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Keyfred Inc. (the "Company") establishes and discloses this Privacy Policy, in accordance with the Personal Information Protection Act of the Republic of Korea and other applicable laws, to protect the personal information of users of "Photoz" (the "Service"), its photo archive and community service, and to handle related complaints promptly and smoothly.

Article 1 Personal Information We Process and How We Collect It

1. The Company processes the following personal information.

   Category	Items	How collected
   At sign-up (required)	E-mail address, name, profile picture (not provided by Apple sign-in), account identifier of the sign-in provider (Google or Apple)	Received from the provider when the Member signs in with Google or Apple
   Profile (optional)	Nickname, bio (up to 150 characters), gender (male / female / other / prefer not to say), country and city of activity, native language, favourite camera brands (including smartphone model and free-text "other"), favourite photo genres, profile photo	Entered or uploaded by the Member. Profile photos are resized to 512px and stored with location metadata removed
   Photos	Uploaded photo files and their metadata (EXIF information such as camera, lens, capture settings, capture time and GPS location, plus XMP and C2PA information); photo locations the Member sets on a map themselves (for photos without location); titles, descriptions, tags, categories and cities entered by the Member	Uploaded, entered or set by the Member
   Photo processing results	Capture verdict and its basis, safety check result, AI metadata suggestions	Generated while the Service is used
   Community activity	Follows, likes, saves, ratings, comments, Author Grade	Generated while the Service is used
   Device and usage information	Device identifier (per app installation), platform (iOS, Android, Lightroom plugin for Mac and Windows), app version (for the plugin, including the Lightroom and operating system (macOS, Windows) versions), sign-in session records, service access logs (access time, IP address)	Generated and collected automatically while the Service is used
   App usage analytics	App usage events and screens viewed (for example, sign-up completed, upload completed, likes, saves, searches; search words, photo and message contents and account identifiers are never included), crash and error reports (stack traces, device model, OS and app version), app instance ID, and, in the Android app only, the advertising ID	Collected automatically by the app
   Web usage analytics	Types of pages viewed in the web app (photoz.co.kr/app) and time spent on them, browser, OS and device type, screen size, language, approximate location (country and city, estimated from the IP address), referral source, and analytics cookie identifiers; for visitors who arrive by clicking a Google ad, the ad click identifier and campaign information, sign-up completion and first photo upload completion events, and ad measurement cookie identifiers; addresses that identify individual photos, albums or authors, search words, photo and message contents and account identifiers are never included	Collected automatically by the browser of Members and non-member visitors. For visitors from the EEA, the UK or Switzerland, collected only if they allow it
   Consent records	Consent items, version of the document consented to, time of consent and withdrawal	Generated when the Member gives or withdraws consent
   Subscription information (paid use only)	Subscription plan, payment store (App Store or Google Play), store transaction identifier, subscription status and period	Received from the App Store or Google Play
   Messages	Content of messages sent and received, time sent and time read (read status), message reception setting (who may message the Member), setting for message notification e-mails, and, where the Member reports a conversation, the reason and note of the report	Entered by the Member when sending messages, changing settings or making a report, or generated while the Service is used

2. The Company does not collect card numbers or other payment method information. Payments are processed by the App Store or Google Play.

3. The Company does not receive Members' Google or Apple passwords.

4. When a Member saves a photo, the photo's author can see the Member's profile (name, nickname, profile picture) and the time of saving in the "who saved" list. Only saves starting with the save on which the Member is first told this are shown in the list. Likewise, the author can see who liked the photo in the "who liked" list.

5. Messages a Member sends can be seen by the other party to the conversation. If the other party has chosen to receive message notification e-mails, the sending Member's name, the new message and part of the earlier conversation are delivered to the other party's e-mail address, but the sending Member's e-mail address is never shown to them. The Company's operators do not ordinarily read messages; they review only conversations reported by a Member, and only to handle the report (Article 13, item 7).

Article 2 Purposes of Processing

The Company processes personal information for the following purposes. If a purpose changes, the Company will take the necessary measures under applicable laws, such as obtaining separate consent.

1. Sign-up, identity confirmation, keeping Members signed in, account management and account deletion
2. Uploading, storing and displaying photos, and providing the Private Archive
3. Capture verdict (checking whether a photo was captured by a camera or scanner) and deciding whether it can be made public
4. Upload safety checks to block child sexual abuse material, sexually explicit images and gore, and meeting related legal obligations
5. AI suggestions for titles, descriptions, tags and categories, translation of comments at a Member's request, and writing the welcome message the official account sends about a new Member's first published photo
6. Community features such as profiles, follows, likes, ratings, comments and Author Grade calculation
7. Delivering messages between Members, notifying Members of new messages by push notification and e-mail, applying sending limits to prevent spam and harassment, and handling message reports
8. Showing photo location where the Member chooses to
9. Providing subscription plans, managing upload limits and checking subscription status
10. Handling infringement reports and enquiries, and preventing misuse of the Service, including restrictions on use
11. Service security, incident response, and legal obligations such as keeping access logs
12. Improving the Service, analysing errors and crashes, web app page usage statistics, and measuring advertising performance (app installs, and sign-ups and first photo uploads in the app and the web app)
13. Sending news and offers by e-mail or push notification, where the Member has consented

Article 3 Retention and Destruction

1. When a Member deletes their account, the Company destroys their personal information immediately. When a Member signs in again and deletes their account under Profile → Delete account in the app, their photos and Originals, profile, tags, follows, likes and saves, and all sign-in sessions are deleted immediately and irreversibly, and Apple sign-in tokens are revoked.

2. When a Member deletes an individual photo, the Original, Derivatives and metadata (including location) of that photo are deleted with it.

3. Notwithstanding paragraph 1, messages are kept so that the other party to the conversation can continue to see them. When a Member deletes their account, the link between that Member and their messages (the Member identifier) is removed, but the other party's conversation history remains, and the departed Member is shown to the other party as "Deleted user". When both Members in a conversation have deleted their accounts, the conversation (including its messages and report records) is deleted. However, a conversation with a report still being handled is kept until the report has been handled, and then deleted.

4. Notwithstanding paragraph 1, the following information is kept for the period shown and then destroyed.

   Information kept	Basis	Retention period
   Records of contracts or withdrawal of offers, and records of payment and supply of goods	Act on the Consumer Protection in Electronic Commerce	5 years
   Records of consumer complaints or dispute handling	Act on the Consumer Protection in Electronic Commerce	3 years
   Service access logs	Protection of Communications Secrets Act	3 months
   Pseudonymised consent records	Proof of consent	3 years
   Legally required evidence, such as photos refused by the safety check	Compliance with obligations under applicable laws	The period required by law

5. Notwithstanding paragraph 1, Google Analytics event data (app and web app) is kept by Google for 2 months and Crashlytics crash reports for 90 days, after which they are deleted.

6. Method of destruction: electronic files are deleted in a way that cannot be recovered; personal information printed on paper is shredded or incinerated.

7. Information kept under paragraph 4 is stored separately from other information and is not used for any purpose other than the one set by the relevant law.

Article 4 Provision to Third Parties

1. The Company does not provide Members' personal information to third parties, except in the case of paragraph 2, where the law specifically provides for it, or where investigative authorities or other bodies request it in accordance with the procedures and methods set by law.

2. Only for Members who have given optional consent to "Share ad measurement data" in the Android app, the Company provides personal information as follows. This provision involves an overseas transfer.

   Item	Details
   Recipient	Meta Platforms, Inc.
   Country	United States
   Purpose	Measuring the performance of the Company's ads on Facebook and Instagram (which ad led to an app install or sign-up) and optimising their delivery
   Information provided	Android advertising ID, app launch and sign-up completion events with their time, device model, OS and app version. As with any internet connection, the device's IP address is also transmitted. Names, email addresses, photos and messages are not provided
   When and how	Sent encrypted over the network from the app on the Member's device to Meta when the app is launched or sign-up is completed
   Retention	Under Meta's data policy. Once the Member withdraws consent, nothing further is provided

3. Members may decline the provision in paragraph 2, and declining does not restrict their use of the Service. Members who have consented can withdraw their consent at any time in the app under Profile → Settings → Privacy.

Article 5 Entrustment of Processing

1. The Company entrusts the following personal information processing tasks in order to provide the Service.

   Processor	Task entrusted
   Amazon Web Services, Inc.	Servers (hosting) and data storage for operating the Service, and sending e-mails through Amazon SES (verification codes, message notifications)
   OpenAI, L.L.C.	AI analysis of photos using the OpenAI API (safety check, capture verdict support, metadata suggestions) and translation of comments at a Member's request, and writing welcome messages to new Members. The Company uses OpenAI first; if it fails, the Google Gemini API processes the request instead
   Google LLC	AI analysis of photos using the Gemini API (safety check, capture verdict support, metadata suggestions) and translation of comments at a Member's request, and writing welcome messages to new Members (when the request could not be processed with the OpenAI API)
   Google LLC	Displaying maps of photo locations using Google Maps Platform: the app on the Member's device loads the map directly from Google (photos whose exact location is public, and the author's own photos with location). Searching for places and naming the location when a Member sets a photo's location themselves (Places API, Geocoding API): the Company's server sends the search text and coordinates to Google
   Google LLC	App usage statistics and crash analysis using Firebase (Google Analytics, Crashlytics), and measuring Google Ads advertising performance; web app page usage statistics and measuring Google Ads advertising performance using Google Analytics

2. These processors are located outside Korea, so details of the overseas transfer are also given in Article 6.

3. Through entrustment contracts and other means, the Company ensures that processors do not process personal information for any purpose other than the entrusted task, sets out technical and managerial safeguards, restrictions on sub-entrustment, management and supervision of processors, and liability for damages, and supervises whether processors handle personal information safely.

4. Google and Apple, which Members use to sign in, and the App Store and Google Play, which process payments, process personal information under the terms and privacy policies that Members have agreed to directly with them.

5. If the entrusted tasks or processors change, the Company will disclose this through this Privacy Policy.

Article 6 Overseas Transfer of Personal Information

1. With the Member's consent, the Company transfers personal information overseas as follows.

   Item	Amazon Web Services, Inc.	OpenAI, L.L.C. (OpenAI API)	Google LLC (Gemini API)	Google LLC (Google Maps Platform)	Google LLC (Firebase, Google Analytics)
   Country of the recipient	Company incorporated in the USA. Data is stored in the Asia Pacific (Seoul) region (ap-northeast-2, Republic of Korea)	USA	USA	USA	USA
   Items transferred	All personal information in Article 1	For each uploaded photo, a copy downscaled to 768px on the long side with metadata removed, and an EXIF summary (camera make and model, lens, focal length, aperture, shutter speed, ISO, capture time). For photos with location, the city name derived from the GPS coordinates may be sent instead of the coordinates. Comments a Member has asked to translate. To write the welcome message to a new Member: a downscaled copy of the Member's first published photo and that photo's title, description and tags (shortened if long)	For each uploaded photo, a copy downscaled to 768px on the long side with metadata removed, and an EXIF summary (camera make and model, lens, focal length, aperture, shutter speed, ISO, capture time). For photos with location, the city name derived from the GPS coordinates may be sent instead of the coordinates. Comments a Member has asked to translate. To write the welcome message to a new Member: a downscaled copy of the Member's first published photo and that photo's title, description and tags (shortened if long)	Location coordinates of the photo (rounded to 5 decimal places) and the map request. As with any internet connection, Google also receives the device's IP address and device and app information. When a Member sets a photo's location themselves, the Company's server sends the place search text, the identifier of the chosen place and the coordinates the Member picked (rounded to 5 decimal places). No photo or account information is sent	The app usage analytics information in Article 1 (app usage events, crash and error reports, app instance ID and, in the Android app only, the advertising ID) and the device model, OS and app version. The web usage analytics information in Article 1. As with any internet connection, Google also receives the device's IP address
   Purpose	Hosting the Service, storing data and sending e-mails	Safety check, capture verdict support, suggestions for titles, descriptions, tags and categories, comment translation, welcome messages to new Members	Safety check, capture verdict support, suggestions for titles, descriptions, tags and categories, comment translation, welcome messages to new Members. Used when the request could not be processed with the OpenAI API	Displaying the map on the photo detail screen; searching for places and naming the location when a Member sets a photo's location themselves	App and web app usage statistics, crash analysis and measuring advertising performance
   Time and method of transfer	Encrypted transfer over the network when the Service is used	Encrypted transfer over the network when an uploaded photo is processed or when a Member asks to translate a comment, or when the welcome message is written about 20 minutes to 48 hours after a Member first publishes a photo	Encrypted transfer over the network when an uploaded photo is processed or when a Member asks to translate a comment, or when the welcome message is written about 20 minutes to 48 hours after a Member first publishes a photo	Encrypted transfer over the network directly from the app on the Member's device to Google when the detail screen of such a photo shows the map. Encrypted transfer over the network from the Company's server to Google when a Member searches for a place or sets a photo's location	Encrypted transfer over the network from the app or browser on the device to Google while the app or web app is used
   Retention and use period	Until the Member deletes their account or the retention period in Article 3 ends	The purpose ends once the result is returned. The Company sends requests with response storage turned off. However, under its terms OpenAI may retain inputs for up to 30 days for abuse monitoring	The purpose ends once the result is returned. However, under its terms Google may retain inputs for a limited period for abuse monitoring	The purpose ends once the map is displayed. Google may process and retain this data under the Google Maps Platform terms and Google's Privacy Policy. The map SDK may temporarily cache map data on the Member's device. The Company's server caches place search and location name results in server memory for up to 24 hours	Google Analytics event data (app and web app) is deleted after 2 months and Crashlytics crash reports after 90 days (Article 3, paragraph 5)

2. The Company uses the OpenAI API and the paid tier of the Gemini API. The Company does not use Members' photos or comments to train AI models, and neither does OpenAI under the OpenAI API terms nor Google under the paid-tier terms.

3. Members may refuse the overseas transfer. However, because the transfer is essential to providing the Service, a person who refuses cannot sign up for or use the Service. A Member who has already signed up can stop further transfers by deleting their account. Members using the Android app can delete or reset the advertising ID in the device settings (Article 10).

4. The provision to Meta Platforms, Inc. (United States) under Article 4(2) is an overseas transfer. The recipient, country, items, purpose, timing and method, and retention period are as set out in the table in Article 4(2). This transfer applies only to Members who give optional consent; declining or withdrawing consent does not restrict use of the Service.

Article 7 Automated Decisions

1. The Company decides automatically, based on metadata (EXIF, XMP, C2PA) and AI analysis, whether an uploaded photo can be made public or must stay in the Private Archive. Only photos judged to have been captured by a camera or scanner can be made public. If the evidence is insufficient, the photo stays private and the Member is told the result and the reason.
2. Refusing an upload because the safety check identifies it as prohibited content is also done automatically.
3. Under Article 37-2 of the Korean Personal Information Protection Act and Article 22 of the EU General Data Protection Regulation (GDPR), Members may ask for an explanation of an automated decision, object to it and request human review. Please send the photo concerned and your request to support@photoz.co.kr. The Company will respond within the period set by applicable laws.
4. For details, please see the "Photoz AI Notice".

Article 8 Members' Rights and How to Exercise Them

1. Members may exercise the following rights at any time:
   • request access to their personal information;
   • request correction or deletion of their personal information;
   • request suspension of processing;
   • withdraw consent;
   • ask for an explanation of, and object to, automated decisions (Article 7);
   • for EEA residents, request data portability and object to processing.
2. Members can edit or delete their profile directly in the app, turn off location display for a photo or delete photos, and delete their account under Profile → Delete account. Consent to news and offers can be turned off at any time in the app settings. Who may send messages to the Member and whether message notification e-mails are received can be changed in the app settings, and message notification e-mails can also be turned off with the unsubscribe link in each e-mail.
3. Other requests can be sent to support@photoz.co.kr. After confirming the requester's identity, the Company will act within the period set by applicable laws and report the outcome.
4. Rights may be exercised through a representative, who must submit a power of attorney.
5. If a Member withdraws a required consent (collection and use of personal information, AI photo analysis, overseas transfer), the Service can no longer be provided, so the withdrawal is handled as an account deletion.
6. Information that must be kept by law may be kept for the required period despite a deletion request, and the Company will explain why.

Article 9 Children Under 14

The Company does not accept sign-ups from children under 14 and does not collect their personal information. EEA residents must be at or above the age of digital consent set by their country (13 to 16). If the Company learns that it has collected personal information from a Member who does not meet this requirement, it will destroy that information without delay.

Article 10 Automatic Collection Tools

1. The Android app uses the device's advertising ID only to measure advertising performance (which ad led to an app install or sign-up), and not for personalised advertising. Members can delete or reset the advertising ID in the Android settings (Settings > Google > Ads, or Settings > Privacy > Ads).
2. The iOS app does not use the advertising identifier (IDFA) and does not track Members across apps or websites owned by other companies. It therefore does not ask for App Tracking Transparency permission.
3. Both apps use Firebase (Google Analytics, Crashlytics) to collect app usage statistics and crash information as described in Articles 1, 5 and 6.
4. The apps store the credentials needed to keep the Member signed in in the device's secure storage (iOS Keychain, Android Keystore, Mac Keychain and Windows Credential Manager for the Lightroom plugin).
5. Only when a Member has consented to the provision in Article 4(2) does the Android app use Meta's SDK to send that information to Meta. If the Member has not consented or has withdrawn consent, Meta's SDK sends no information. Meta processes the information it receives under its own privacy policy.
6. The web app (photoz.co.kr/app) uses essential cookies to keep users signed in and to remember language and theme settings, and Google Analytics cookies (analytics cookies whose names begin with _ga and ad measurement cookies whose names begin with _gcl). Analytics cookies are used to understand which pages are used and how much, and ad measurement cookies are used only to check whether a visitor signed up or uploaded a first photo after seeing an ad the Company ran on Google; neither is used for personalised advertising or remarketing (Google signals and ad personalisation are not used). For visitors from the EEA, the UK or Switzerland, these cookies are used only if they allow them. Visitors can turn off analytics and ad measurement cookies at any time under "Cookie settings" at the bottom of the web app, and can also refuse cookies or delete stored cookies in their browser settings. However, refusing essential cookies makes it impossible to sign in.

Article 11 News and Offers

The Company sends news and offers by e-mail or push notification only if the Member has given optional consent. Nothing is sent between 21:00 and 08:00 Korea Standard Time, and Members can turn these messages off at any time in the app settings.

Article 12 Photo Location

GPS location information in photos is kept only on the server and is not shown publicly by default. Separate consent is requested when the Member first turns on location display for a photo, and location is shown only at the precision the Member chooses for each photo (exact, neighbourhood or city). Members can turn location display off at any time. For photos whose exact location is public (and for authors viewing their own photos), the app on the Member's device loads the map directly from Google, so the coordinates, together with the device's IP address and device and app information, are sent to Google (Article 6). Members can set the location of their own photos that have no location by picking a place on a map. In that case, the search text the Member enters and the coordinates the Member picks are sent from the Company's server to Google to find the place and name the location (Article 6). A location set this way is stored as the photo's location, and once the Member agrees in the confirmation dialog, the photo's location becomes public at exact precision. Members can change or remove a location they set themselves, but cannot change the location recorded by the camera (EXIF).

Article 13 Security Measures

The Company takes the following measures to process personal information securely.

1. Encryption in transit: all communication between the apps and the servers, and between the servers and processors, is encrypted.
2. Protection of credentials: refresh tokens used to keep Members signed in are stored on the server only as hashes, are replaced each time they are used, and sessions are revoked if misuse is suspected.
3. Access control: access to personal information processing systems is limited to the minimum number of staff who need it for their work.
4. Protection of Originals: Originals are provided only to the Member who uploaded them, who can download their own Original through a signed URL valid for a short time. Other users receive only watermarked Derivatives through signed URLs valid for a short time. The apps block screenshots and screen recording on photo screens.
5. Evidence storage: photos refused by the safety check are kept, with restricted access, in separate storage that uses its own encryption key.
6. Minimising data sent to AI: only downscaled copies with metadata removed, not Originals, are sent for AI analysis.
7. Restricted access to messages: operators do not ordinarily read messages, and review a conversation only when a Member has reported it and only to handle the report. The report list shows only a short preview of the reported message, and each time an operator opens the full conversation, the operator and the time are logged.

Article 14 Chief Privacy Officer

The Company has appointed a Chief Privacy Officer who is responsible for personal information processing and for handling related complaints and remedies.

• Chief Privacy Officer: Yonghee Lee (CEO)
• E-mail: support@photoz.co.kr
• Phone: +82-10-5213-0417
• Address: Keyfred Inc., 474-7 Soraebi-ro, Sudong-myeon, Namyangju-si, Gyeonggi-do, Republic of Korea

Article 15 Remedies

Members may apply to the following bodies for dispute resolution or advice regarding infringement of their personal information.

• Personal Information Dispute Mediation Committee: 1833-6972, www.kopico.go.kr
• Personal Information Infringement Report Center (Korea Internet & Security Agency): 118, privacy.kisa.or.kr
• Supreme Prosecutors' Office: 1301, www.spo.go.kr
• Korean National Police Agency, Cyber Investigation Bureau: 182, ecrm.police.go.kr

EEA residents have the right to lodge a complaint with the data protection supervisory authority of the Member State where they live or work or where the alleged infringement took place.

Article 16 Additional Information for EEA Residents

The Company processes the personal information of EEA residents on the following legal bases:

• Performance of a contract: account, photo storage, capture verdict, community features, messages between Members, subscriptions;
• Consent: AI photo analysis, overseas transfer, news and offers, photo location display, web app analytics and ad measurement cookies;
• Legal obligation: keeping records required by law, keeping evidence of prohibited content;
• Legitimate interests: service security and prevention of misuse, including preventing spam and harassment in messages and handling message reports.

Where processing is based on consent, Members may withdraw their consent at any time. Withdrawal does not affect the lawfulness of processing carried out before it.

Article 17 Language

This Privacy Policy is provided in Korean, English, Japanese, Chinese (Simplified), Spanish, Portuguese, French and German. If the language versions conflict, the Korean version prevails.

Article 18 Changes to This Privacy Policy

If this Privacy Policy is added to, deleted from or modified, the Company will announce the change in the Service at least 7 days before the effective date. For significant changes affecting Members' rights, such as changes to the items collected, purposes of use or provision to third parties, the Company will announce them at least 30 days before the effective date and, where required by applicable laws, will ask for consent again.

Addendum

1. This Privacy Policy takes effect on November 17, 2026.
2. The previous Privacy Policy (version 1.2) applies until November 16, 2026.
3. Changes in version 1.2: for app usage analytics and advertising performance measurement using Firebase (Google Analytics, Crashlytics), the items processed (Article 1), purposes of processing (Article 2), retention (Article 3), entrusted tasks (Article 5) and overseas transfer (Article 6) were added, and the automatic collection tools (Article 10) were revised regarding the use of the advertising ID.
4. Changes in version 1.2: for setting photo locations manually (geotagging), the items collected (Article 1), entrusted tasks (Article 5), items and purpose of overseas transfer (Article 6) and photo location (Article 12) were changed.
5. Changes in version 1.2: OpenAI was added as a processor for AI analysis of photos and comment translation, and comment translation was added to the purposes of processing, entrusted tasks and items of overseas transfer (Articles 2, 5 and 6).
6. Changes in version 1.3: the provision of personal information to Meta Platforms, Inc. for advertising performance measurement, only for Members who give optional consent in the Android app, was added (Articles 4, 6 and 10).
7. Changes in version 1.3 (added on October 18, 2026): writing, with AI, the welcome message that the official account sends about a new Member's first published photo was added to the purposes of processing, the outsourced tasks and the items, purpose and timing of the overseas transfer (Articles 2, 5 and 6).
8. Changes in version 1.3 (added on October 24, 2026): Google Analytics page usage statistics and cookies in the web app were added to the items processed, the purposes of processing, the retention periods, the outsourced tasks, the overseas transfer, the automatic collection tools and the legal bases for EEA residents (Articles 1, 2, 3, 5, 6, 10 and 16). These changes apply from October 24, 2026, and were added to the previous policy (version 1.2) on the same day.
9. Changes in version 1.3 (added on October 24, 2026): to measure sign-ups and first photo uploads by visitors who arrive at the web app through Google ads, the items processed, the purposes of processing, the outsourced tasks, the automatic collection tools (ad measurement cookies) and the legal bases for EEA residents were revised (Articles 1, 2, 5, 10 and 16). These changes apply from October 24, 2026, and were added to the previous policy (version 1.2) on the same day.