Vivian Privacy Policy

1Information We Collect

Required items are necessary for the related feature. Optional items can be declined without affecting your ability to use the Service. Sensitive denotes health information under PIPA Art. 23 / Enforcement Decree Art. 18, collected only with a separate, explicit consent.

About a compatibility partner's (third party's) information

About facial photos / biometric data

2A note on location data

3How we obtain consent

• During onboarding, you must separately check "Agree to the Terms of Service" (required) and "Agree to the Privacy Policy" (required) — you cannot proceed to enter birth information until you agree.
• Marketing consent is a separately checked, optional item; declining it does not limit sign-up or use of the Service.
• Health data (sleep/steps) integration requires a separate screen and separate, explicit consent apart from the required consents above; no health data is read before this consent. You can withdraw it anytime in Settings.
• Each consent item links to the full text, and the timestamp and policy version of your consent are recorded.

4Purposes of Processing

• Account identification, session management, fraud prevention
• Calculating your saju (natal chart, major/annual luck cycles) and delivering saju-based content
• Providing AI chat counseling (via the Anthropic Claude API — combining saju, test, and health data as context)
• Scoring the 16 psychological tests and reflecting results into counseling context
• (With separate consent) Using sleep/step data for the personalized "Today's Flow" sleep card and counseling context — never for advertising purposes
• Delivering tarot card draw results
• Calculating compatibility scores and generating reports
• Managing Charm balance/earn/spend, processing subscriptions/IAP and refunds
• Serving rewarded ads (AdMob) to grant free Charm, and measuring ad performance
• Service analytics, error handling, and customer support
• (With consent) Sending marketing communications

5Retention & Deletion

• Default: Deleted without delay upon account deletion, with complete removal from backups within 30 days.
• Chat content / counseling context: Retained for the life of your account; deleted upon account deletion.
• Health data (sleep/steps): Deleted when you disable health integration or delete your account; stored under separate access controls and never combined with advertising identifiers/targeting.
• Test results, tarot history, compatibility reports: Retained for the life of your account; deleted upon deletion.
• Statutory retention exceptions under Korea's Act on Consumer Protection in Electronic Commerce apply even after account deletion:
  • Records of contracts/withdrawal of subscription: 5 years
  • Records of payment and supply of goods: 5 years
  • Records of consumer complaints/dispute resolution: 3 years
  • Records of labeling/advertising: 6 months
  • Service access (connection) logs under the Protection of Communications Secrets Act: 3 months

6Cross-Border Transfer of Personal Data

Cross-border transfer detail (Anthropic — AI counseling)

• Recipient: Anthropic, PBC (United States)
• Items: Full text of your questions and AI replies during chat counseling; counseling context snapshot (natal chart/luck-cycle summary, test result summary, health data summary [consenting users only], concern tags); partner birth information for compatibility reports
• Country: United States
• Timing/method: Sent in real time over encrypted (HTTPS) connections each time you request AI chat counseling or a deep/compatibility report
• Purpose/retention: Processed solely to generate AI responses. We understand Anthropic retains API request data briefly per its own API data-retention policy before deletion (exact period: [verify against Anthropic's current API policy — expert confirmation needed]). Chat text stored on our own servers (Supabase) is retained per §5 above.
• How to opt out: You may decline this cross-border transfer. Doing so will restrict AI chat counseling, deep saju reports, and compatibility reports (on-device features such as viewing your saju chart, taking psychological tests, and drawing the free daily tarot card remain available). This consent is bundled into the required sign-up consents; you can withdraw it afterward in Settings > Manage Consent, which disables the above features. Deleting your account also deletes data stored on Supabase per §5.

You may likewise decline transfers to Google (login/AdMob), Apple (login), and RevenueCat, which may restrict the corresponding social login method, rewarded-ad Charm earning, or in-app purchases. You can opt out of personalized advertising specifically via device settings (iOS: disable tracking in App Tracking Transparency / Android: delete your advertising ID) or at Google Ads Settings.

7Third-Party Disclosure & Processors

We do not sell personal data or share it with third parties for commercial purposes. We engage the processors listed in §6 to help operate the Service; they may not use your data beyond the scope of their engagement. In-app purchases are processed directly by Apple App Store / Google Play — we never hold your payment card details.

8Special Rules for Health Data (Sensitive Information)

9Device Permissions

We never deny access to the Service on account of declining an optional permission.

10Data Stored Only On Your Device

Your computed saju chart is also cached locally for speed; it is removed if you clear the app's data. The authoritative copy on our server (Supabase) follows the retention periods in §5.

11Your Rights

• You may request access, correction, deletion, or suspension of processing of your personal data at any time, and may withdraw consent.
• You can delete your account directly from the app's Settings screen.
• Contact us below to exercise these rights; we act within the period required by law (in principle without delay, no later than 10 days).
• Parents/legal guardians may exercise these rights on behalf of a child under 14.

12Security Measures

• HTTPS encryption in transit throughout
• Anthropic/Supabase API keys and other secrets live only in server-side (Edge Function) environment variables — never in the client app
• Charm spend/refund operations run only as server-side atomic transactions (client cannot forge balances)
• Row-Level Security (RLS) on every database table — you can only read your own data
• Separate access controls for sensitive data such as health information

13Children Under 14

14Artificial Intelligence Notice

Counseling replies, Today's Flow narratives, and compatibility/deep reports are generated by a large language model (Anthropic Claude), grounded in saju (myeongli) interpretation and AI analysis, for reference purposes only — they do not substitute for medical, legal, or financial advice. A persistent disclosure banner is shown at the bottom of the chat screen. If self-harm/suicide risk signals are detected, the app replaces counseling with safety-resource guidance (Korea: 1577-0199, 24/7; U.S.: 988).

15Data Protection Officer

16Remedies for Rights Infringement (Korea)

• Personal Information Dispute Mediation Committee (1833-6972, www.kopico.go.kr)
• Personal Information Infringement Report Center (118, privacy.kisa.or.kr)
• Supreme Prosecutors' Office Cyber Crime Investigation Division (1301, www.spo.go.kr)
• National Police Agency Cyber Bureau (182, ecrm.cyber.go.kr)

17Changes to this Policy

We may revise this Policy to reflect legal or service changes. Material changes will be announced in-app or at least 7 days in advance.