, in accordance with Article 30 of the Personal Information Protection Act, establishes and discloses the following Privacy Policy to protect the rights and interests of data subjects. This Policy applies to all electronic services operated by the Company, including the Lubble application, related websites, and customer support channels.

Article 1. Purpose of Collection and Use of Personal Information

The Company collects and uses personal information for the following purposes. If the purpose changes, the Company will obtain separate consent through the procedures required by applicable law.

Membership Registration and User Identification
- Account creation, user identification, and identity verification through email registration or social login (Google, Apple, etc.)
Provision of Services
- Operation of service features such as couple connection, shared calendar, countdowns, memos, photos, messages, diaries, and widgets
- Management of connection status between members, provision of shared space, and storage and synchronization of data
Payment, Subscription, and Digital Goods Management
- Verification of paid service payment status
- Management of subscription status, purchase validation, and restoration processing
- Determination of eligibility for premium features
- Management of the granting, accrual, deduction, and use history of digital goods such as Hearts
- Processing of Free Hearts granted in connection with watching rewarded ads
Customer Support and Complaint Handling
- Identification of service errors and response
- Handling of inquiries, reports, account requests, and withdrawal requests
Ensuring Service Security
- Prevention of abnormal use
- Prevention of unauthorized access
- Management of service usage records and security checks
Compliance with Legal Obligations
- Consumer protection
- Retention of records related to electronic commerce
- Fulfillment of obligations under applicable laws
Advertising and Ad Performance Measurement
- Provision of rewarded ads
- Processing of ad display, participation status, and reward granting
- Measurement of ad performance and analysis of marketing efficiency
- Meta ad performance measurement and conversion analysis

Article 2. Items of Personal Information Collected

The Company may collect the following personal information.

Category	Collected Items
When registering by email	Email address, password, nickname, date of birth, date of first meeting
When using social login	Google or Apple account identifier, email, nickname, and profile photo if selected
When using the service	User-generated content such as countdowns, memos, images, chats, schedules, and notification settings
When using subscription and payment services	App User ID, subscription status, purchased product information, purchase date and time, information necessary for receipt validation and subscription restoration, and Heart grant/deduction/balance history
For advertising and performance measurement	Advertising ID (ADID, IDFA), hashed email, internal user identifier (userId), app event data (e.g. sign-up, purchase, subscription, Heart grant/use, ad participation status, etc.)
Automatically collected items	IP address, access time, device information (OS, device model), advertising ID (ADID, IDFA), cookies, service usage records, ad exposure and participation records, diagnostic information, etc.
When contacting customer support	Inquiry details, device information, app version, contact email, etc.
When processing payments	Billing and payment-related information is processed directly by the Apple App Store or Google Play Store. The Company may receive only information necessary to verify payment approval, subscription status, and purchase validation.

※ Membership registration by children under the age of 14 is restricted, and the Company does not collect personal information from children of that age.

Article 3. Retention and Use Period of Personal Information

General Principle
- The Company will destroy personal information without delay once the purpose of collection and use has been achieved.
- However, certain information may be retained for a certain period in accordance with applicable laws or the Company’s legitimate operational purposes.
Retention under Internal Policy
- Information related to prevention of fraudulent or improper use: 30 days after withdrawal
- Minimum identifying information for customer support: 30 days after withdrawal
Retention under Applicable Laws

Purpose of Retention	Retention Period	Legal Basis
Records on contracts and withdrawal of offers	5 years	Electronic Commerce Act
Records on payment and supply of goods/services	5 years	Electronic Commerce Act
Records on consumer complaints and dispute resolution	3 years	Electronic Commerce Act
Records on labeling and advertising	6 months	Electronic Commerce Act
Records on access (including IP logs)	3 months	Protection of Communications Secrets Act