Privacy Policy
Aspado (the “Company”) provides the Kan goal-management app. This policy explains how the Company processes and protects personal information in accordance with Article 30 of Korea’s Personal Information Protection Act (“PIPA”).
1. Purposes and legal bases for processing
| Purpose | Legal basis |
|---|---|
| Create accounts, sign users in, verify identity, and secure accounts | PIPA Article 15(1)4 (entry into and performance of a contract) |
| Store, synchronize, and restore goals and tasks | PIPA Article 15(1)4 |
| Verify subscriptions and provide paid features | PIPA Article 15(1)4 |
| Retain payment and supply transaction records as required by law and respond to user access requests | Article 6 of Korea’s Act on the Consumer Protection in Electronic Commerce and Article 6 of its Enforcement Decree |
| Respond to support and account-deletion requests | PIPA Article 15(1)4 |
| Diagnose failures, protect the service, and prevent abuse | PIPA Article 15(1)6 (legitimate interests of the Company) |
| Provide and measure personalized advertising | PIPA Article 15(1)1 (the data subject’s consent) |
We do not use personal information for a purpose other than those stated above. If a purpose changes, we will obtain any required consent or take other measures required by law.
2. Personal information we process
| Category | Information | Collection method |
|---|---|---|
| Account and authentication | Sign-in provider identifier, email address, display name, profile image, sign-in provider | Received when you sign in with Google or Apple |
| User content | Core goals, sub-goals, action items, tasks, completion records, status, colors, target dates, and creation/modification times | Entered in the app and transmitted when you enable synchronization |
| Subscription and entitlement | App, store and product identifiers; subscription status; order, transaction and original-transaction identifiers; transaction type and status; purchase, expiry and revocation times | Collected during App Store or Google Play purchase verification |
| Device and service | Operating system, app version, language, app-instance identifier, IP address, user agent, security and error records | Generated or collected automatically while using the app and server |
| Advertising and consent | Advertising identifier, approximate location, ad impressions and interactions, and advertising consent choice | Collected during consent and ad requests for free users |
| Support | Contact email, inquiry, deletion request, identity-verification and processing record | Collected through email or an in-app request |
Goals, tasks, and preferences used without signing in are generally stored on your device. When you sign in and enable synchronization, account-linked content is sent to the cloud. We do not collect Korean resident registration numbers, passport or driver’s-license numbers, health data, biometric data, or other sensitive information to provide Kan.
3. Processing and retention periods
| Information | Retention period |
|---|---|
| Account and authentication information; synchronized user content | Until account deletion |
| Active subscription entitlement | Until account deletion or the entitlement ends, whichever occurs first |
| Minimum records of contracts, withdrawals, payments, and supply of goods or services | 5 years from the transaction date. For legacy records without a purchase time, 5 years from creation of the transaction record |
| App error records stored on the device | Up to 7 days from creation |
| Support inquiries and identity-verification materials | 1 year after the inquiry is resolved |
| Deletion request number, status and time, and an irreversibly transformed account identifier | Until the Kan service ends, solely to prevent recreation of a deleted account and misuse of prior credentials |
Under Article 6 of Korea’s Act on the Consumer Protection in Electronic Commerce and Article 6 of its Enforcement Decree, we retain records of contracts, withdrawals, payments, and supply of goods or services for five years. After account deletion, we separately retain only the app, store and product identifiers; order, transaction and original-transaction identifiers; transaction type and status; purchase, expiry and revocation times; and the retention deadline. Customer IDs, Firebase user identifiers, email addresses, purchase tokens, and raw receipts are not included in this statutory record. When a former user asks us to locate a transaction, we transform the submitted email into a non-reversible lookup value and return only exact matches.
4. Destruction procedures and methods
When information is no longer needed, we identify it, obtain approval from the privacy function, and destroy it without undue delay. Electronic files and database records are permanently deleted so they cannot be restored or reproduced. We do not retain Kan users’ personal information on paper.
Account deletion removes the sign-in account, synchronized goals and tasks, direct identifiers on our servers, and content written by that user. If other users participated in a post, we may retain a de-identified shell after removing the author and text to protect those users’ contributions. Completing deletion in the app also removes account-specific data on that device. Uninstalling the app alone does not delete the cloud account or cancel a store subscription.
Statutory transaction records are stored separately from ordinary customer information and are automatically destroyed when each five-year retention period expires.
After we request deletion, Firebase Authentication information may take up to 180 days to be removed from live and backup systems. Deleted information in disaster-recovery backups is not used in the ordinary service and is destroyed when the backup expires.
5. Disclosure to third parties
We do not disclose personal information for a third party’s independent purposes. If disclosure is based on separate consent or specifically permitted by law, we will provide the recipient, purpose, fields, and retention period in advance.
6. Processing contractors
| Contractor | Processing activity |
|---|---|
| Google LLC | Authentication through Firebase Authentication, content synchronization through Cloud Firestore, app-integrity protection through Firebase App Check, Google Sign-In, AdMob advertising, and UMP consent management |
| Apple Inc. | Sign in with Apple and App Store payment, subscription, and entitlement verification |
We use contracts and service terms to address purpose limitation, safeguards, subprocessors, and oversight. Changes to contractors or activities will be published in this policy. Synchronized Kan content in the production Cloud Firestore database is stored in the Seoul, South Korea region (asia-northeast3).
7. International transfers
| Recipient | Country | Information | Timing and method | Purpose | Retention |
|---|---|---|---|---|---|
| Google LLC (contact) | United States | Sign-in identifier, email, display name, profile image, IP address, user agent | Encrypted transmission when using Google sign-in and authentication | Authentication, security, abuse prevention | Deletion requested at account deletion; removal from live and backup systems within up to 180 days. Authentication IP logs may remain for a few weeks |
| Google LLC | United States and countries where Google operates services | App-integrity information, advertising identifier, approximate location, app/device data, ad impressions, interactions, and consent information | Encrypted transmission during app validation and ad requests | Integrity validation, ads, measurement, frequency capping, fraud prevention, consent management | App Check tokens: up to 7 days; replay-protection tokens: up to 30 days. Advertising logs remove part of IP addresses after 9 months and identifying information after 18 months; AdMob reports are retained for 90 or 2,555 days depending on report type |
| Apple Inc. (contact) | United States and countries where Apple operates services | Apple sign-in identifier, email or relay email, authentication token/code, purchase and subscription identifiers | Encrypted transmission during Apple sign-in or purchase verification | Sign-in, disconnection, payment, subscription and entitlement verification | For the duration of the Apple account or app relationship and any period required by law |
The legal basis is PIPA Article 28-8(1)3 when a transfer is necessary to perform sign-in or subscription services, and Article 28-8(1)1 (consent) for personalized advertising. You may use local features without Google or Apple sign-in. To stop account-related transfers, delete the account through Settings > Account > Delete Account. You may refuse or revisit advertising choices at Settings > Ad Privacy Settings; refusal does not disable non-advertising features.
8. Automatic collection and behavioral information
Kan does not directly install browser cookies. Authentication, security, and advertising SDKs may automatically process an app-instance identifier, IP address, user agent, advertising identifier, approximate location, and ad impression/click information for sign-in security, app-integrity validation, advertising, measurement, frequency capping, and fraud prevention.
You can revisit choices at Settings > Ad Privacy Settings. You can also change tracking or advertising-identifier settings in Settings > Privacy & Security > Tracking on iOS or Settings > Privacy > Ads on Android. In regions where consent is required, no ad request is made until the consent state permits it.
9. Rights of data subjects and representatives
You may request access, correction, deletion, suspension of processing, or withdrawal of consent. In Kan, go to Settings > Account > Delete Account and verify your identity. If you cannot use the app, follow the Kan account deletion instructions or email [email protected]. Email deletion requests are completed within 30 days after account ownership is verified, and we reply with the result.
You or an authorized representative may exercise rights by email. We may request the minimum material needed to confirm identity or authority. Never email a password or one-time verification code. If applicable law restricts access or suspension, we will explain the reason. Account deletion and App Store or Google Play subscription cancellation are separate; cancel a paid subscription in the applicable store.
10. Personal information of children under 14
Kan does not offer account services to children under 14 and does not operate a parental-consent process for collecting their information. If we learn that such information was processed without valid parental consent, we will verify the request and delete the information without undue delay.
11. Security measures
We apply administrative safeguards such as least-privilege access and periodic reviews; technical safeguards such as encryption in transit and at rest, token validation, app-integrity checks, and protected access records; and physical access restrictions for systems and storage locations.
12. Privacy officer and responsible function
- Privacy officer title: Privacy Officer
- Responsible function: Aspado Privacy
- Email: [email protected]
13. Remedies for infringement
Users in Korea may seek advice or relief from the Personal Information Infringement Report Center (118, privacy.kisa.or.kr), Personal Information Dispute Mediation Committee (1833-6972, kopico.go.kr), Supreme Prosecutors’ Office (1301, spo.go.kr), or Korean National Police Agency (182, ecrm.police.go.kr).
14. Changes to this policy
This policy applies from August 18, 2026. Material changes will be announced in the app or on the website before they take effect. Previous versions remain available in the policy version history.
Published: August 18, 2026
Effective: August 18, 2026