개인정보처리방침 — Witty English

1. Who we are

This Privacy Notice explains how Witty English ("we", "us", "our") processes personal data for the WITTY ENGLISH vocabulary service (the "Service"). We are the data controller for personal data processed through the Service.

2. Personal data we collect

Account data: name, email address, and (for social sign-in) profile photo and provider ID.
Authentication data: hashed credentials, session tokens, and sign-in timestamps.
Learning content: decks, words, sentences, and practice history you create.
Support communications: messages sent through our KakaoTalk 1:1 channel or in-app support.
Usage and telemetry: pages visited, features used, error and diagnostic logs.
Device and technical data: IP address, browser, operating system, device identifiers, referrer, language preference.
Purchase data: the email address you share for account upgrade after a bank transfer, and your entitlement status. We do not store your bank account or card details.

3. Why we use your data and our legal basis

Provide the Service (account, decks, sync, AI features): performance of a contract.
Customer support: performance of a contract and legitimate interest.
Security and fraud prevention: legitimate interest and legal obligation.
Product improvement and analytics: legitimate interest.
Order and tax records: performance of a contract and legal obligation.
Marketing communications (if any): your consent, which you can withdraw at any time.

4. Who we share data with

Hosting and infrastructure providers that store and serve the Service.
AI providers that generate definitions, examples, and feedback from your prompts.
Analytics and error-monitoring tools that help us understand usage and diagnose issues.
Professional advisers (legal, accounting) where reasonably necessary.
Authorities where required by law, court order, or valid legal process.

We do not sell your personal data.

5. International transfers

Your data may be processed in countries outside your own, including the United States. Where required, we rely on appropriate safeguards such as Standard Contractual Clauses or adequacy decisions.

6. Data retention

We keep account and learning content for as long as your account is active. If you delete your account or ask us to erase your data, we will delete or anonymise it within a reasonable period, except where retention is required by law (e.g. tax records), to resolve disputes, or enforce our agreements. Diagnostic logs are kept for a short rolling window and then deleted.

7. Your rights

Depending on where you live, you may have the right to:

access the personal data we hold about you;
rectify inaccurate or incomplete data;
erase your data ("right to be forgotten");
restrict or object to certain processing;
data portability;
withdraw consent where processing is based on consent;
lodge a complaint with your local supervisory authority.

To exercise these rights, contact us through our KakaoTalk 1:1 channel. We aim to respond within one month.

8. Security

We use appropriate technical and organisational measures to protect your data, including encryption in transit, access controls, and regular review. No online service can be guaranteed 100% secure — please use a strong password and keep your credentials confidential.

9. Cookies and similar technologies

We use a small number of essential cookies and local storage entries so you can stay signed in, keep your theme and language preferences, and resume where you left off. We may also use privacy-friendly analytics. You can clear cookies and local storage at any time; doing so will sign you out and reset device-stored preferences.

10. Children

The Service is not directed to children under 14 (or the equivalent minimum age in your jurisdiction), and we do not knowingly collect their personal data. If you believe a child has provided personal data, please contact us so we can delete it.

11. Changes to this notice

We may update this Privacy Notice from time to time. We will update the "Last updated" date above and, for material changes, notify you through the Service.

12. Contact

For privacy questions or requests, contact us through our KakaoTalk 1:1 channel.