Privacy Policy

1. Introduction

Welcome to Zeeggle. We are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our AI-powered English learning platform, including our web application, mobile applications (iOS and Android), and related services.

By using our services, you agree to the collection and use of information in accordance with this policy. If you do not agree with our policies and practices, please do not use our services.

2. Information We Collect

2.1 Personal Information

We collect personal information that you voluntarily provide to us when you:

• Register for an account (username, email address, password)
• Update your user profile
• Contact us for support or inquiries
• In-app purchases or premium feature subscriptions (including name, date of birth, gender, and mobile phone number collected through identity verification during payment)
• Agreement records: the agreement type, policy version, date and time, source, IP address, and browser or app user-agent needed to document your acceptance or withdrawal
• Social sign-in information received from Google, Apple, Kakao, or Naver, such as provider account identifier, name, and email, according to the permissions you grant

2.2 Learning and Conversation Data

To provide our AI tutoring services, we collect and process:

• Conversation transcripts: Full text of your conversations with our AI tutor
• Voice recordings: Audio files of your speech during practice sessions
• Session metadata: Timestamps, session duration, topic selections, and conversation settings
• Performance metrics: Speech complexity scores, fluency ratings, grammatical accuracy, pronunciation assessments, word counts, and lexical diversity measurements
• Learning progress: Session history, completed topics, improvement trends, and personalized recommendations

2.3 Device and Usage Information

We automatically collect certain information when you use our services:

• Device information: Device type, operating system, browser type, and version
• Usage data: Pages visited, features used, time spent on the platform, and interaction patterns
• Network information: IP address and connection type
• Authentication tokens: JWT tokens stored locally for session management
• Push notification tokens: Device token, platform, user-agent, and notification delivery records when you enable push notifications

2.4 Mobile App Permissions

Our mobile applications may request the following permissions:

• Microphone access: To record your voice during conversation practice
• Camera access: The app package declares this permission for framework compatibility, but the current service does not access or collect camera content
• Storage access: To save conversation recordings and session data locally
• Audio modification: To enable voice recording and playback features

You can manage these permissions through your device settings at any time.

2.5 Payment Information

For subscriptions and in-app purchases, web payments are processed through PortOne Inc. and KG Inicis, while mobile payments are processed through Apple App Store and Google Play Store. We do not directly store your payment card details. We only receive transaction confirmations, receipt information, and subscription status from payment processors. The mobile phone number collected through identity verification is provided to payment processors as customer information required for payment processing.

2.6 Identity Verification Information

The following information is collected during identity verification for paid service payments:

• Full name
• Date of birth
• Gender
• Mobile phone number
• CI (Connecting Information): A unique identifier for identity confirmation
• DI (Duplication Information): An identifier to prevent duplicate registrations within the service

Identity verification information is collected through the mobile phone identity verification service of Danal Co., Ltd. and transmitted to our servers via PortOne Inc. The collected information is used solely for identity confirmation, payment processing, and duplicate registration prevention.

3. How We Use Your Information

We use the information we collect for the following purposes:

• Provide and improve our services: Deliver AI-powered English tutoring, process your conversations, and generate performance feedback
• Speech analysis: Analyze your pronunciation, fluency, grammar, and complexity using AI technology
• Personalization: Customize learning recommendations, track your progress, and adapt content to your skill level
• Session management: Save your conversation history, enable replay features, and generate detailed session reports
• Account management: Authenticate users, manage subscriptions, and provide customer support
• Platform optimization: Analyze usage patterns to improve user experience and develop new features
• Communication: Send important updates, notifications, and respond to your inquiries
• Security: Detect and prevent fraud, abuse, and technical issues

4. Third-Party Services and Data Sharing

4.1 Service Providers

We use trusted third-party services to provide and improve our platform:

• OpenAI: We use OpenAI's API for AI conversation generation and speech analysis. Your conversation data is processed according to OpenAI's API data usage policies
• Amazon Web Services (AWS): We store audio recordings and user data on AWS S3 with encryption and access controls
• Cloud hosting providers: For application infrastructure and database management
• PortOne: Used for web payment processing and identity verification service integration. Payment information and identity verification results are transmitted through PortOne
• KG Inicis: A payment gateway (PG) service for credit card payment processing, integrated via PortOne. Only the minimum information required for payment authorization and cancellation is transmitted
• Danal: A mobile phone identity verification service provider, integrated via PortOne. The mobile phone number, carrier information, and other details entered during identity verification are transmitted to Danal for identity confirmation
• Payment processors: Apple App Store and Google Play Store for mobile app subscriptions and in-app purchases
• Meta (Facebook): We use Meta Pixel and the Meta App Events SDK for advertising measurement and marketing. Collected information includes page views, registration completions, and purchase events. The advertising identifier (IDFA/AAID) is only collected with user consent.
• Google Analytics and Firebase: Used for product analytics, error events, and user-linked usage measurement. Data may include page views, feature interactions, internal user ID, and device information.
• Vercel Speed Insights: Used to measure web performance and reliability, including page performance metrics and technical request information.
• Amazon Simple Email Service (SES): Used to deliver account, support, and learning-report emails. The recipient email address and message content are processed for delivery.
• Modal: Provides infrastructure for real-time and uploaded speech transcription. Voice audio and technical connection data may be processed to produce transcripts and pronunciation analysis.
• Firebase Cloud Messaging and Apple Push Notification service: Used to deliver notifications to Android, web, and iOS devices using device push tokens and delivery information.

4.2 Data Sharing Limitations

We do not sell, rent, or trade your personal information to third parties for marketing purposes. We only share your data with service providers who assist us in operating our platform, and only to the extent necessary to provide our services. All third-party providers are contractually obligated to protect your information and use it only for specified purposes.

4.3 Legal Disclosure

We may disclose your information if required by law, court order, or governmental authority, or to protect our rights, property, or safety, or that of our users or the public.

5. Data Storage and Security

5.1 Security Measures

We implement industry-standard security measures to protect your information:

• Encryption of data in transit using HTTPS/TLS protocols
• Encryption of data at rest in our databases and cloud storage
• JWT-based authentication with secure token management
• Access controls and authentication for administrative functions
• Regular security audits and monitoring

5.2 Data Retention

We retain your personal information and learning data for as long as your account is active or as needed to provide our services. You may request deletion of your data at any time (see Section 7). Some data may be retained for longer periods if required by law or for legitimate business purposes such as fraud prevention and analytics.

5.3 Data Location

Your data may be transferred to and stored on servers located in different countries where our service providers operate. We ensure that all such transfers comply with applicable data protection laws and that your data receives adequate protection.

6. International Users and Data Transfers

Zeeggle is operated globally and may process your information in various countries. If you are located in the European Economic Area (EEA), United Kingdom, or other regions with data protection laws, please note that we will transfer your data to countries that may have different data protection standards. We implement appropriate safeguards to ensure your data is protected in accordance with this Privacy Policy and applicable laws.

7. Your Rights and Choices

Depending on your location, you may have the following rights regarding your personal information:

7.1 Access and Portability

You can access your profile information, conversation history, and session reports through your account dashboard. You may request a copy of your data in a portable format.

7.2 Correction and Update

You can update your profile information at any time through your account settings.

7.3 Deletion

You may request deletion of your account and associated data. Please note that some information may be retained for legal or legitimate business purposes after account deletion.

7.4 Opt-Out

You can manage communication preferences and opt out of non-essential notifications through your account settings.

7.5 Withdraw Consent

Where we rely on your consent to process your data, you can withdraw that consent at any time. This will not affect the lawfulness of processing before the withdrawal.

To exercise any of these rights, please contact us at the information provided in Section 10.

8. Children's Privacy

Our services are not directed to children under the age of 13 (or the applicable age of consent in your jurisdiction). We do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us immediately, and we will take steps to delete such information.

For users between 13 and 18 years old (or the age of majority in your jurisdiction), we recommend that parents or guardians review this Privacy Policy and supervise the use of our services.

9. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the Last Updated date. We encourage you to review this Privacy Policy periodically.

Your continued use of our services after any changes to this Privacy Policy constitutes your acceptance of the updated policy.

10. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

We will respond to your inquiry within a reasonable timeframe, typically within 30 days.

11. Region-Specific Privacy Rights

11.1 European Economic Area (EEA) and UK Users

If you are located in the EEA or UK, you have additional rights under the General Data Protection Regulation (GDPR):

• Right to object to processing of your personal data
• Right to restrict processing in certain circumstances
• Right to lodge a complaint with your local data protection authority
• Right to be informed about the legal basis for processing your data

11.2 California Users

If you are a California resident, the California Consumer Privacy Act (CCPA) provides you with specific rights regarding your personal information:

• Right to know what personal information is collected, used, shared, or sold
• Right to delete personal information (subject to certain exceptions)
• Right to opt-out of the sale of personal information (Note: we do not sell personal information)
• Right to non-discrimination for exercising your CCPA rights

12. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience, analyze usage patterns, and maintain your session state. These technologies include:

• Essential cookies: Required for authentication and core functionality
• Local storage: Used to store JWT tokens and user preferences
• Analytics: To understand how users interact with our platform

You can control cookies through your browser settings, but disabling certain cookies may affect the functionality of our services.

13. Cross-Border Transfer

In accordance with Article 28-2 of the Personal Information Protection Act (PIPA), we transfer personal information overseas as described below. You may refuse this transfer without any disadvantage to your use of the service, and you may withdraw your consent at any time through My Page.

• Recipient: Meta Platforms Ireland Limited (Block J, Serpentine Avenue, Dublin 4, Ireland)
• Purpose of transfer: Advertising performance measurement and optimization (Meta Conversions API)
• Items transferred: Hashed email (SHA-256), external identifier, browser identifiers (_fbp/_fbc cookies), IP address, User-Agent, and upon payment: transaction ID, amount, and currency
• Country of transfer: Ireland
• Timing and method of transfer: Immediately upon registration or payment completion via HTTPS (server → graph.facebook.com)
• Retention period: As per Meta Platforms Ireland's Privacy Policy (up to approximately 2 years)

No disadvantage for refusal — consent can be withdrawn at any time from My Page

Consent terms version: v1.0