MOAVO Habits Privacy Policy

Effective: 2026-07-01

MOAVO (CEO: Jae-Young Dokgo, hereinafter the “Company”) operates the MOAVO Habits service (hereinafter the “Service”) in compliance with the Personal Information Protection Act (PIPA) of the Republic of Korea and other applicable laws and regulations, in order to protect the freedom and rights of data subjects and to process personal information lawfully and manage it securely. Pursuant to Article 30 of the Personal Information Protection Act, the Company establishes and discloses this Privacy Policy to inform data subjects of the procedures and standards for the processing and protection of personal information, and to handle related complaints promptly and smoothly.

*This English version is provided for the convenience of users. In the event of any discrepancy between the Korean version and this English translation, the Korean version shall prevail. Unless otherwise specified, all references to laws and regulations in this Privacy Policy refer to the laws and regulations of the Republic of Korea.*

Article 1. Purposes of Processing Personal Information

The Company processes personal information for the following purposes. Personal information being processed will not be used for any purpose other than those stated below, and if the purpose of use changes, the Company will take necessary measures in accordance with applicable laws.

1. Membership Registration and Management
Verifying intent to register, identifying and authenticating users, maintaining and managing membership status, preventing fraudulent use, delivering notices, and handling inquiries and complaints.

2. Service Provision
Providing habit creation, tracking, and management services; providing habit achievement statistics and analysis; generating AI-based habit coaching comments and reports; providing photo attachment features; providing a home screen widget; and sending service-related notifications such as habit reminders.

3. Subscription and Payment Management
Providing paid subscription (Premium) services, verifying and managing subscription status, managing free trial periods, and responding to payment-related inquiries.

4. Complaint Handling
Receiving and processing inquiries and complaints, retaining records for dispute resolution, and identifying and responding to service errors.

5. Service Stability and Security
Detecting abnormal logins and service use, limiting login attempts, responding to system failures, and managing security logs.

6. Statistical Analysis and Service Improvement
Analyzing service usage, improving quality, researching and developing new features, and compiling statistics and conducting internal analysis for research and materials related to behavioral science and habit formation. In such cases, the Company pseudonymizes or anonymizes personal information to the extent possible and does not combine it with identifiable information.

Article 2. Personal Information Items Processed

The Company processes the following personal information.

1. Personal Information Processed Without the Data Subject’s Consent

2. Personal Information Processed With the Data Subject’s Consent

The Company provides separate consent options for service notifications and marketing communications during sign-up or in the settings screen. Consent to receive marketing communications is optional, and declining consent does not restrict the use of basic Service features.

3. Information Automatically Generated and Collected During Service Use

The Company may automatically generate and collect the following information in the course of providing the Service.

4. Notice Regarding Sensitive Information
The Company does not intentionally collect sensitive information under applicable law, such as a user’s ideology, beliefs, or health status. However, content that users voluntarily enter or attach within the Service — such as habit titles, notes, and photos — may contain sensitive information, so please refrain from entering unnecessary sensitive information. Information voluntarily entered by users is processed only within the scope of providing the services requested by the user.

Article 3. Processing and Retention Period of Personal Information

The Company processes and retains personal information within the retention and use period prescribed by law or the retention and use period consented to by the data subject at the time of collection.

1. Retention Periods for Key Personal Information

The Company operates its systems so that short-term data such as expired tokens, session information, and password reset tokens are automatically expired, invalidated, or deleted.

2. Destruction Upon Membership Withdrawal
When a user requests membership withdrawal through the in-app function [Settings] > [Delete Account], the Company will destroy the user’s personal information — including member information, habit records, photos, AI-generated content, and tokens — without delay, except for information that must be retained separately under applicable laws.

3. Retention Under Applicable Laws

In accordance with applicable laws, the following information is stored separately for the specified periods.

Article 4. Procedures and Methods for Destroying Personal Information

The Company destroys personal information without delay when it becomes unnecessary, such as upon expiration of the retention period, achievement of the processing purpose, or membership withdrawal. However, if the information must be retained under other laws, the Company transfers it to a separate database (DB) or stores it in a different location for safekeeping.

1. Destruction Procedure
The Company identifies personal information for which grounds for destruction have arisen and destroys it in accordance with internal procedures.

2. Destruction Method
Personal information in electronic file format is permanently deleted using technical methods that make recovery or restoration impossible. Photo files and similar data stored on servers are completely deleted from the storage media.

3. Handling of Backup Data
Personal information contained in system backup files is securely deleted according to the backup operation cycle, and even when recovery is necessary, the Company ensures that information already withdrawn or deleted is not reused.

Article 5. Provision of Personal Information to Third Parties

The Company does not, in principle, provide data subjects’ personal information to external parties.
However, exceptions apply in the following cases:
1.Where the data subject has given separate prior consent
2.Where there are special provisions in the law or it is necessary to comply with legal obligations
3.Where it is deemed necessary for the urgent protection of the life, body, or property of the data subject or a third party

Article 6. Outsourcing of Personal Information Processing

The Company outsources the following personal information processing tasks to provide the Service smoothly.

When entering into outsourcing agreements, the Company specifies in contracts or other documents, in accordance with applicable laws, matters such as the prohibition of processing personal information beyond the purpose of the outsourced task, security measures, restrictions on sub-outsourcing, supervision of the processor, and liability for damages, and supervises whether the processor handles personal information securely. If the content of the outsourced tasks or the processor changes, the Company will disclose such changes through this Privacy Policy without delay.

Article 7. Cross-Border Transfer of Personal Information

The Company may transfer personal information abroad as follows to provide the Service.

The Company’s primary service data (member information, habit records, photos, etc.) is stored and processed in the AWS Seoul Region (ap-northeast-2) in the Republic of Korea

Article 8. Measures to Ensure the Security of Personal Information

The Company takes the following measures to ensure the security of personal information.

1. Administrative Measures
Establishment and implementation of the privacy policy, minimization of access rights to personal information, management of personal information handlers, internal inspections, and access control.

2. Technical Measures
One-way encryption (hashing) of passwords
Secure storage and management of authentication tokens
Access rights management and per-user data ownership verification
Retention and monitoring of access records to personal information processing systems
HTTPS (TLS) encrypted communications
Prevention of brute-force attacks through login attempt limits
Expiration policy of 15 minutes for access tokens and 30 days for refresh tokens, with token rotation
Automatic invalidation and deletion of expired data

3. Physical Measures
Server infrastructure is operated in secure data centers with physical access controls in place.

Article 9. Automated Decision-Making

The Company uses artificial intelligence (AI) technology within the Service to perform the following automated processing.

1. AI Habit Coaching Comments
When a user saves a habit record, the AI may automatically generate a personalized coaching comment of one to two sentences. The information used includes the habit title, identity statement, streak count, and note content; directly identifying information such as email or name is not transmitted. Users may disable this feature in the settings of each individual habit within the app.

2. AI Habit Reports
Upon the user’s request, the AI may analyze the user’s habit performance and generate a report. The information used includes the habit title, identity statement, total achievement days, success rate, longest streak, current streak, and recent note content. This processing does not occur unless requested by the user.
The AI features above are auxiliary functions that generate habit coaching content and do not make decisions that significantly affect the rights or obligations of data subjects. Nevertheless, data subjects may object to automated processing or request an explanation, and such requests may be directed to the Personal Information Protection Officer described in Article 13.

Article 10. Transmission of Marketing Communications

The Company transmits marketing communications in compliance with the Act on Promotion of Information and Communications Network Utilization and Information Protection and other applicable laws.
Marketing communications may include app update announcements, events, benefits, promotions, and new service announcements, and such information is sent via app push notifications only to users who have given separate, optional consent.
The Company provides a separate [Optional] Consent to marketing/event notifications option during sign-up or in the settings screen, and users may withdraw their consent at any time through the app settings or device notification settings. The Company processes requests to refuse or withdraw consent to marketing communications without delay.
Habit reminders, security alerts, and notices essential to the use of the Service may be operated separately from marketing communications. Where required by applicable laws, the Company may periodically verify users’ consent to receive marketing communications.

Article 11. Rights and Obligations of Data Subjects and How to Exercise Them

Data subjects may exercise the following rights regarding personal information protection against the Company at any time:
1.Request to access personal information
2.Request to correct errors
3.Request to delete
4.Request to suspend processing
5.Withdrawal of consent and membership withdrawal

Rights may be exercised via email or through in-app functions, and the Company will take action without delay in accordance with applicable laws.

If a data subject requests the correction or deletion of errors in their personal information, the Company will not use or provide the relevant personal information until the correction or deletion is completed.

Article 12. Processing of Personal Information of Children Under 14

The Service is intended for users aged 14 or older. The Company does not allow children under the age of 14 to register as members and verifies the age requirement through the [Required] ‘I am 14 years of age or older’ item during the sign-up process.
The Company does not intentionally collect personal information of children under 14. If the Company becomes aware that personal information of a child under 14 has been collected, the relevant account may be restricted or withdrawn, and the related personal information will be destroyed without delay.

Article 13. Personal Information Protection Officer

The Company designates the following Personal Information Protection Officer to take overall responsibility for personal information processing and to handle complaints and provide remedies for data subjects in relation to personal information processing.

Name: Jae-Young Dokgo (MOAVO)
Position: CEO
Email: moavohabits@gmail.com

As a sole proprietorship, the Company does not maintain a separate dedicated privacy department, and the Personal Information Protection Officer directly performs the related duties. Data subjects may direct all inquiries, complaints, and requests for remedies regarding personal information protection arising from the use of the Service to the Personal Information Protection Officer, and the Company will respond to and process them without delay.

Article 14. Remedies for Infringement of Data Subjects’ Rights

Data subjects may apply for dispute resolution or consultation with the following Korean organizations to seek remedies for personal information infringement.

1. Personal Information Dispute Mediation Committee, 1833-6972 (Korea), https://www.kopico.go.kr
2. Personal Information Infringement Report Center (KISA), 118 (Korea), https://privacy.kisa.or.kr
3. National Police Agency, 182 (Korea), https://ecrm.police.go.kr

Article 15. Changes to This Privacy Policy

This Privacy Policy takes effect on July 1, 2026.
If there are additions, deletions, or modifications to this Privacy Policy, the Company will provide notice at least 7 days before the effective date through in-app announcements or pop-ups. However, for changes that significantly affect the rights of data subjects, notice will be provided at least 30 days in advance.

Privacy Policy Version: v1.0
Effective Date: July 1, 2026