Privacy Policy

Effective Date: March 4, 2026 | Version 2.2

Rchemist Co., Ltd. (hereinafter "Company") establishes and discloses this Privacy Policy to protect users' personal information and to address related grievances in accordance with the Personal Information Protection Act and other relevant laws of the Republic of Korea.

Article 1 (Information Collected)

The Company does not collect personally identifiable information such as email addresses, real names, phone numbers, or addresses. However, the following service usage information is collected for service provision:

Category	Items Collected	Purpose of Collection
Account Info	Unique code (8-digit, auto-generated), Nickname (user-chosen), Password (encrypted)	Account identification, Login, Service provision
Profile Settings	Avatar (animal/color/accessory), Frame, Featured badges	Profile customization
Learning Activity	Learning records, Scores, Combos, Streaks, Daily challenge records, Mission records	Learning progress management, Statistics
Social	Friend list, Friend requests, Group/Guild info, Chat messages, Guardian-child connection, Activity feed	Social features
Competition/Ranking	Duel match records, League info (tier/weekly score), Raid participation records, Personal raid statistics (total damage/sessions/MVP count/boss kills, etc.), Badges/Achievements	Competition features, Rankings
Economy/Currency	Dragon Coin balance, Total earned/spent amount, Inventory (item type/quantity/purchase date)	Virtual currency management, Shop usage
Stickers	Owned sticker packs (Basic/Raid/Cheer), Sticker sending history	Chat sticker feature
Challenge Settings	Weekly challenge difficulty (digit count, operation types, preset name, week)	Challenge customization
App Settings/Activity	Focus mode settings, Last access time, Archive (locally stored completion records)	Preferences, Access status, Record keeping
Notifications	Notification history, Notification settings, Quiet hours settings, FCM push token	Notification delivery
Device Info	Device identifier, App version, OS information, Access logs	Service improvement, Error analysis
Customer Support	Inquiry title/content	Inquiry processing

Collection Methods

• Automatic guest account creation upon first app launch
• Direct input when user sets up code/password
• Automatic generation and collection during service use
• Direct input during customer inquiries

Article 2 (Purpose of Information Processing)

The Company processes collected service usage information for the following purposes:

Purpose	Details
Account Management	Account identification, Login processing, Prevention of fraudulent use
Service Provision	Learning features, Learning progress recording, Statistics, Chat, Duel matches, Missions, Daily challenges
Social Features	Friend and group features, Guardian-child connection, Activity feed
Competition/Ranking	League system, Raids, Badge/Achievement management
Notification Delivery	Push notifications, Quiet hours application
Customer Support	Receiving and processing customer inquiries, Delivering announcements
Virtual Currency/Shop	Virtual currency (Dragon Coin) management, Shop item purchase and inventory, Stickers
Service Improvement	Service usage statistics analysis, Error analysis, New service development

Article 3 (Retention and Use Period)

1. The Company destroys information without delay after the purpose of collection and use has been achieved.
2. Upon account deletion: Immediate destruction
3. Notification data: Automatically deleted after 30 days
4. Chat messages: Deleted upon account deletion
5. Archive data: Stored locally on device, deleted upon app deletion or account withdrawal
6. Virtual currency/Inventory: Immediately deleted upon withdrawal (non-refundable)
7. Retention periods under relevant laws:

   Items Retained	Retention Period	Legal Basis
   Records of contracts or subscription withdrawal	5 years	Act on Consumer Protection in Electronic Commerce
   Records of payment and supply of goods	5 years	Act on Consumer Protection in Electronic Commerce
   Records of consumer complaints or dispute resolution	3 years	Act on Consumer Protection in Electronic Commerce
   Service visit records	3 months	Protection of Communications Secrets Act

Article 4 (Provision to Third Parties)

The Company does not provide users' information to third parties in principle. However, the following are exceptions:

• When the user has given prior consent
• When required by law or requested by investigative agencies in accordance with legally prescribed procedures

Article 5 (Entrustment of Information Processing)

The Company entrusts information processing as follows for smooth service provision:

Entrusted Party	Entrusted Tasks	Retention Period
Google LLC (Firebase)	Cloud server operation, Authentication, Database, Analytics, Push notifications	Until termination of entrustment contract or account deletion

Article 6 (International Transfer of Information)

Item	Details
Recipient	Google LLC
Country of Transfer	United States
Transfer Date and Method	Real-time transmission over network during service use
Information Transferred	Nickname, Learning data, Device information, Chat messages, Social relationship data, Competition/Ranking data, Virtual currency/Inventory data, Sticker ownership information
Purpose of Recipient's Use	Cloud service provision (Data storage, Authentication, Analytics)
Retention and Use Period	Until account deletion or termination of entrustment contract

For more details about Google's personal information processing, please refer to Google's Privacy Policy.

Article 7 (Destruction of Information)

1. The Company destroys information without delay when it becomes unnecessary due to expiration of the retention period or achievement of processing purpose.
2. Destruction Methods:
   • Electronic files: Permanent deletion using methods that prevent recovery and reproduction
   • Paper documents: Shredding or incineration

Article 8 (Children's Privacy Protection - COPPA)

1. The Company complies with the U.S. Children's Online Privacy Protection Act (COPPA).
2. The Company does not collect personally identifiable information such as email addresses, real names, or phone numbers from any users, including children under 13, thereby minimizing the risk to children's privacy.
3. The Company collects only the minimum service usage information reasonably necessary for service provision from children.
4. Guardians can monitor their children's learning activities and service usage through the guardian-child connection feature.
5. Guardians may request access, correction, deletion, or suspension of processing of their child's service usage information by contacting the Privacy Protection Officer.
6. The Company does not provide children's service usage information to third parties or use it for marketing purposes.

Article 9 (Rights and Obligations of Users and Exercise Methods)

Users (or guardians) may exercise the following rights regarding service usage information:

1. Right to Access: Access to current status of service usage information processing
2. Right to Rectification: Correction of errors in information
3. Right to Erasure: Deletion of service usage information
4. Right to Restriction of Processing: Suspension of information processing

Exercise Methods: Requests can be made through the in-app settings menu or customer support.

The Company will take action within 10 days of receiving a request and notify the result.

Article 10 (Measures to Ensure Security of Information)

The Company takes the following measures to ensure the security of service usage information:

1. Administrative Measures: Establishment and implementation of internal management plan, Minimization and training of personnel handling information
2. Technical Measures:
   • Encrypted storage of passwords
   • TLS/SSL encryption during data transmission
   • Installation and periodic update and inspection of security programs against hacking
   • Restriction and management of access rights
3. Physical Measures: Access control to data storage facilities

Article 11 (Privacy Protection Officer)

Users may direct all inquiries, complaints, and requests for relief regarding personal information protection to the Privacy Protection Officer. The Company will respond and process inquiries without delay.

Article 12 (Remedies for Rights Infringement)

Users may apply for dispute resolution or consultation with the following organizations for relief from personal information infringement:

Article 13 (Changes to the Privacy Policy)

1. This Privacy Policy may be amended due to changes in laws, policies, or security technology.
2. When amending the Privacy Policy, the Company will provide notice at least 7 days in advance of the effective date through in-app announcements or push notifications.
3. For changes unfavorable to users, notice will be provided 30 days in advance.

Addendum
This Privacy Policy is effective from March 4, 2026.

Revision History
Version 1.0 (January 1, 2025): Initial establishment
Version 2.0 (February 8, 2026): Reflected no personal information collection policy, Removed Google/Apple social login, Complete rewrite of collected items
Version 2.1 (February 24, 2026): Refined member/guest terminology, Relaxed age restriction, Added virtual currency/shop/sticker/weekly challenge/archive features
Version 2.2 (March 4, 2026): Added COPPA (Children's Online Privacy Protection Act) compliance provisions, Removed parental consent requirement for children under 14

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