Lubble Privacy Policy

Lubble (“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 personal information and rights of data subjects. This Policy applies to the Lubble application and all electronic services operated by the Company, including related websites and customer support channels.

Article 1. Purposes 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.

Sign-up and user identification
- Creating accounts through email sign-up or social login (Google, Apple, etc.), identifying users, and verifying identity
Service provision
- Operating service features such as couple connection, shared calendar, countdowns, notes, photos, messages, diaries, and widgets
- Managing connection status between members, providing shared spaces, and storing and syncing data
Payment and subscription management
- Confirming payment status for paid services
- Managing subscription status, purchase validation, and restoration
- Determining eligibility for premium features
Customer support and complaint handling
- Identifying and responding to service errors
- Responding to inquiries, receiving reports, and processing account and withdrawal requests
Ensuring service security
- Preventing abnormal use
- Preventing unauthorized access
- Managing service usage records and conducting security checks
Compliance with legal obligations
- Consumer protection
- Retention of records related to e-commerce
- Compliance with obligations under applicable laws

Article 2. Categories of Personal Information Collected

The Company may collect the following personal information.

Category	Items Collected
When signing up by email	Email address, password, nickname, date of birth, anniversary/start date
When using social login	Google or Apple account identifiers, email address, nickname, and profile photo if selected
When using the Service	User-generated content such as countdowns, notes, images, chats, schedules, and notification settings
When using subscription and payment services	App User ID, subscription status, purchased product information, purchase date/time, and information necessary for receipt validation and subscription restoration
Automatically collected information	IP address, access time, device information (OS, device model), advertising identifiers (ADID, IDFA), cookies, service usage records, etc.
When contacting customer support	Inquiry details, device information, app version, contact email address, etc.
When processing payments	Billing and payment information is processed directly by the Apple App Store or Google Play Store. The Company may only receive information necessary to verify payment approval, subscription status, and purchase validation.

Children under the age of 14 are not permitted to register, and the Company does not collect personal information from children under that age.

Article 3. Retention and Use Period of Personal Information

General rule
- Once the purpose of collection and use of personal information has been achieved, the Company will destroy the relevant information without delay.
- However, certain information may be retained for a certain period where required by applicable law or for the Company’s legitimate operational purposes.
Retention under internal policy
- Information related to preventing fraudulent or abnormal use: 30 days after withdrawal
- Minimum identifying information for responding to customer support requests: 30 days after withdrawal
Retention under applicable laws

Purpose of Retention	Retention Period	Legal Basis
Records on contracts and withdrawal/cancellation	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

Article 4. Provision of Personal Information to Third Parties

The Company does not, in principle, provide users’ personal information to external parties. However, exceptions may apply in the following cases: