This English version is provided for convenience. In the event of any discrepancy between
this translation and the original Korean version, the
Korean version prevails.
pilstech (Representative: Kim Hong-pil; hereinafter the "Operator") operates the mobile
application "PicoPet" (hereinafter the "Service") in compliance with applicable laws, including
the Personal Information Protection Act, and establishes and discloses this Privacy Policy as
follows in order to protect users' personal data.
1. Items of Personal Data Collected and Methods of Collection
The Operator collects the following personal data. The Service does not use a separate
sign-up form and relies solely on social account login (Kakao, Google, Apple, LINE).
Category
Items collected
Method of collection
User identification (Required)
Social login provider (Kakao/Google/Apple/LINE), unique social account identifier,
nickname (automatically generated at sign-up, changeable in the app)
At social login
User information (Optional)
Email address (only where the user has consented to its provision through the
social account)
At social login
Breed recommendation
Preference analysis responses (selected tags), recommendation results (list of
breeds), and the user-uploaded face photo (an image whose background has already been
removed on the user's device)
When using the breed recommendation feature
User-generated content
Feed posts (photos, text, breed information), comments, like records, decorated
photos, diaries (title, content, photos, mood tags), saved breeds, item unlock
history, and the block relationships and reports created by the user
When using the relevant feature
Automatically collected items
Last login date and time and IP address, and the authentication token used to keep
the user signed in
Automatically collected at login
Rewarded ad use
Ad view request identifier (a randomly generated value), ad transaction ID, date and
time the reward was granted, and the start and expiry date and time of the pass (24-hour
Premium Pass)
When watching a rewarded ad
Information collected directly by the Google Mobile Ads SDK, which is included in the app to
display ads, is described in Section 8.2.
The processing of face photos uploaded by users is set out separately in Section 2 (Processing
of Face Data). Background removal and breed recommendation analysis are performed on the user's
device, and the Operator does not separately extract or store biometric facial features.
2. Processing of Face Data
The breed recommendation feature of the Service uses the user's face photo. The Operator
handles the Face Data processed in this feature as follows.
2.1 Face Data processed
The Face Data processed by the Operator consists solely of the face image file
that the user has taken or selected and uploaded, together with the address
(URL) string of that image stored in the database.
The Operator does not create or store any biometric identifier capable of
uniquely identifying a user from their face. Specifically, the Operator does not create,
derive, or store any of the following:
Face embeddings, face templates, or biometric identifiers
Facial landmarks, bounding boxes, or face orientation values (yaw/roll/pitch)
Smile scores, eye-openness values, face quality scores, or other facial feature
points
Any other biometric feature information capable of uniquely identifying an individual
from their face
2.2 Purposes of processing
Background removal and breed recommendation analysis are performed on the user's
device; the server performs no facial recognition and no breed recommendation
computation. The face image is transmitted to the server only after processing on the device
has been completed.
The server stores the face image solely for the following purposes:
Storing the breed recommendation result
Allowing the stored recommendation result to be viewed again
Restoring the previous recommendation result and photo so that the user can view them
again even after deleting and reinstalling the app
Providing photo-related features requested by the user, such as photo decoration
Face photos are not used for facial recognition, identity verification, biometric
authentication, determining whether two images are of the same person, advertising, marketing,
or user tracking.
2.3 Where face images are stored
Face image files are stored on the PicoPet servers that the Operator builds and manages
directly.
The database stores only the address (URL) string of the image, not the image file
itself.
Face images are not stored in any external cloud storage (for example, Amazon S3, Google
Cloud Storage, or Firebase Storage), and are not transmitted to any external artificial
intelligence (AI) API.
2.4 Provision to third parties
The Operator does not sell face images or face-related data, and does not
provide or transmit them to advertising networks, analytics services, crash-reporting
services, or external artificial intelligence services.
Communication with the social login providers listed in Section 8 is limited to login
authentication; Face Data is not included in that communication.
2.5 Retention period
A face image is retained until the user (i) deletes the relevant recommendation result,
(ii) resets their recommendation history, or (iii) deletes their account. It is not deleted
automatically merely because a period of time has elapsed.
Uploaded files that were not properly linked to a recommendation record or other content
during Service processing are automatically deleted after the minimum period necessary.
2.6 How to delete
Users may delete an uploaded face photo through any of the following in the app:
Deleting an individual recommendation result
Resetting the entire recommendation history
Deleting the account
Upon such deletion, the Operator deletes both the database record and the actual image
file stored on the server (including any resized images generated from that file).
However, where the user continues to use the same image in another feature (for example,
a shared feed post), the image file is retained until that use ends.
3. Purposes of Processing Personal Data
User management, such as user identification and maintaining login status
Storing breed recommendation results and restoring them when the app is reinstalled
(for Face Data, see Section 2)
Providing core Service features such as photo decoration, feed, and diary
Preventing misuse and ensuring the stability of the Service
Protecting users, including responding to inquiries
Operating and maintaining the Service and investigating violations of the Terms of
Service
Detecting misuse, ensuring account security, and handling reports about posts
Granting passes for watching rewarded ads and preventing duplicate or fraudulent grants
Displaying ads to fund the operation of the Service (see Section 8.2)
4. Retention and Use Period of Personal Data
The user's personal data is retained and used until the account is deleted,
and is deleted promptly upon account deletion in accordance with the procedure in Section 5
below. However, the report records referred to in paragraph 2 of that Section are retained for
one year from the date of account deletion and are then deleted, and the ad transaction records
referred to in paragraph 3 of that Section are retained with their link to the user removed.
The retention period for face photos is set out separately in Section 2.5.
However, where retention is required under applicable laws, the data is kept for the
period prescribed by such laws. (For example, Service access records are kept for 3 months
under the Protection of Communications Secrets Act. If paid or payment features are introduced
in the future, transaction and payment records may be kept under the Act on the Consumer
Protection in Electronic Commerce.)
5. Procedure and Method of Deleting Personal Data
When the user uses "Delete Account" in the app, the Operator deletes the following
data without delay. Deletion is carried out both in the database of the Service's
operating servers and in the image files linked to those records:
All account information (social account identifier, email, nickname, profile
information, login records, and authentication token)
Breed recommendation records and uploaded face photo files
Feed posts, comments, and like records (including other users' comments and likes on
posts authored by the user) and post photo files
Decorated photos and their image files, and diaries and their photo files
Saved breed list and item unlock history
Block relationships created by the user
Premium Pass information and ad view request records
Notwithstanding paragraph 1, reports submitted about posts and comments
are retained for one year from the date of account deletion in order to
address repeated infringement of rights, protect users, and handle disputes, and are deleted
thereafter. Reports whose retention period has expired are deleted by the Operator on a
regular basis without any separate request. Such records contain the internal identification
numbers of the reporting user and the reported target, the reason for the report, and the date
and time of the report; they do not contain any image file, including face photos.
Notwithstanding paragraph 1, ad transaction records (the ad transaction ID
issued by Google and the date and time of the reward) are retained with the user's internal
identification number removed, so that they can no longer be linked to a specific user, in
order to prevent the same ad reward from being granted twice.
For a user who signed in with an Apple account, the Operator also requests revocation of
the login token issued by Apple upon account deletion.
Data in electronic file form is removed without delay from the database and file storage of
the Service's operating servers by means of deletion commands, and deleted data can no longer
be accessed through the Service.
6. Provision of Personal Data to Third Parties
The Operator does not provide users' personal data to third parties, except where the user
has separately consented or where required under the provisions of applicable laws. The
provision of Face Data to third parties is set out separately in Section 2.4.
7. Consignment of Personal Data Processing
The Operator does not consign the operation of its Service servers to any external hosting
company; the Operator builds and operates the servers directly. Photos uploaded by users (face
photos included) and content created by users are stored only on servers managed directly by the
Operator and are not transmitted to external analytics services or artificial intelligence APIs.
The Operator does not store users' photos in external cloud storage and does not transmit them to
external services for advertising, analytics, or crash-reporting purposes. For the third-party
SDKs included in the app for login and for displaying ads, please refer to Section 8.
8. Notice Regarding Third-Party SDKs and Advertising
8.1 Login SDKs
For login purposes, the Service includes the following third-party SDKs in the app, and
communication with each provider's servers occurs during the login process. That communication is
limited to the information required for login authentication and does not include photos
uploaded by users or any Face Data. Matters concerning each provider's processing of personal
data are governed by that provider's own privacy policy.
Kakao SDK (Kakao Login) — Kakao Corp.
Google Sign-In (Google Login) — Google LLC
Sign in with Apple (Apple Login) — Apple Inc.
LINE SDK (LINE Login) — LY Corporation
Firebase Authentication (handling of Google login) — Google LLC
(Firebase's analytics and advertising features are not used)
8.2 Advertising SDK (Google AdMob)
To fund the operation of the Service, the Service displays the following ads through the
Google Mobile Ads SDK (AdMob) provided by Google LLC.
Rewarded ads: shown only when the user chooses to watch one. Completing the
ad grants a 24-hour Premium Pass.
Interstitial ads: may be shown during the screen transition after the user
finishes decorating a photo.
For ad delivery, ad performance measurement, fraud prevention, and analytics, the advertising
SDK may collect the following information and send it to Google. This information includes
behavioral information about the user's interaction with ads.
Device identifiers — the advertising identifier (IDFA) is collected only if the user allows
tracking
Advertising data and interaction information (ad impressions, clicks, completed views,
etc.)
Approximate location based on IP address
Performance and diagnostic information (including app crash information)
The Operator does not provide the advertising SDK with users' photos, Face Data, posts, or user
identification information (social account identifier, email, nickname, or internal user number).
The signal that Google sends to the Operator's server to confirm a reward contains only a view
request identifier randomly generated by the Operator.
8.3 Your Choices Regarding Ad Tracking and Personalized Ads
The Service asks whether the user allows tracking through iOS App Tracking Transparency
(ATT). If the user has not allowed tracking, or has not yet been asked, the advertising
identifier (IDFA) is not collected or used; non-personalized ads may still be shown in that
case. Users who do not allow tracking can still use every feature of the Service in the same
way.
Users can change their tracking choice at any time in the device's [Settings > Privacy
& Security > Tracking].
For users in regions where consent is required by law, such as the European Economic Area
(EEA) and the United Kingdom, consent to the processing of personal data for advertising is
obtained through Google's consent management tool, and ads may not be shown depending on the
consent given. Users can change or withdraw that consent at any time under [Ad Privacy Settings]
in the app's settings.
Rewarded ads are shown only when the user chooses to watch them.
9. Your Rights and How to Exercise Them
Users may exercise the following rights at any time:
Modifying user information such as the nickname in the app settings
Resetting or deleting breed recommendation records (including face photos) through
in-app features
Modifying or deleting posts, diaries, and other content authored by the user
Deleting all personal data through "Delete Account" in the app (to the extent set out
in Section 5)
Changing the ad tracking choice and ad privacy consent (Section 8.3)
When a user deletes content such as a post, diary entry, or decorated photo, or replaces
its image with a different one, the image file linked to that content is deleted together with
the database record. However, where the same image is still in use in the user's other content,
it is retained until that use ends.
Requests for access, correction, deletion, or suspension of processing that are difficult
to handle through the above methods may be made by email to the Privacy Officer in Section 11
below, and the Operator will take action without delay.
Users must be at least 14 years of age to use the Service, and the Operator does not
collect the personal data of children under the age of 14.
10. Measures to Ensure the Security of Personal Data
Encryption of data in transit (HTTPS)
Access control based on authentication tokens — the Service APIs require user
authentication and verify that the requester is the owner of the data when handling requests to
view, modify, or delete their own data, such as recommendation records, posts, and diaries
Image files uploaded by users are accessible only through addresses generated from
unguessable random identifiers (UUIDs), and those addresses are provided only through the
user's own app screens
Minimization of access privileges for servers and administrator accounts, and retention of
access logs
Applying security updates to the operating system and server software
Restricting network access through firewalls and similar measures
Restricting access to files and backups containing personal data
11. Privacy Officer
Privacy Officer: Kim Hong-pil
Email: help.picopet@gmail.com
Users may direct all inquiries, complaints, and requests for remedy regarding the protection
of personal data arising during use of the Service to the contact above.
12. Complaints and Remedies
If you need to report or seek advice regarding an infringement of personal data, you
may contact the following organizations (all are Korean authorities).
Privacy Infringement Report Center (Korea Internet & Security Agency):
118 (no area code) / privacy.kisa.or.kr
Personal Information Dispute Mediation Committee: 1833-6972 / kopico.go.kr
Supreme Prosecutors' Office, Cyber Investigation Division: 1301 (no area code) /
spo.go.kr
National Police Agency, Cyber Investigation Bureau: 182 (no area code) /
ecrm.police.go.kr
13. Changes to This Privacy Policy
If the contents of this Policy are added to, deleted, or modified, notice will be given via
an in-app announcement or this page from 7 days prior to the effective date. However, for any
change that is unfavorable or material to users, notice will be given from 30 days prior to the
effective date.
Addendum
This Privacy Policy takes effect on November 17, 2026. It replaces the previous Privacy Policy
(Version 1.1, effective August 16, 2026) as of that date.
The Korean version of this Privacy Policy is the official version and shall prevail in the
event of any inconsistency between the translated versions.