bubi Privacy Policy

Effective: June 10, 2026

This English version is provided for convenience. The Korean version of this Privacy Policy is the legally binding text; in case of any conflict, the Korean version shall prevail.

bubi ("Service") complies with the Personal Information Protection Act, the Act on Promotion of Information and Communications Network Utilization and Information Protection, and other applicable laws of the Republic of Korea, and has adopted this Privacy Policy to protect Members' personal data.

1. Personal Data We Collect

Required (at signup): email address or third-party OAuth identifier supported by the Service (such as a Google account), password (stored hashed)
Profile (onboarding / profile edit): nickname, gender, date of birth, country, bio, profile avatar image
Notification preferences (optional): chat notifications, marketing communications, night-time notifications
Automatically collected: device identifier, OS version, app version, access timestamp, usage logs
Payment and credits: subscription and credit product IDs, transaction IDs, subscription state (active/expired/refunded), credit balance and ledger entries, billing metadata. We do not directly collect card numbers, bank accounts, or similar payment credentials — those are processed only by Apple/Google in-app purchase systems.
Generated during use: AI character conversations, voice call transcripts, chat/call timestamps, selected character data, relationship scores, user/character facts learned from conversations, session summaries and long-term memories (including vector embeddings)
Character creation: character name, gender, apparent age, personality and tone description, appearance description (free-form text), generated portrait images
Voice calls: microphone access permission (device OS level), call duration, call billing (credit deduction) information

2. Purposes of Collection and Use

Member identification and account management
Provision of AI chat and voice call services (including LLM and voice AI API calls)
Character creation and portrait generation services
Maintaining conversation context, session summarization, long-term memory retrieval, and relationship scoring
Subscription and credit state management and payment/refund processing
Notification delivery (chat, marketing, and night notifications per Member settings)
Fraud detection and prevention, and service quality improvement
Responding to user inquiries and delivering announcements
Compliance with legal obligations

3. Retention Period

Upon account termination, account identifiers are deleted or de-identified without undue delay. However, chat/call records, payment and credit records, dispute records, access logs, and similar data may be retained to the extent necessary for legal retention duties, dispute handling, and fraud prevention, and then deleted or de-identified after the periods below:

Contract or withdrawal records: 5 years (Act on Consumer Protection in Electronic Commerce)
Payment and supply records: 5 years (same Act)
Consumer complaint/dispute records: 3 years (same Act)
Access logs: 3 months (Protection of Communications Secrets Act)

4. Disclosure to Third Parties

We do not disclose personal data to third parties, except with the Member's prior consent or where required by law.

5. Processors (Subcontractors)

We entrust the following parties with personal data processing tasks for service operation:

Processor	Task	Processing Location	Data Processed	Retention
Supabase, Inc.	Database, auth, and storage hosting	United States / Singapore and other selected regions	Account data, profiles, chat/call records, credit/payment metadata, generated images, usage logs	Service period and the retention periods in Section 3
RevenueCat, Inc.	Subscription and credit payment state management and webhooks	United States	App user identifier, subscription/product IDs, transaction IDs, subscription status	Subscription/payment management period and statutory retention periods
OpenRouter, Inc. and model/image providers selected through OpenRouter	LLM routing, AI response/summary/embedding generation, portrait image generation	United States and other provider processing locations	Chat/call inputs, character settings, image generation prompts, context needed for response generation	Until the processing purpose is achieved or as retained under the provider's policy
OpenAI, L.L.C. / Anthropic PBC and other LLM providers	LLM inference, summarization, embeddings, and other AI features	United States and other provider processing locations	Chat inputs, text to summarize, and context needed for response generation	Until the processing purpose is achieved or as retained under the provider's policy
ElevenLabs, Inc.	Conversational voice AI (speech recognition, synthesis, call processing)	United States and other locations	Voice call input/transcripts, character voice settings, call metadata	Until call processing purpose is achieved or as retained under the provider's policy
Apple Inc. / Google LLC	In-app purchase processing	United States and other locations	Payment account, transaction ID, payment status, and store payment information	Store policy and statutory retention periods
Google LLC (Google Analytics for Firebase)	Usage statistics and behavioral analytics	United States	App instance identifier, user identifier (user_id), screen/event usage logs, subscription tier (free/paid), country/language	Retained under Google's policy (default up to 14 months)

6. Cross-Border Transfer

Under Section 5, personal data may be transferred to the countries where processors or service providers are located. Transfers occur electronically over TLS-encrypted network channels when the Service is used; transferred data, purposes, and retention periods follow the table in Section 5 and Section 3. Members have the right to refuse cross-border transfers under Article 28-8 of the Personal Information Protection Act; refusal may limit access to AI chat, voice calls, account management, subscription/credit processing, or other parts of the Service.

7. Your Rights

Members may request at any time to access, correct, delete, or suspend processing of their personal data.
Use the in-app "Delete Account" function or email the contact below to submit requests.
We will respond within 10 days of receipt, subject to exceptions permitted by law.

8. Deletion Procedure

Procedure: Personal data whose retention period has expired or whose processing purpose has been achieved is deleted without delay. Upon account deletion, your login credentials and profile identifiers are irreversibly anonymized, and your conversations, AI memories, and other personal data are permanently deleted; records required by law (e.g., payment records) are separately retained for the statutory period and then destroyed.
Method: Electronic files are permanently deleted in a non-recoverable manner; backup copies are erased on a rolling basis.

9. Security Measures

TLS encryption in transit
Password hashing (no plaintext storage)
Row-Level Security in the database
Principle of least privilege for operational accounts
Minimization of personnel with data access and access log management

10. Cookies, Device Identifiers, and Microphone

The mobile app does not use cookies and does not collect advertising identifiers (IDFA/GAID). However, app-internal identifiers, device information, and access logs may be generated for service quality improvement and fraud prevention. Voice call features require microphone access permission, which can be managed in device OS settings.

11. Children's Privacy

We do not knowingly collect personal data from children under 13. Any such account, if discovered, will be deleted immediately.

12. Data Protection Officer

Name: bubi Operator
Email: seukwon@gmail.com

Please direct privacy-related inquiries, complaints, and remedy requests to the contact above.

13. Remedies for Rights Infringement

For infringement reports or consultation, Members may contact:

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

14. Revision History

2026-04-21: Initial version
2026-06-10: Updated for voice calls, credits, character creation, long-term memory, notification settings
2026-08-16: Minimum signup age lowered from 14 to 13