This Privacy Policy applies to all services (including the NEO App and Web platforms) provided by Hyunjon Co., Ltd. (hereinafter referred to as the "Company," "we," "us," or "our").
1. Introduction and Purpose
We are committed to protecting your privacy and personal information. This Privacy Policy complies with applicable data protection laws, regulations, and guidelines governing information and communication service providers.
The purpose of this Privacy Policy is to transparently explain what personal information we collect, how we use and protect it, and what rights you have regarding your data. This policy may be updated periodically to reflect changes in laws, regulations, or our internal practices. Any revisions will be communicated to you through this policy.
2. Information We Collect and Purpose of Collection
We collect the minimum necessary personal information required to provide our platform and services effectively.
Account Registration
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[Required] Apple Sign-In Information: Your name and email address (or a randomized email address if you select "Hide My Email") automatically collected during the Apple Sign-In process.
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[Required] TrueDepth API Data: We use the TrueDepth API to detect the position of your face and measure its distance from your mobile device. Please note: This data is processed locally on your device in real-time and is never transmitted to or stored on our servers.
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[Optional] Physical Characteristics: Birth year, biological sex, height, and weight.
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[Optional] Heart Rate Data: Resting heart rate, walking heart rate average, maximum heart rate, heart rate variability (HRV), and VO2 max.
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Purpose of Use: To identify users, provide customized fitness tracking and movement measurement services, manage accounts, handle customer service inquiries, and deliver overall service functionality.
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Retention Period: Until account deletion or the fulfillment of the collection purpose.
Service Usage Data
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[Collected Automatically] Usage Records: Recent access dates, registration date, IP address, event logs, and device information (unique device identifiers, OS version).
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Purpose of Use: To analyze statistical data for service usage and to improve the platform.
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Retention Period: Until account deletion or the fulfillment of the collection purpose.
3. How We Use Your Information
We use your personal data for the following purposes:
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Service Provision: User identification, verification of intent to register, delivery of content, provision of customized services, and identity verification.
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Personalization: Delivering tailored services based on demographic and physical characteristics.
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Account Management: Preserving records for dispute resolution, handling user complaints and inquiries, delivering important notices, processing account deletions, and restricting users who violate our Terms of Service.
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Development & Analytics: Developing new features, content, and services, conducting user analysis, generating statistics on service usage and access frequency, and improving overall service quality.
4. Data Retention and Deletion
As a general rule, we promptly delete personal information once the purpose of collection and use has been fulfilled or the retention period has expired.
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Destruction Method: Electronic files are securely deleted using technical methods that prevent data recovery. Physical records (paper, printouts) are destroyed by shredding or incineration.
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Exceptions (Mandatory Retention): We retain certain information for specified periods as required by internal policies or applicable laws:
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Records of Consumer Complaints or Disputes: 3 years (in accordance with applicable consumer protection laws).
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Service Access Logs (IP, Log data): 3 months (in accordance with the Protection of Communications Secrets Act).
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Fraud Prevention Data (Apple account info, birth year, sex, weight of users involved in fraudulent activity): 1 year (internal policy to prevent unauthorized access and abuse).
5. Sharing Information with Third Parties
We use your personal information strictly within the scope disclosed in this policy. We do not provide your data to third parties without your prior consent, except in the following circumstances:
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With Your Explicit Consent: Before collecting or sharing information, we will inform you of the business partner’s identity, the data involved, and the duration and method of data protection, and we will obtain your explicit consent. If you do not consent, we will not share your data.
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Legal Obligations: When required by law, or in response to lawful requests by law enforcement agencies for investigation purposes.
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Anonymized Data for Research: When necessary for statistical analysis, academic research, or market research, provided the data has been thoroughly anonymized and de-identified in accordance with applicable governmental guidelines so that no individual can be identified.
6. Your Privacy Rights
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Access and Modification: You may view or edit your personal information at any time through the app's settings. You may also request modifications via our customer support channels (which may require identity verification).
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Data Processing Restrictions: You may request that we suspend the processing of your personal information, though we may refuse this request if required by law.
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Withdrawal of Consent (Account Deletion): You may withdraw your consent for data collection and use at any time by deleting your account.
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Correction of Errors: If you request the correction of inaccurate personal data, we will not use or share that data until the correction is complete. If incorrect data was already provided to a third party, we will notify them immediately to ensure corrections are made.
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Exercising Your Rights: You or your legal representative may exercise these rights directly within your account profile page or by contacting customer support.
7. Data Security Measures
We implement rigorous technical, administrative, and physical security measures to prevent the loss, theft, leakage, alteration, or damage of your personal information:
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Regular Audits: We conduct internal privacy audits regularly (at least quarterly).
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Staff Training and Minimization: Only designated personnel have access to personal data, and we enforce strict access control and training policies.
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Internal Management Plans: We establish and execute internal data protection protocols.
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Technical Defenses: We install, regularly update, and monitor security software (including firewalls and anti-virus programs) to prevent hacking and computer viruses. Our systems are housed in secure zones with restricted access.
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Log Management: System access logs are securely stored and managed for a minimum of 6 months, using features that prevent forgery, theft, or loss.
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Access Control: We meticulously grant, modify, and revoke access privileges to database systems and utilize intrusion prevention systems to block unauthorized external access.
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Physical Security: Physical records and storage media are kept in securely locked locations. We maintain strict access control procedures for facilities housing personal data.
8. Data Protection Officer and Contact Information
We have designated a Data Protection Officer (DPO) to oversee all personal information processing, handle privacy-related complaints, and facilitate damage relief.
Data Protection Officer (DPO)
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Name: Hyeonjo Shin
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Position: Chief Technology Officer (CTO)
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Email: hyeonjon.kr@gmail.com
For all general privacy inquiries, requests for access to your data, or customer service issues, please contact:
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Customer Service Department Email: hyeonjonkr@gmail.com
9. Dispute Resolution and Remedies
If you believe your privacy rights have been violated, you may seek resolution, consultation, or file a complaint with the applicable governmental or regulatory privacy agencies in your jurisdiction.
For users located in South Korea, you may contact the following agencies:
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Personal Information Dispute Mediation Committee: 1833-6972 (www.kopico.go.kr)
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KISA Personal Information Infringement Report Center: 118 (privacy.kisa.or.kr)
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Supreme Prosecutors' Office: 1301 (www.spo.go.kr)
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Korean National Police Agency Cyber Bureau: 182 (cyberbureau.police.go.kr)
10. Changes to this Privacy Policy
This Privacy Policy may be updated due to changes in government policy or corporate necessity. Any additions, deletions, or modifications will be announced via our website or app without delay.
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Privacy Policy Version: v1.0.0
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Notification Date: April 28, 2025
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Effective Date: April 28, 2025
(Note: This is the initial version of the Privacy Policy.)