Pickabeau Privacy Policy
In accordance with the Personal Information Protection Act (Korea) and other relevant laws and regulations, Anigma Technologies Inc. (hereinafter the "Company") establishes and discloses this Privacy Policy as follows in order to protect the personal information of users of the Pickabeau service and to handle related complaints promptly and smoothly.
Article 1 (Purposes of Processing and Items of Personal Information Collected)
The Company processes personal information for the following purposes and does not use it for any purpose other than these. If the purpose of use changes, the Company will take necessary measures, such as obtaining separate consent, in accordance with Article 18 of the Personal Information Protection Act.
| Category | Purpose of Processing | Items Collected |
|---|---|---|
| Sign-up (email) | Member identification and identity verification, account management, responding to customer inquiries | [Required] Email, password, name [Required, when signing up in Korean] Date of birth, mobile phone number |
| Sign-up (social account) | Member identification and sign-up/login through a social account | Kakao, Google, Facebook: account identifier, email, profile name Naver: account identifier, email, name, mobile phone number, date of birth Additional input after sign-up: name, (when signing up in Korean) date of birth and mobile phone number |
| Paid report purchase (members and non-members) | Order and payment processing, report delivery, refund processing | [Required] Name, email, mobile phone number (when paying in Korean), order and payment records (product, amount, payment date and time, type of payment method) * Payment method information such as card numbers is processed by the payment service provider and is not stored by the Company. |
| Face, hair and package reports | Producing and delivering customized analysis reports | [Required] Face photo (taken according to the guide), name, age, occupation, mobile phone number, email, survey responses about appearance and style |
| Image consulting report | Face analysis and producing and delivering the image consulting report | [Required] Front and side face photos, name, email, desired mood, double eyelid status |
| Personal color diagnosis | Providing personal color analysis results | [Required] Face photo [Generated] Diagnosis result (tone, skin, hair and eye color values) |
| AI beauty content | Generating simulations and images and (for members) saving usage history | [Required] Face photo [Generated] Result image |
| Partner medical institution consultation request | Calculating a consultation estimate and, where the user has consented, connecting to a consultation with a partner medical institution | [Required] Name, email, mobile phone number (when requesting in Korean), face photo and simulation image, selected medical institution and case [Optional] Purpose of consultation, reason for interest |
| Toss mini app (Apps in Toss) | Identifying mini app users and processing in-app payment orders | Anonymous identification key issued by Toss, in-app payment order records |
| Automatically generated during use of the Service | Service usage statistics, error analysis, prevention of misuse, measuring advertising performance | Access date and time, access records, browser and device information, Service usage records, cookies (Article 9) |
- ① A face photo may constitute sensitive information under Article 23 of the Personal Information Protection Act, so the Company obtains the user's separate consent on the Service screen before receiving the photo. A face photo is used only for the processing purposes above and is not used for advertising or promotional purposes.
- ② When collecting the above personal information, the Company informs the user of the items collected and the purposes through the Service screen or a separate consent screen and obtains consent.
Article 2 (Processing and Retention Period of Personal Information)
The Company processes and retains personal information within the retention period required by law or the retention period to which the user has consented, and destroys it without delay once the period has elapsed or the purpose has been achieved.
| Category | Retention Period |
|---|---|
| Member information | Until membership withdrawal |
| Image consulting photos (front and side) and original analysis data | 30 days from the date of the last photo submission |
| Personal color diagnosis photo | 30 days from the upload date (the diagnosis result is retained until membership withdrawal) |
| Photos for face, hair and package reports | Until the report has been delivered |
| Completed reports (including face photos included in the report) | Until membership withdrawal or the user's deletion request (for the purpose of allowing re-viewing on My Page) |
| AI beauty content result images (member records) | Until membership withdrawal or the user's deletion request |
| Original photos sent for generating AI beauty content | Until the result has been generated |
| Partner medical institution consultation request information | Destroyed immediately upon completion of the estimate calculation (24 hours at most). Where it has been provided to a partner medical institution, the Company's copy is destroyed within one week after provision |
| Order and payment records | The period under the Act on the Consumer Protection in Electronic Commerce (items (d) and (e) below). Retained for this period even after membership withdrawal |
- Notwithstanding the table above, in the following cases the information is retained until the period set out in each item.
- (a) Where an investigation or inquiry due to a violation of relevant laws and regulations is in progress: until that investigation or inquiry ends
- (b) Where a claim or debt relationship arising from use of the Service remains: until that claim or debt relationship is settled
- (c) Records on labeling and advertising under the Act on the Consumer Protection in Electronic Commerce: 6 months
- (d) Records on contracts or withdrawal of offers, payment of charges and supply of goods, etc. under the same Act: 5 years
- (e) Records on consumer complaints or dispute resolution under the same Act: 3 years
- (f) Records on website visits (log records, access location tracking data) under the Protection of Communications Secrets Act: 3 months
Article 3 (Provision of Personal Information to Third Parties)
- ① The Company processes users' personal information only within the scope stated in Article 1, and provides it to third parties only in cases falling under Articles 17 and 18 of the Personal Information Protection Act, such as the user's consent or special provisions of law.
- ② The Company provides personal information as follows only where the user has consented to provision to a third party when requesting a consultation with a partner medical institution. The user may refuse consent, and if the user refuses, connection to a medical institution consultation may be restricted.
| Recipient | Purpose of Provision | Items Provided | Retention Period |
|---|---|---|---|
| The partner medical institution with which the user requested a consultation | Expert consultation based on the plastic surgery simulation | Name, contact information, face photo, AI analysis result, selected case, desired consultation content | Until the purpose of the consultation is achieved |
- ③ In the following cases, personal information may be provided without the user's consent in accordance with relevant laws and regulations.
- (a) Where there are special provisions in law or where it is unavoidable in order to comply with obligations under laws and regulations
- (b) Where it is requested by a state agency such as an investigative agency in accordance with procedures set by relevant laws and regulations
Article 4 (Outsourcing of Personal Information Processing)
The Company outsources personal information processing tasks as follows in order to provide the Service smoothly, and when entering into an outsourcing contract, it sets out necessary matters so that personal information is managed safely in accordance with relevant laws and regulations and supervises the contractor.
| Contractor | Outsourced Task |
|---|---|
| Supabase Inc. | Member authentication, database and file storage (Seoul region) |
| Toss Payments Co., Ltd. | Processing payments in Korean won and U.S. dollars |
| PayPal | Processing payments in Japanese yen |
| Viva Republica Inc. (Toss) | Identifying Toss mini app users and processing in-app payments |
| Twilio Inc. (SendGrid) | Sending emails such as verification emails and report completion and retake notices |
| Microsoft Corporation | Storing report files, Service usage statistics and error analysis (Azure Application Insights, Korea Central region), review translation |
| Amazon Web Services, Inc. | Storing report files |
| OpenAI, L.L.C. | Assisting in drafting text for image consulting reports (face photos are not transmitted) |
| Oplux | Generating AI beauty content images |
Article 5 (Overseas Transfer of Personal Information)
The Company transfers personal information overseas as follows in order to provide the Service. Personal information is transmitted over an encrypted network at the time the Service is used, and each contractor's retention period is until the outsourcing purpose is achieved or the retention period in Article 2.
| Recipient | Country of Transfer | Items Transferred | Purpose of Transfer |
|---|---|---|---|
| Twilio Inc. (SendGrid) | United States | Email address, name | Sending emails |
| PayPal | United States, etc. | Name, email, order and payment information | Processing payments in Japanese yen |
| OpenAI, L.L.C. | United States | Image consulting analysis results (excluding face photos) | Assisting in drafting report text |
Users may refuse the overseas transfer. However, if a user refuses, it may be difficult to use services that require the relevant task (payment, receiving emails, image consulting reports, etc.). Please communicate your refusal using the contact information in Article 10.
Article 6 (Procedures and Methods for Destroying Personal Information)
- ① The Company destroys personal information without delay when it becomes unnecessary, such as when the retention period has elapsed or the processing purpose has been achieved. For information with a set retention period, such as image consulting and personal color photos, the Company checks daily through an automated procedure and destroys it.
- ② When a member withdraws, the Company deletes the account together with the photos, simulation records, and diagnosis and report records provided by the member. However, information that must be retained under laws and regulations pursuant to Article 2 is stored separately from other information for the relevant period and then destroyed.
- ③ Information in the form of electronic files is permanently deleted by a method that cannot be restored, and information recorded on paper is shredded or incinerated.
Article 7 (Rights and Obligations of Users and Legal Representatives and How to Exercise Them)
- ① Users may at any time request access to, correction of, deletion of, suspension of processing of, and withdrawal of consent to their personal information. Members may withdraw consent and request deletion of personal information through "Withdraw membership" on My Page.
- ② The rights in paragraph ① may be exercised by writing, telephone, email or the like to the contact in Article 10, and the Company shall take action without delay (within 10 days from the date of receiving the request) and notify the result. If the period is unavoidably extended, the Company shall notify the reason and the period together.
- ③ The rights in paragraph ① may be exercised through an agent such as a legal representative or a person who has been given authority. In this case, a power of attorney in the form of Attachment Form No. 11 of the Notice on Methods of Processing Personal Information must be submitted.
- ④ Requests for access to personal information and suspension of its processing may be restricted under Article 35 (4) and Article 37 (2) of the Personal Information Protection Act, and deletion cannot be requested for personal information designated as a collection target by other laws.
- ⑤ The Company verifies whether the person requesting the exercise of rights is the data subject or a legitimate agent.
Article 8 (Measures to Ensure the Security of Personal Information)
- ① Technical measures: encryption of personal information in transit (HTTPS), encrypted storage of passwords, access control for the database and file storage
- ② Administrative measures: limiting personal information handlers to the minimum number of people necessary for work, regular training for personal information handlers
- ③ Users are also asked to take care that their passwords and the like are not exposed to third parties.
Article 10 (Chief Privacy Officer and Person in Charge of Access Requests)
The Company has designated a Chief Privacy Officer and a responsible department as follows to oversee matters relating to personal information processing and to handle user complaints and provide remedies for damage. For inquiries, access requests, complaint handling and the like relating to personal information that arise while using the Service, please contact the following and we will respond without delay.
| Category | Name / Department | Contact |
|---|---|---|
| Chief Privacy Officer | Kyungmin Cho (Chief Executive Officer) | contact@anigma-ai.com |
| Person in charge of receiving and handling access requests | Jongtae Yoon | jongtae@anigma-ai.com |
| Service customer center | Pickabeau Operations Team | pickabeau@anigma-ai.com / 0507-1391-4331 |
Article 11 (Remedies for Infringement of Rights)
To obtain relief for an infringement of personal information, users may apply to the following organizations for dispute resolution, consultation and the like.
- Personal Information Dispute Mediation Committee: www.kopico.go.kr / 1833-6972 (no area code)
- Personal Information Infringement Report Center: privacy.kisa.or.kr / 118 (no area code)
- Supreme Prosecutors' Office: www.spo.go.kr / 1301 (no area code)
- National Police Agency: ecrm.police.go.kr / 182 (no area code)
A person whose rights or interests have been infringed by a disposition or omission of the head of a public institution in response to a request under Article 35 (access), Article 36 (correction and deletion) or Article 37 (suspension of processing, etc.) of the Personal Information Protection Act may file an administrative appeal under the Administrative Appeals Act (Central Administrative Appeals Commission, www.simpan.go.kr).
Article 12 (Processing and Use of Anonymized Information)
- ① The Company may anonymize (statistically process) the personal information collected under Article 1 so that individuals can no longer be identified, and use it for the purpose of developing and improving the quality of the Service.
- ② Anonymization means processing so that, taking time, cost, technology and the like reasonably into account, an individual can no longer be identified even if other information is used, and anonymized information is not subject to the Personal Information Protection Act pursuant to Article 58-2 of that Act.
Article 13 (Changes to the Privacy Policy)
- ① Where content is added, deleted or modified, the Company will announce it through the Service screen from 7 days before it takes effect, and will announce important changes affecting users' rights, such as the items collected or the purposes of use, from 30 days before it takes effect.
- ② The previous Privacy Policy (effective January 1, 2025) is replaced by this Policy.