Learn Languages with Retriever — International Transfer of Personal Data

6. International transfers

Most of the processors in section 5 are incorporated and operate servers outside Korea, so personal data is transferred abroad to the extent needed to run the Service (PIPA Art. 28-8). There are two legal grounds: processing and storage entrusted for the performance of the Service (database and server hosting, read-aloud synthesis, speech recognition in the Apps in Toss mini-app, notification and email delivery, collection of error and crash reports from the iOS and Android apps) rests on Art. 28-8(1)(iii) and is disclosed through this policy, while transfers for the AI tutor, Daily Talk and pronunciation coaching rest on Art. 28-8(1)(i) and require your separate in-app consent (section 10). Transfers for AI conversation in the Apps in Toss mini-app likewise rest on Art. 28-8(1)(i) and require your separate consent in the mini-app's Settings (section 10-2). The operational notifications of new sign-ups and of developer feedback and app satisfaction ratings (Slack) are processing and storage of member accounts entrusted to a processor and disclosed through this policy under Art. 28-8(1)(iii). For transfers from the EEA/UK we rely on the European Commission's Standard Contractual Clauses included in each provider's data processing agreement.

How to refuse a transfer — storing your account and learning record (rows 1–2) is essential to the Service, so refusing it means you cannot register or sync progress. Every other transfer can be refused by turning the feature off: Settings > Sound to disable AI voice, simply not using the AI tutor, and Settings > Notifications to disable notifications. Refusing these does not restrict the rest of the learning features. The transfer of error and crash reports from the iOS and Android apps (row 10) is built into the app so that we can find why it terminated unexpectedly, and cannot be refused other than by no longer using the app — it carries only technical data and your account ID, never anything you wrote or said. This transfer does not occur on the web or in the Apps in Toss mini-app. The operational notification of new sign-ups (row 11) happens once when an account is created, so it cannot be refused other than by not registering — it carries only the items in the table above, never your password, name or IP address. In the Apps in Toss mini-app it happens once when Toss sign-in creates a new account (there is no email address), and not at all if you do not sign in. The notification of developer feedback and app satisfaction ratings (row 11 of the table above) happens only when you send feedback or a rating yourself, and not at all if you do not — even then your account's email address, name and account ID are never attached.

Refusing in the Apps in Toss mini-app — the transfer for mini-app AI conversation (rows 3–5) happens only if you consent on the AI conversation consent card in Settings; if you do not consent, or tap 'Turn off AI conversation (withdraw consent)' on the same card, our server blocks the request itself and nothing you write is sent — you lose only the AI conversation round, Daily Talk and AI Call, and the rest of the lesson continues. The transfer of speaking-round audio does not happen if you decline microphone permission; only that round is skipped and the rest of the lesson continues. Read-aloud in the mini-app uses server AI voice only (there is no built-in device voice), so the transfer of app-authored study sentences cannot be refused other than by not using the mini-app — those sentences contain none of your personal data. Account and learning-record storage (row 1) happens in the mini-app only if you choose Toss sign-in; if you do not, the mini-app works the same (and even when signed in, the mini-app's learning record itself is never uploaded). This notice is also available as a separate page.

10-2. The Apps in Toss mini-app

The Learn Languages with Retriever mini-app offered inside the Toss app through "Apps in Toss" (the "mini-app") differs from the iOS/Android apps and the web in the ways below. For mini-app users this section prevails over the other sections of this policy.

• An account is optional. You can use the mini-app without signing in, and then you are identified solely by the Toss anonymous key the Toss app issues to the mini-app. The key is not linked to any account; our server verifies the key that accompanies a read-aloud, speaking or AI conversation request with Toss, counts daily usage only under a value re-hashed with our secret key, and never stores the raw key. What happens if you choose Toss sign-in ('Confirm account with Toss') in Settings is described in the Toss sign-in item below.
• Your learning record stays on the device. Progress and settings are kept only in the mini-app storage inside the Toss app, and even if you sign in with Toss the mini-app's learning record is never sent to or synced with our servers. Removing the mini-app from the Toss app deletes them, and we cannot restore them.
• Speaking practice audio goes through our server. The mini-app has no on-device speech recognition, so the audio recorded in a speaking round is received by our server and forwarded to the speech-recognition processor in sections 5 and 6 (OpenAI, L.L.C., United States) to be turned into text. Our servers do not store the audio; the processor keeps it only for abuse monitoring for up to 30 days, then deletes it, and the resulting text is used only to check your answer and is not stored. Microphone permission is requested the first time you start a speaking round; declining skips only that round, with no penalty.
• Read-aloud uses server AI voice only. The mini-app has no built-in device voice, so the switch to device voice described in section 10 does not apply. What is sent is only an app-authored study sentence, never text you wrote.
• AI conversation is used only if you consent. Mini-app AI conversation means three things — the short 'AI conversation' round that appears now and then in a lesson, Daily Talk (messaging with a figure) and AI Call (talking with a figure by voice); there is no pronunciation coaching. All three open only after you consent on the AI conversation consent card in the mini-app's Settings, and then (1) the sentences you type and the earlier lines of that conversation, the audio you speak in AI Call, the figure you chose, the language you are learning, the lesson difficulty and your native-language setting (Korean) are sent (2) to the AI processors in sections 5 and 6 (primary provider: OpenAI, L.L.C., United States) (3) solely to generate replies and for speech recognition and read-aloud. No name, contact details, Toss account data or learning record is sent; our servers store neither the conversation nor the audio; the processors keep it only for abuse monitoring for up to 30 days (alternate provider Google: 55 days), then delete it, and never use it for model training. Consent is recorded only as the time of your latest consent under the usage-counting identifier above; tapping 'Turn off AI conversation (withdraw consent)' on the same card erases it at once, and from then on our server blocks AI requests. If you do not consent, only these three do not open and the lesson is otherwise unchanged; there is a daily cap on conversations.
• No push notifications, email or in-app purchases. The mini-app is free, and we collect no push token, email address or purchase record from it. The error and crash records described in section 2 are collected in the mini-app on the same terms (identifying strings masked, deleted after 90 days). The mini-app has no native app process of ours, however, so nothing is transferred to the error-reporting processor (Sentry) in section 5. Friend invitations create a link to share: a link shared without signing in carries no code at all, and a link shared by a Toss sign-in account carries that account's invitation code (a short random string).
• Toss sign-in is used only if you choose it. When you tap 'Confirm account with Toss' in the mini-app's Settings, the Toss app shows its consent screen, and only if you agree does our server check with Toss and create or find your account using your user identifier (userKey). Toss sends your name (USER_NAME) encrypted; we never decrypt, store or display it, and we receive no email, phone number, birthday, gender or CI. We never merge accounts automatically by name, email or CI; to merge with an existing web/app account you must create a one-time link code valid for 10 minutes and enter it yourself. Only while you are signed in are the analytics records in section 2, lesson-completion records (date and count), any app satisfaction rating you leave (rating and comment — the rating prompt opens only for Toss-signed-in accounts) and any feedback you send with 'Send feedback to the developer' in Settings (feedback text, display language, app version — its arrival triggers the operational notification in section 6; the feedback menu is shown only to Toss-signed-in accounts) kept under that account and friend-invitation rewards credited to it; our session token is kept only in the mini-app screen's memory. If you unlink this Service in the Toss app, withdraw consent to the Toss sign-in terms or leave Toss, Toss notifies our server, and we remove the Toss link and any unused link codes from that account and end existing sign-ins. If Toss is the account's only sign-in method, the account and its server learning record are deleted too. If processing fails we do not treat the deletion as done and process it again. Unlinking is not the same as deleting your account — to delete the whole account use the methods in section 8.
• Your rights — for a user who has not signed in, the only records our server keeps are per-day usage counts and the time of AI-conversation consent, both tied to the usage-counting identifier; we cannot identify a person from that identifier, so there is no further personal data to disclose or correct. You delete your AI-conversation consent record by withdrawing consent on the AI conversation consent card in Settings, which takes effect at once, and the learning record and settings on the device are erased by removing the mini-app from the Toss app. A Toss sign-in account can be deleted from the account card in the mini-app's Settings (after you confirm your identity with Toss again — or with the password, for an account that has one), and you can remove the Toss link by unlinking in the Toss app. For anything else, write to contact@apochopo.com.
• The handling of personal data by the Apps in Toss platform and the Toss app itself (including issuing the anonymous key) is governed by the Toss operator's privacy policy.

Your right to refuse, and what refusing means

• You have the right to refuse consent to the transfers above.
• Storing your account and learning record (rows 1–2 of the table in section 6) — if you refuse, you cannot register or sync your progress across devices. This transfer is processing and storage essential to providing the Service and is disclosed through this policy under Art. 28-8(1)(iii).
• Transfers for the AI tutor, Daily Talk and pronunciation coaching (rows 3–5) — these do not happen if you choose 'Don't allow' on the in-app consent screen. Refusing locks only those three features; lessons, review and listening practice remain available.
• AI conversation in the Apps in Toss mini-app — in-lesson conversation round, Daily Talk and AI Call (rows 3–5 of the table in section 6) — happens only if you consent on the AI conversation consent card in the mini-app's Settings, and does not happen if you do not consent or tap 'Turn off AI conversation (withdraw consent)' on the same card. Refusing withholds only those three; the rest of the lesson continues.
• Speaking audio in the Apps in Toss mini-app — not transferred if you decline microphone permission; only that round is skipped, with no penalty. Read-aloud in the mini-app (the transfer of app-authored study sentences) cannot be refused other than by not using the mini-app, because the mini-app has no built-in device voice — those sentences contain none of your personal data.
• Other transfers (push notifications, email delivery, payments) can be refused by not enabling, or by turning off, the feature concerned.
• Error and crash reports from the iOS and Android apps (row 10 of the table in section 6) — this transfer is built into the app so that we can find why it terminated unexpectedly, and cannot be refused other than by no longer using the iOS/Android app. It carries only technical data and your account ID, never anything you wrote or said. It does not occur on the web or in the Apps in Toss mini-app.
• Operational notification of new sign-ups (row 11 of the table in section 6) — happens once when an account is created, and cannot be refused other than by not registering. It carries only your email address, sign-up method, sign-up time and region of access (country and city) — never your password, name or IP address. In the Apps in Toss mini-app it happens once when Toss sign-in creates a new account, and not at all if you do not sign in.
• Toss sign-in in the Apps in Toss mini-app (rows 1–2 of the table in section 6) — happens only if you choose Toss sign-in ('Confirm account with Toss') in the mini-app's Settings. If you refuse (do not sign in), you lose only the account features and friend-invitation rewards; the mini-app works the same. After signing in you can remove the link by unlinking this Service or withdrawing consent to Toss sign-in in the Toss app (section 10-2).
• Notification of developer feedback and app satisfaction ratings (row 11 of the table in section 6) — happens only when you send feedback or leave an app satisfaction rating in Settings, and not at all if you do not. It carries only the feedback text (anything that looks like an email address is masked), display language, app version, platform, time sent and a reference number unrelated to your account, or the rating, comment, where the prompt opened, platform, app version and time sent — your account's email address, name and account ID are never attached.
• To withdraw consent or ask anything else, use the app's Settings screen or write to contact@apochopo.com.

Consent statement

I have read and understood the notice above and consent to the transfer of my personal data abroad as described.