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This is a translation provided for convenience. If it differs from the Korean version, the Korean version prevails.

Pinly Location-Based Services Terms

In accordance with the Act on the Protection, Use, etc. of Location Information of the Republic of Korea (the "Location Information Act"), these Terms set out matters concerning the use of location information and location-based services in "Pinly" (the "Service"), a family location-sharing service provided by WAFFLE (the "Company"). The Company has completed its registration as a location-based service business for small businesses and others under Article 9-2 of the Location Information Act (Registration No. 1220).

  • Effective date: 2026-07-01

Article 1 (Purpose)

These Terms set out the rights, obligations, and responsibilities between the Company and personal location information subjects (the "Users"), and other necessary matters, in connection with the location-based services provided by the Company.

Article 2 (Effect and Amendment of the Terms)

  1. These Terms take effect when a user who wishes to use the Service agrees to them.
  2. The Company may amend these Terms to the extent that doing so does not violate applicable laws such as the Location Information Act. When amending them, the Company will state the effective date and the reason for the amendment and give advance notice through in-app notices or similar means from 7 days before the effective date (30 days for changes that are unfavorable to users or material).

Article 3 (Description of the Service)

The location-based services provided by the Company are as follows:

  1. Real-time location sharing among family (group) members
  2. Arrival and departure alerts for designated places (geofences) and low-battery alerts
  3. In an emergency (SOS), immediately sharing one's location and device status (battery level, charging status, etc.) with family (group) members and sending alerts
  4. Storage and viewing of location history
  5. Map display and geocoding (address conversion) features incidental to the services above

Article 4 (Fees and Conditions)

  1. The Company does not charge users any separate fee for the collection, use, or provision of location information itself, and provides both a free service and a paid service (Pro subscription) as follows:

    • Free: basic location-based services, such as family location sharing, real-time location viewing, and basic place alerts, can be used free of charge.
    • Paid (Pro subscription): a monthly or annual subscription product that gives access to convenience features added on top of the location-based services. Specific fees follow the amounts shown on the in-app purchase screen and in each store (Apple App Store, Google Play).
  2. The actual amount charged for a paid subscription follows the price shown in each store and may vary according to store policies, exchange rates, promotions, and similar factors. Payment, automatic renewal, cancellation, and refunds for subscriptions follow the policies of the store used for payment.

  3. The fee for the paid product (Pro subscription) is not consideration for the collection, use, or provision of location information, but a fee for using convenience features added to the location-based services. If a user withdraws consent to the collection, use, or provision of location information or stops sharing their location, no separate fee is charged for that in itself.

  4. Mobile data charges incurred while using the Service are borne by the user in accordance with the policies of the user's mobile carrier.

Article 5 (Purposes and Retention Period for Collecting, Using, and Providing Location Information)

  1. Purposes of collection, use, and provision

    • Real-time location sharing among family members and map display
    • Alerts for arrival, departure, low battery, and similar events
    • Immediately sharing location and device status with family members in an emergency (SOS)
    • Providing location history
  2. Location information items collected: latitude and longitude coordinates, location accuracy, device battery level, charging status

  3. Collection method: based on the user's permission, location information is collected periodically, including while the app is in the background, to provide family location sharing.

  4. Retention period

    • The Company destroys location information without delay once the purpose of its collection, use, and provision has been achieved.
    • Location history is deleted automatically 30 days after it is collected.
    • However, records confirming the collection, use, and provision of location information under Article 16(2) of the Location Information Act are recorded and preserved automatically and retained for at least 6 months.

Article 6 (Use or Provision of Personal Location Information)

  1. The Company does not provide personal location information to third parties without the user's consent.

  2. By the nature of the family location-sharing service, a user's location information is shared with other members of a group the user has consented to join. Users can control whether their location is visible to each family member individually (individual hiding).

  3. When the Company provides personal location information to a third party designated by the user, it immediately notifies the user's device each time of the recipient, the date and time of provision, and the purpose of provision. However, if the user has chosen a specific notification method in advance, that method is followed.

Article 7 (Rights of Personal Location Information Subjects)

  1. Users may at any time withdraw all or part of their consent to the collection, use, and provision of personal location information.

  2. Users may at any time request a temporary suspension of the collection, use, and provision of personal location information. The Company will not refuse such a request and has technical means in place for it (pausing location sharing in the app, individual hiding, etc.).

  3. Users may request access to or notification of the following materials, and may request correction if the materials contain errors:

    • Records confirming the collection, use, and provision of location information about them
    • The reasons for and details of any provision of their personal location information to a third party under the Location Information Act or other laws
  4. If a user withdraws consent, the Company destroys without delay the personal location information collected and the records confirming the collection, use, and provision of location information (except where retention is required by law).

  5. Rights can be exercised through features in the app or by contacting customer support (privacy@pinly.live).

Article 8 (Retention of Records Confirming the Collection, Use, and Provision of Location Information)

In accordance with Article 16(2) of the Location Information Act, the Company automatically records and preserves records confirming the collection, use, and provision of location information in its location information system and retains them for at least 6 months. These records include the date and time of collection, use, and provision of location information and the recipients (such as family group members). The Company does not provide personal location information to outside third parties or for advertising purposes; "provision" here means that location information is shared with the members of the family (group) to which the user belongs.

Article 9 (Rights of Persons with a Duty of Protection for Children Aged 8 or Under and Others)

  1. When a person with a duty of protection for any of the following persons (the "children aged 8 or under and others") consents to the collection, use, or provision of personal location information to protect the life or body of that person, the consent is deemed to be the consent of the person concerned:

    • Children aged 8 or under
    • Persons under adult guardianship
    • Persons with disabilities who meet certain requirements under the Act on Welfare of Persons with Disabilities
  2. The Company does not collect users' age information to provide the Service and does not verify whether a user is one of the children aged 8 or under and others. If a person with a duty of protection wishes to use the Service for such a person, they may give the consent described in paragraph 1 by installing the Service directly on that person's device and agreeing to these Terms and to the collection, use, and provision of location information.

  3. A person with a duty of protection who has given consent under paragraph 2 may exercise the user's rights under these Terms on behalf of the children aged 8 or under and others (withdrawing consent, temporarily suspending the collection, use, and provision of location information, requesting access or correction, etc.).

Article 10 (Location Information Manager)

The Company designates a Location Information Manager to manage location information securely and to handle user complaints smoothly.

Article 11 (Damages)

  1. A user who has suffered damage from the Company's violation of the Location Information Act may claim damages from the Company. In this case, the Company cannot be released from liability unless it proves that it acted without intent or negligence.
  2. If a user violates their obligations under these Terms and causes damage to the Company or a third party, the Company may claim damages from that user.

Article 12 (Disclaimer)

  1. The Company is not liable for damage arising from any of the following:

    • Natural disasters or equivalent force majeure
    • The user's intentional misconduct or negligence (denying device permissions, disabling location services, incorrect settings, etc.)
    • Inaccuracy or delay of location information caused by external conditions such as mobile networks or GPS
    • Failure to properly manage the account or device for reasons attributable to the user
  2. Location information may differ from the actual location depending on the device environment and network conditions, and the Service is intended to provide supplementary information. The Company does not guarantee the absolute accuracy of location information.

Article 13 (Dispute Mediation)

  1. If the Company and a user cannot reach or hold consultations regarding a dispute related to location information, either party may apply for a ruling to the Korea Communications Commission under the Act on the Establishment and Operation of the Korea Communications Commission.

  2. The Company or a user may apply for mediation of a dispute related to location information to the Personal Information Dispute Mediation Committee under the Personal Information Protection Act.

Article 14 (Company Contact and Business Information)

Inquiries, consultations, and complaints regarding location-based services can be submitted to the following:

  • Company name: WAFFLE
  • Address: 702-156, 1068 Jungang-ro, Ilsandong-gu, Goyang-si, Gyeonggi-do, 10447, Republic of Korea
  • Location-based service business registration no.: 1220 (registration as a location-based service business for small businesses and others under Article 9-2 of the Location Information Act)
  • Location Information Manager: Chongwook Lim
  • Customer support (contact): privacy@pinly.live

Business information

  • Company name: WAFFLE
  • Representative: Chongwook Lim
  • Business registration no.: 493-65-00536
  • Mail-order sales registration no.: 2026-고양일산동-1610
  • Location-based service business registration no.: 1220
  • Address: 702-156, 1068 Jungang-ro, Ilsandong-gu, Goyang-si, Gyeonggi-do, 10447, Republic of Korea
  • Effective date: 2026-07-01