1. Purposes of processing
We process personal information only for the purposes below. If a purpose changes, we take the steps PIPA Article 18 requires, such as obtaining separate consent.
- Sign-up and tenant setup: verifying sign-up requests and the administrator, creating the company workspace (tenant), and contacting you about sign-up
- Providing the Service: sign-in and permissions, and the features you request — AI agent chat, workflow automation, e-approval, documents, mail and calendar
- Consultations: confirming consultation requests and contacting you
- Support and notices: answering inquiries and sending notices needed to run the Service (outages, security, changes to terms)
- Reliability and security: preventing misuse, keeping access logs, analysing incidents
- (Only if you opted in) product news and pilot program emails
2. Personal information we process
| Category | Items | How collected |
|---|---|---|
| Sign-up request | Company name, business registration number, administrator email, administrator name | Sign-up form |
| Account | Name, email, password (stored one-way hashed), tenant and role | Sign-up and invitation |
| Consultation | Required: name, company, mobile number, email / Optional: job title, interests, message | Consultation form |
| Information customers enter while using the Service | Members' names, emails, departments, titles, grades, employee numbers, contact details; business documents; AI agent conversations; approval and work records | Entered by customer administrators and members |
| Connected services (only if you connect them) | Mail (headers, bodies, attachments), calendar events, files, the connected account's email, access tokens | Google, Microsoft and other APIs (with your authorization) |
| Generated automatically | IP address, browser and device information, access times, usage records, cookies | Generated while you use the Service |
For member information and business data a customer puts into the Service, the customer is the controller (personal information controller). The Operator processes it on the customer's behalf, only on the customer's instructions and within the contract.
3. Retention periods
We keep personal information only for the period required by law or agreed with you, and destroy it without delay when that period ends.
- Sign-up requests: until sign-up is completed or the request is withdrawn
- Accounts: until you close your account or the customer's contract ends
- Consultation requests: one year after the consultation ends (destroyed immediately if you ask earlier)
- Customer data: for the term of the customer's contract; after it ends, destroyed after a period in which the customer can export it
- Connected-service tokens: until you disconnect the service or the account is deleted
- Access logs: 3 months (Protection of Communications Secrets Act)
- For paid use, contract and payment records: 5 years; consumer complaint and dispute records: 3 years (Act on Consumer Protection in Electronic Commerce)
4. Provision to third parties
We process personal information only within the purposes in Section 1 and do not provide it to third parties except with your consent or where the law specifically allows (PIPA Articles 17 and 18). We currently provide no personal information to third parties.
5. Processors (outsourcing)
We use the processors below to provide the Service. Our contracts with them prohibit processing beyond the stated purpose and require technical and organisational safeguards, restrict sub-processing, and set out supervision and liability. We supervise their handling of personal information.
| Processor | Work entrusted |
|---|---|
| Microsoft Corporation (Microsoft Azure) | Hosting, database and file storage, secrets storage (Key Vault), backups |
| Anthropic, PBC | AI features you request — chat responses, document drafts and analysis — using Claude models |
| OpenAI, L.L.C. | AI responses (when the customer has selected and allowed these models) |
| Google LLC (Gemini API) | AI responses (when the customer has selected and allowed these models) |
| Perplexity AI, Inc. | Web research searches you request (search queries) |
| Imply Data, Inc. | Service observability (logs and traces for incident analysis) |
If a customer registers its own AI model key (BYOK), those requests go to the provider the customer has contracted with, under the customer's account. We will update this policy without delay if processors or entrusted work change.
6. Services you connect
Only when you authorize a connection do we read or write data in your account through these services' APIs. You can disconnect at any time on the Service's Connections screen or in the provider's account settings.
| Service | Scope | Use |
|---|---|---|
| Google (Gmail, Google Calendar, Google Drive) | Read, send and organise mail; read and write events; read and write files | Mailbox, calendar and file explorer, and AI agents carrying out your requests |
| Microsoft (Outlook mail and calendar, OneDrive — Microsoft Graph) | Read and send mail; read and write events; read and write files | Same |
| Box | Read and write files | File explorer and sync |
7. Google API Services User Data Policy (Limited Use)
The Service's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy (https://developers.google.com/terms/api-services-user-data-policy), including the Limited Use requirements.
- We use Gmail, Google Calendar and Google Drive data only to provide the features you see on screen or ask an AI agent for — reading, summarising, drafting replies to and sending mail; checking and adding events; opening and saving files.
- We do not use this data for advertising (including personalised, retargeted or interest-based ads), and we do not sell it.
- We do not use this data to develop, improve or train generalised AI or machine-learning models. When we pass it to an AI model provider to carry out a feature you requested, we limit it to that purpose and use only API terms under which the provider does not train models on the input.
- Humans do not read this data, except with your explicit consent for specific data, when necessary for security purposes (such as investigating abuse), to comply with applicable law, or when aggregated and anonymised for internal operations.
- We do not transfer this data to third parties except as necessary to provide or improve user-facing features, for security, or to comply with applicable law.
8. International transfers
Our servers and database are in Microsoft Azure's Korea Central region. Personal information is transferred abroad for the processing below (PIPA Article 28-8). Transfers happen each time you use the relevant feature, over encrypted connections (TLS).
| Recipient (contact) | Country | Items | Purpose / retention |
|---|---|---|---|
| Anthropic, PBC (anthropic.com/legal/privacy) | United States | Content of AI requests (conversations, documents, mail and other data you include) | Generating AI responses / short retention per the provider's policy, then deletion |
| OpenAI, L.L.C. (openai.com/policies/privacy-policy) | United States | Same (if these models are selected and allowed) | Same |
| Google LLC (policies.google.com/privacy) | United States | Same (if Gemini models are selected and allowed) | Same |
| Perplexity AI, Inc. (perplexity.ai/hub/legal/privacy-policy) | United States | Web research queries | Returning search results / per the provider's policy |
| Imply Data, Inc. (imply.io/privacy-policy) | United States (processing region per contract) | Service logs and traces (internal user identifiers, request records) | Incident analysis / retention set by the Operator |
| Google LLC, Microsoft Corporation (if you connect them) | United States and each provider's data centres | Mail, events and files you send | Carrying out your requests / per your account settings |
If you do not want your information transferred abroad, ask your company administrator to turn off the relevant AI models, research or connections, or contact us. Those features will then be unavailable.
9. Destruction
When the retention period ends or the purpose is achieved, we destroy personal information without delay. Where another law requires us to keep it, we store it separately from other personal information.
- Electronic files: deleted so they cannot be recovered (database rows and storage objects deleted; backups overwritten when their retention cycle ends)
- Paper: shredded or incinerated
10. Your rights and how to exercise them
You may at any time ask us to give you access to, correct, delete or stop processing your personal information, or withdraw consent. Send a request in writing or by email ([Operator details not configured]) and we will act without delay (within 10 days). A representative must submit a power of attorney.
For member information entered by a customer, the customer is the controller; we will forward your request to the customer and help them handle it.
Information the law requires us to collect cannot be deleted, and access or suspension may be limited where it could harm another person's rights.
11. Security measures
- Organisational: an internal management plan, and a minimum number of trained staff handling personal information
- Technical: encryption in transit (TLS), one-way password hashing, encrypted storage of connected-service tokens and API keys (AES-256-GCM, with keys in a cloud key vault), per-tenant data separation, role-based access control
- Records: data changes, approvals and use of privileges are kept in tamper-evident audit logs
- Physical: access control at our cloud provider's (Microsoft Azure) data centres
13. Privacy officer
We have designated a privacy officer who oversees personal information processing and handles complaints and remedies.
- Privacy officer: [Operator details not configured]
- Contact: [Operator details not configured]
14. Remedies
For remedies for infringement of personal information, you can apply for dispute resolution or advice to these Korean authorities.
- Personal Information Dispute Mediation Committee: 1833-6972, www.kopico.go.kr
- Privacy Infringement Report Center (KISA): 118, privacy.kisa.or.kr
- Supreme Prosecutors' Office: 1301, www.spo.go.kr
- Korean National Police Agency: 182, ecrm.police.go.kr
15. Changes to this policy
This policy applies from [Operator details not configured]. We will announce additions, deletions or changes on the Service at least 7 days before they take effect (30 days for changes that significantly affect your rights).
16. Additional information for EU and UK users (GDPR)
This section gives additional information required by the General Data Protection Regulation (GDPR, Regulation (EU) 2016/679) and the UK GDPR when we process personal data of people in the European Union (EU), the European Economic Area (EEA) or the United Kingdom (GDPR Art. 3, 13 and 14). It applies together with sections 1–15; where they differ, the more protective provision for the data subject applies.
16-1. Controller and processor
| Data | Role | Explanation |
|---|---|---|
| Member data and business data your company (the customer) enters into the service | Company = controller · Operator = processor | Your company decides the purposes and means of processing; the operator processes only on the company's documented instructions and the Data Processing Addendum (DPA) (GDPR Art. 28). |
| Sign-up applications, sales consultations, sign-in accounts and website usage records | Operator = controller | The operator processes these directly to run the service. |
If you are a member of a company, the fastest way to exercise your rights is through your company. Requests sent from "Account settings · My data" go to your company's administrator, and the operator supports the company technically.
16-2. Purposes and legal bases (GDPR Art. 6)
| Purpose | Legal basis |
|---|---|
| Creating accounts, sign-in and providing requested features (AI Agents, e-approval, documents, etc.) | Performance of a contract (Art. 6(1)(b)) |
| Processing member data (the company is the controller) | Basis chosen by the company — usually employment contract (b) · legal obligation (c) · legitimate interests (f) |
| Security, fraud prevention, access logs and audit records | Legitimate interests (Art. 6(1)(f)) · legal obligation (c) |
| Statutory retention (accounting, tax and employment records) | Legal obligation (Art. 6(1)(c)) |
| Responding to sales consultations | Steps at your request before a contract (b) · legitimate interests (f) |
| Product news e-mails (optional) | Consent (Art. 6(1)(a)) — you may withdraw it at any time (Art. 7(3)) |
You have the right to object to processing based on legitimate interests (Art. 21).
16-3. Retention periods
Retention periods are as in section 3. Your company sets the retention of company data; company administrators can set retention for AI memories, request records and export files under "Privacy management". Records still under a statutory retention period are stored separately from other data and destroyed when the period ends.
16-4. Recipients and sub-processors
| Sub-processor | Processing | Location |
|---|---|---|
| Microsoft Corporation (Azure) | Servers, database, file storage, key vault, backups | Republic of Korea (Korea Central) |
| Anthropic, PBC | AI model (Claude) responses | United States |
| OpenAI, L.L.C. | AI model responses and speech transcription (if your company allows it) | United States |
| Google LLC (Gemini API) | AI model responses (if your company allows it) | United States |
| Voyage AI, Inc. | Document embeddings (vectors) for knowledge search | United States |
| Together Computer, Inc. (Together AI) | Running open-weight AI models (if configured) | United States |
| Perplexity AI, Inc. | Web research search queries | United States |
| Imply Data, Inc. | Service observability (logs and traces) | United States (region per contract) |
| Kakao Corp. | Address search window (loaded only when you click address search) | Republic of Korea |
We send AI model providers only what the task you requested needs (your question and the relevant parts of the documents, e-mails or business records used for it). Resident registration numbers, card numbers and similar data are masked before files are uploaded or added to the knowledge index. Under the providers' API terms, input data is not used to train models. If your company registers its own key (BYOK), requests go to the provider account your company contracted.
Services you connect yourself, such as Google, Microsoft or Box, are described in section 6. We announce new or changed sub-processors in advance through this policy and the DPA, and your company may object.
16-5. International transfers
- EU/EEA → Republic of Korea: on 17 December 2021 the European Commission decided that the Republic of Korea ensures an adequate level of protection (Commission Implementing Decision (EU) 2022/254, GDPR Art. 45). Transfers to the service's primary storage (Azure Korea Central) rely on this adequacy decision.
- UK → Republic of Korea: transfers rely on The Data Protection (Adequacy) (Republic of Korea) Regulations 2022.
- Republic of Korea → United States and other sub-processor locations: where the provider is certified under the EU-U.S. Data Privacy Framework (adequacy decision of 10 July 2023) we rely on that decision; otherwise on the Commission's Standard Contractual Clauses (SCC, Commission Implementing Decision (EU) 2021/914, Art. 46(2)(c)) with supplementary measures (encryption in transit, data minimisation). We also meet the cross-border transfer requirements of Korea's Personal Information Protection Act (Art. 28-8).
- You can request a copy of the transfer safeguards using the contact details in section 16-8.
16-6. Your rights (GDPR Art. 15–22)
- Access (Art. 15) — the personal data we process and a copy
- Rectification (Art. 16) — correct inaccurate or incomplete data
- Erasure (Art. 17) — when there is no longer a ground to process
- Restriction (Art. 18) — storage only until a dispute is resolved
- Portability (Art. 20) — receive your data in a machine-readable format (JSON)
- Objection (Art. 21) — to processing based on legitimate interests
- Not to be subject to solely automated decisions (Art. 22)
- Withdraw consent (Art. 7(3)) — this does not affect the lawfulness of processing before withdrawal
How to exercise them: in the service, open "Account settings · My data" (the globe menu at the top after signing in) to download your data or send a request, or e-mail [Operator details not configured]. After verifying your identity we respond within one month of receipt; for complex or numerous requests we may extend this by up to two further months and will tell you why (Art. 12(3)). Requests are free of charge (Art. 12(5)).
Even after an erasure request, records we must keep by law (accounting and tax books and vouchers, employment records such as the register of workers) are kept separately, with the reason and period explained, and destroyed when the period ends (Art. 17(3)(b)).
16-7. Automated decision-making and AI
The service's AI Agents produce drafts, summaries, analyses and simulations. Decisions with legal or similarly significant effects — such as performance evaluations, hiring or approvals — are always made by a person; AI alone never makes them (GDPR Art. 22, PIPA Art. 37-2). Performance evaluations use only aggregate metrics disclosed in advance, and you can contest the result and ask for human review.
16-8. Contacts and representatives
Privacy questions and requests: [Operator details not configured]
For member data, the fastest route is your company's (the controller's) privacy contact.
16-9. Right to lodge a complaint (GDPR Art. 77)
- EU/EEA: the supervisory authority of the member state where you live, work or where the infringement took place — list at https://edpb.europa.eu/about-edpb/about-edpb/members_en
- United Kingdom: Information Commissioner's Office (ICO) https://ico.org.uk
- Republic of Korea: Personal Information Protection Commission https://www.pipc.go.kr and the bodies listed in section 14
16-11. Security and breach notification
In addition to the measures in section 11, e-mail addresses, phone numbers and similar values are masked before they are written to audit records (GDPR Art. 5(1)(c) and 25). If we become aware of a personal data breach we inform the company (controller) without undue delay; for processing where the operator is the controller we notify the supervisory authority within 72 hours (Art. 33) and inform data subjects without undue delay where there is a high risk (Art. 34). We also notify and report under Korea's Personal Information Protection Act (Art. 34, 72 hours).
Operator
- Operator (legal entity)
- 아이오니스 주식회사
- Representative
- 박성진
- Business registration no.
- 516-87-03503
- Address
- 서울특별시 강남구 영동대로 602, 6층 피148호(삼성동, 삼성동 미켈란 107)
- Contact email
- [Operator details not configured]
- Phone
- [Operator details not configured]
Read the Terms of ServiceView the Data Processing Addendum (DPA)Back to top