II. Privacy Notice
Document version: 1.0 candidate
Effective date: October 13, 2026
Summary of this notice. You should read it in full, but here is what you most need to know.
- Only the data needed for registration, records and payment is collected. Phone numbers, advertising identifiers and address books are not collected.
- We record which screens and features you use. These usage records help us improve the app. They never contain anything you type, such as questions, notes or messages, and they are deleted with your account.
- Ads are not personalized with your data. No tracking SDK, cookies or web views are used either.
- There are four external processors. OpenAI (AI questions and automatic review), Google (login, push, error reports, performance monitoring), Apple (login, payment, weather), Amazon Web Services (video storage, backups). None is permitted to train models on your data.
- Deleting your account ends use immediately and data is deleted within 7 days. Backups are kept separately, and deletion requests are applied again on any restore.
- Exercise your rights directly in the app or at info@maruna.ai.
1. Controller and Basic Principles
The controller of personal data for ProTips is 주식회사 마루나에이아이. Personal data is processed to the extent necessary for the specific purposes and legal bases below. Reading this notice or using the service is not consent to every optional processing.
Where this notice and the contract with the member differ, the provision more favorable to the member applies under the Personal Information Protection Act.
The service is for persons aged 14 or older. If a registration attempt by a person under 14 is detected, the process stops and unnecessary information already processed is destroyed without delay. A legal representative or lawful agent may submit rights requests through the routes in Sections 6 and 9.
2. Items, Purposes and Legal Bases
The table below describes the scope of processing per feature. If an optional feature is not used, information solely for that feature is not required. Where the same information serves several purposes, the basis and retention for each purpose are distinguished.
| Category | Items | Purpose and source | Legal basis | Retention |
|---|---|---|---|---|
| Account and login | Sign in with Apple: Apple user identifier, email (including a private relay address), name. Google sign-in: Google user identifier, email, name, profile picture. The account identifier issued by the Company and login session information | Registration, login and account protection. Received from the login provider the member chose. | Processing necessary to form and perform the contract. The identifier and email are required; name and profile picture are used only as initial profile values to the extent the provider supplies them. | Deleted at account deletion. Legal retention and dispute records follow Section 5. |
| Age verification | Date of birth and the age calculated from it | Blocking registration under 14 and checking statutory requirements for minors. Entered by the member at registration. | Legal obligation (verification of children under 14) and contract performance | Deleted at account deletion. A date of birth showing the person is under 14 is not stored. |
| Profile | Nickname, username, profile image, bio, email, time zone, home course, visibility settings | Profile display and application of the visibility settings the member chose | Contract performance for the chosen features | Deleted when the member edits or deletes it, or at account deletion |
| Golf records | Round, course, hole, shot and putt records, scorecards and notes, scorecard note images, weather data for the round day, the member's golf bag, recently selected courses and favourite course settings | Storing, viewing and editing records and the statistics and analysis the member requested | Contract performance for the requested service | Deleted directly by the member or at account deletion. Residual scope of shared rounds follows Section 5. |
| Posts and videos | Post text, swing videos and images, comments, the location tag the member chose (coordinates and place name), visibility | Posting and sharing content the member chose | Contract performance for the chosen features. A location tag is processed only when the member selects it. | Deleted by the member or at account deletion |
| Friends and messages | Friend relationships, block and mute lists, conversation participants, message text and image attachments, sent, received and read status | Friends, spectating and messaging features, and handling of legitimate reports | Contract performance. Additional retention of report-investigation material follows the report-record rule in Section 5. | Kept for the life of the account unless the member deletes it. When the author deletes their account, the author's messages are deleted from the counterpart's conversation as well. |
| AI questions | The member's question, the record summary needed to answer, conversation gist, answer, the member's rating, items saved for the AI to remember | Interpretation of records and answers the member requested, and continuing earlier conversations | Contract performance for the requested service | Questions and answers are deleted automatically 365 days after creation. Memory items are deleted on their own expiry dates. Deleted immediately at account deletion. |
| Automatic review | Text of nicknames, usernames, comments and posts | Automatic review for prohibited content | Contract performance and legitimate interest in protecting other members | Only the review result is kept with the content. Retention by the external AI provider follows Section 4. |
| Payment and subscription verification | Store, product identifier, subscription state, start date, expiry date and auto-renewal flag, store transaction link identifier, one-way hash of verification material, store event identifier | Confirming subscription entitlement, restoring purchases, handling refunds and disputes. Original receipts and payment-method data are held by the store and not stored by the Company. | Contract performance and retention duties under the E-commerce Act | Kept for the life of the account for subscription management. Contract and payment records are kept separately for 5 years. |
| Marketing messages (optional) | Whether consent was given and the time of consent or withdrawal | Push and email announcements of new features, events and partner offers. Sent only to members who opted in, not between 9 p.m. and 8 a.m. the next day without separate consent, with an opt-out shown in every message. Consent is re-confirmed every 2 years. | The member's optional consent. Declining does not restrict service use. | Deleted on withdrawal of consent or at account deletion |
| Customer support and reports | Inquiry text, the screen it was sent from, attached images, app version and platform. Report target, reason, detail and the IP address at the time of the report. The reason chosen at account deletion | Responding to inquiries, handling reports, exercise of statutory rights, prevention of false reports | Contract performance or legal obligation | Consumer complaint and dispute records for 3 years. Other inquiry and report records for 3 years after resolution. |
| Usage records | Time spent on each screen (when it was opened and closed), when the app was brought back to the foreground, feature events (the event name, the screen or route it came from, fixed values such as the tab or plan chosen, and when it happened), campaign details from the link that opened the app, app version and platform | Improving the service and understanding how it is used. Generated automatically as the member uses the app. Text the member enters, such as questions, notes and messages, is not included. | Legitimate interest in improving the service | Deleted at account deletion |
| Stability and security | Login events (IP address, time, app, device and language information), web-server access logs (IP address, time), error reports (device, OS, app version, error information, the screens opened and features used just before the error), app performance measurements (app start time; for requests to our servers, the path pattern, response time and response code; device, OS and app version), app integrity token, push notification token and device identifier (including the token for the in-round Live Activity display) | Authentication protection, failure and performance analysis, response to unauthorized access, notification delivery | Processing necessary for the contract and legitimate interest in service safety | Login records and push tokens are deleted at account deletion. Web-server access logs and error records are deleted after 90 days, storage error reports after 180 days. Performance measurements are not linked to the account and follow Section 4. |
| Current location | Device coordinates at the time of a nearby-course search or weather lookup | Nearby-course search and round-day weather the member requested | Consent under the Location Information Act and provision of the requested feature | The Company does not store the coordinates; only the search result and forecast are returned to the member. Details in Part IV. |
Payment-method data such as card numbers is processed by the store and is not among the items ProTips collects directly. Mobile phone numbers are not collected. Information converted to a hash or account identifier is still managed as personal data where it can be linked to an individual.
The Company places ads in the service but does not perform personalized advertising using members' records or behaviour, address-book upload, collection of advertising identifiers, or model training distinct from providing the requested features. If such processing, including personalized advertising, is introduced in future, the actual items, purpose, retention period and how to refuse are announced first and the necessary consent is obtained separately.
3. Disclosure and Provision to Third Parties
You control visibility. The visibility of profiles, content and records follows the settings chosen in each feature and the permitted viewing scope. Guardians, coaches or payers are not automatically granted separate viewing rights.
What you send goes to the recipient. Information the member sends as a message or shares with a specific counterpart is delivered to that recipient. Public disclosure and sharing with a specific counterpart are explained separately.
Provision to third parties needs a basis and notice. Where the Company provides personal data to a third party that uses it for its own purposes, the recipient, purpose, items, retention period, right to refuse and its effect are explained and a lawful basis is secured. A mere partnership or affiliation does not permit provision.
There is no regular provision to third parties. The Company performs no regular provision to third parties. Store payments are independent transactions between the member and Apple or Google, not a provision of personal data by the Company.
Agency requests are checked first. Requests from courts, investigative agencies and similar bodies are handled to the necessary extent after their authority and legal basis are verified. Not every agency request is a basis for providing personal data.
4. Processors and Overseas Transfers
Processors performing the Company's work process personal data within the purpose and scope set by contract. The Company supervises their secure processing and any sub-processing. A store's independent payment business is distinct from the Company's processing entrustment. The service's main servers and error-collection system are operated directly by the Company in the Republic of Korea.
| Work | Provider | Relationship and scope | Country and retention |
|---|---|---|---|
| External AI processing | OpenAI (United States) | Processor. Processes the question and record summary needed for AI answers, and text subject to automatic review, together with a pseudonymous identifier. | United States. Not used for model training; retained for up to 30 days for abuse monitoring, then deleted. |
| External login, push notifications, error reports, performance monitoring | Google LLC (United States) | Google sign-in is authentication by an independent provider. Firebase push delivery (relayed to Apple's push service on iOS), error reporting, app integrity checks and app performance monitoring (Firebase Performance Monitoring) are entrusted processing. | United States. Push tokens, error reports and performance measurements follow Google's published retention periods. |
| External login, store transactions, weather forecast | Apple Inc. (United States) | Sign in with Apple is authentication by an independent provider. App Store payment is an independent transaction, and the Company receives only the subscription verification result. Weather forecasts (WeatherKit) are entrusted processing: the Company's server sends the round coordinates and receives the forecast; no account identifier is sent and the Company does not store the coordinates. | United States. Follows Apple's published retention periods. |
| Video and image storage and delivery, database backups | Amazon Web Services (United States entity) | Processor. Storage and delivery of video and image files, and storage of database backup copies. | Storage region Sydney, Australia; backup replica in Seoul, Republic of Korea. Contract term and the backup retention in Section 5. |
Overseas transfer includes not only overseas storage but also access from abroad and entrusted processing abroad. The details of each transfer are provided as follows.
| Required item | Detail |
|---|---|
| Recipient and contact | OpenAI (privacy.openai.com), Google LLC (support.google.com/policies), Apple Inc. (apple.com/legal/privacy/contact), Amazon Web Services (aws.amazon.com/privacy) |
| Country, timing and method | United States, Australia, Republic of Korea. Transmitted and stored over the network at the time the feature is used. |
| Items transferred | OpenAI: question, record summary, text under review, pseudonymous identifier. Google: login identification data, push token and device information, error reports, app performance measurements. Apple: login identification data, subscription verification result, weather lookup coordinates. Amazon Web Services: video and image files, database backups. |
| Purpose and retention | The purpose and period per work item in the table above |
| Legal basis for the transfer | Disclosure in this notice under Article 28-8 paragraph 1 item 3 of the Personal Information Protection Act (entrusted processing and storage necessary to form and perform the contract with the data subject) |
| How to refuse and its effect | Not using the feature, denying the device permission, or contacting info@maruna.ai. Login and file storage are essential to the service, so refusal restricts registration or the feature concerned. For other features, only that feature is restricted. |
The basis for an overseas transfer is determined per processing activity. Entrusted processing and storage necessary for contract performance that meets the statutory requirements is not treated the same as a transfer based on separate consent. A transfer that requires the member's separate consent is not performed before consent is obtained.
5. Retention and Destruction
Data is destroyed as soon as it is no longer needed. Personal data that is no longer needed because its purpose is achieved or its retention period has ended is destroyed without delay. Indefinite retention for operational convenience without a defined ground is not practiced.
Legal retention keeps only the required items and periods, separately. Where retention is required by law, only the items and period the law requires are kept separately from other data. The periods below do not mean blanket retention of all personal data.
| Records concerned | Basis | Period |
|---|---|---|
| Records of contracts or withdrawals, and records of consent to terms and notices | E-commerce Act and its Enforcement Decree | 5 years |
| Records of payment and supply of goods or services | E-commerce Act and its Enforcement Decree | 5 years |
| Records of consumer complaints or dispute handling | E-commerce Act and its Enforcement Decree | 3 years |
| Records of display and advertising | E-commerce Act and its Enforcement Decree | 6 months |
Logs have different periods by type. Login records are kept for the life of the account for account protection and deleted at account deletion. Usage records are likewise kept until account deletion. Web-server access logs and error records are deleted after 90 days, storage error reports after 180 days. The retention period under the Protection of Communications Secrets Act is not applied wholesale to other technical logs.
On deletion, end of use and destruction are handled separately. At account deletion, the end of account use and the actual destruction of data are handled separately. The rules for ordinary data, processor data and backups are as follows.
| Data class | Rule |
|---|---|
| Ordinary account, profile and personal records | Account use ends immediately at deletion and destruction begins. Destruction is targeted to start within 24 hours and is completed within 7 days. This covers the profile, login link, round records, posts and videos, comments, messages, AI question history, friend relationships, push tokens, login records and usage records. |
| Shared posts, shared rounds and recipients' messages | Messages and comments written by the deleted member are deleted from counterparts' conversations and posts as well. The scores and records of other participants in shared rounds remain theirs, and the deleted member's identifying information such as name and profile is removed. |
| Data held by external processors | Deletion is requested immediately at account deletion and completion is confirmed within 30 days. Abuse-monitoring retention by the external AI provider expires under that provider's period. |
| Backups | Backup copies are kept separately from the service in an unalterable form with restricted access, and are not queried in ordinary service or used for new purposes. Recent recovery copies expire after 35 days and long-term copies after at most 3 years. If a backup is restored, deletion requests already completed are applied again. |
| Re-registration restriction | Only a one-way hash of the deleted login identifier is stored separately. Its purpose is to restrict re-registration with the same account for 100 days after deletion, and it is deleted automatically after 100 days. Email, name and device information are not included. Objections can be raised at info@maruna.ai. |
| Sanction records of restricted accounts | Only for accounts that received a sanction such as termination, the reason, the identifier of the content concerned and the time of the measure are kept separately for 1 year after account deletion. The purpose is to prevent repetition of the same violation and to respond to objections; this does not apply to other members. |
Destruction is irreversible. Electronic information is destroyed so that it cannot be recovered or reproduced, and paper material is shredded or otherwise disposed of appropriately. Backups are not queried in ordinary service or used for new purposes and are managed under the defined retention and destruction procedure.
Technical deadlines are not extra retention. Technical processing deadlines are not an additional retention period generally permitted by law. Where a necessary delay occurs, the reason, the data concerned and the expected completion date are communicated and unnecessary use is stopped.
6. Members' Rights and How to Exercise Them
You can request access, correction, deletion, suspension and withdrawal. A member or lawful agent may request access, a copy, correction, deletion, suspension of processing and withdrawal of consent. Where the statutory right to data portability applies, it may be exercised under that law.
Most of it can be done in the app. Editing and deleting the profile, records and posts, deleting the account, and withdrawing marketing consent can be done directly in the app. Other requests are received at info@maruna.ai, and the same route is available when the app cannot be used or the account has been deleted.
Identity checks use the minimum. Only the minimum material needed is used to verify identity and authority to act. Results are notified within the period and procedure set by applicable law. Where a request must be limited or deferred, the legal basis, reasons and available follow-up steps are explained.
Withdrawing is as easy as consenting. Withdrawing consent is not made unnecessarily harder than giving it. Material that must still be retained on an independent legal basis after withdrawal is explained by item, purpose and period.
Automated decisions can be reviewed by a person. Where statutory rights concerning fully automated decisions apply, the corresponding procedures such as refusal, explanation and review are available. Automatic text review results can be re-reviewed by a person, and the same legal classification does not apply to every result merely because it is a record analysis.
7. Automatic Collection Devices and App Permissions
The app uses no cookies and no web views. It also uses no advertising identifier, no App Tracking Transparency request, no advertising SDK and no third-party analytics SDK; the usage records in Section 2 go only to the Company's own servers. The external SDKs included in the app and their purposes are: Firebase Cloud Messaging (push notifications), Firebase Crashlytics (error reporting in the production environment only), Firebase Performance Monitoring (app start and server request timings in the production environment only, not linked to the account), Firebase App Check (app integrity), Google sign-in, Sign in with Apple, the store billing module, and a code-update module (no personal data sent). Login state and record drafts are stored encrypted on the device and are not synchronized off the device.
The permissions the app requests and their purposes are: camera (recording swing videos), microphone (recording video sound), photos (selecting and saving videos), location (while using the app only: nearby-course search, weather, post location tag), notifications (round, message and announcement alerts). Each permission is requested with its purpose when the feature is first used and can be changed in device settings. Denial affects only the feature that needs that permission.
8. Safeguards and Incident Response
The Company performs internal management, access control, necessary encryption, security checks and processor supervision to protect personal data. Access by persons handling personal data is limited to the minimum needed for their work.
When a personal-data breach occurs, or the statutory notification threshold for a possible breach is met, the Company follows the statutory procedure to explain the affected scope, how to prevent harm, the response taken, the contact in charge and how to exercise rights such as damages and dispute mediation, and files the required reports.
9. Privacy Officer
| Item | Detail |
|---|---|
| Controller | 주식회사 마루나에이아이 |
| Privacy officer | Lee Si-yun, Representative Director |
| Contact email | info@maruna.ai |
| Telephone and postal address | +82 10-5189-5781. Seocho-jungang-ro 18-gil 31, 3F 345-ho (Seocho-dong, Yongwon Building), Seocho-gu, Seoul |
| Department receiving access, correction and deletion requests | The privacy officer (info@maruna.ai) |
| Remedies for infringement | Personal Information Infringement Report Center (118), Personal Information Dispute Mediation Committee (1833-6972), Supreme Prosecutors' Office Cybercrime Division (1301), National Police Agency Cyber Bureau (182) |
10. Business Transfer and Changes to this Notice
Where personal data is transferred through a business transfer, merger or similar transaction, the fact of transfer, the recipient's contact details and how to object are notified in advance under the statutory procedure. Transferred personal data is not used beyond the purpose at the time of transfer without an additional lawful basis.
When this notice changes, the changes, the effective date and the previous version are announced. Changes to items or purposes that require consent follow a separate consent procedure. Continued use of the service after an announcement is not treated as new consent required for personal-data processing.