Effective Date: Last updated + 30days Last Updated: 2026-01-29 This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You. We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy. Interpretation and Definitions Interpretation The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural. Definitions For the purposes of this Privacy Policy: Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority. Apple refers to Apple Inc. Application means the software program provided by the Company downloaded by You on any electronic device, named Detox Lock Business, for the purpose of the CCPA (California Consumer Privacy Act), refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California. Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Addiction Labs Co, 52, Ewhayeodae-gil, Seodaemun-gu, Seoul, Republic of Korea For the purpose of the GDPR, the Company is the Data Controller. Consumer, for the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose. Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data. Device means any device that can access the Service such as a computer, a cellphone or a digital tablet. Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites. Google refers to Google LLC. Personal Data is any information that relates to an identified or identifiable individual.For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You. For the purposes for GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity. Registered User refers to the individual who has (an) active account(s) registered on the Company’s server. Registered User is subject to all clauses regarding the User in this Agreement. Sale, for the purpose of the CCPA (California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's Personal information to another business or a third party for monetary or other valuable consideration. Service refers to the Application. Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors. Third-party Social Media Service refers to any website or any social network website. Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit). You (also referred to as "the User" in this Agreement) means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable. Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service. Collecting and Using Your Personal Data Types of Data Collected Account Data Account Data is ONLY collected from Registered Users. In Our registration process, We collect the following information from You. Full Name: This does not necessarily mean Your actual full name, as You can edit the information when Signing up with Apple. Email Address: We can collect your real email address ONLY if You explicitly agree to share it. Otherwise, We collect a random email address created by Sign in with Apple. As of the latest update date of this Privacy Policy, Account Data does NOT include Your payment information and Usage Data. By registering to Our Service, You are subject to privacy policy of Sign in with Apple feature or Sign in with Google, depending on the method you select. For more information on the privacy practices policies of Sign in with Apple, please visit their Privacy Policy: https://www.apple.com/legal/privacy/data/en/sign-in-with-apple/ For more information on the privacy practices policies of Sign in with Google, please visit their Privacy Policy: https://support.google.com/accounts/answer/10130420 Personal Data While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to: - Full Name from Account Data - Email address - Address, State, Province, ZIP/Postal code, City - Usage Data - Advertising Identity(ADID) - Google Advertising ID(GAID) on Android devices - Identifier for Advertisers(IDFA) on iOS devices Usage Data Usage Data is collected automatically when using the Service. Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data. When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data. We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device. Information Collected while Using the Application While using Our Application, in order to provide features of Our Application, We may collect, with your prior permission: - Information regarding your location - Pictures and other information from your Device's camera and photo library - Payment card information (Card brand name, last 4 digits, Expiration date) We use this information to provide features of Our Service, to improve and customize Our Service. The information may be uploaded to the Company's servers and/or a Service Provider's server or it be simply stored on Your device. You can enable or disable access to this information at any time, through Your Device settings. Use of Your Personal Data The Company may use Personal Data for the following purposes: - To provide and maintain our Service, including to monitor the usage of our Service. - For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service. - To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation. - To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information. - To manage Your requests: To attend and manage Your requests to Us. We may share your personal information in the following situations: - With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to show advertisements to You to help support and maintain Our Service, to advertise on third party websites to You after You visited our Service, for payment processing, to contact You. - For Business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company. - With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us. - With Business partners: We may share Your information with Our business partners to offer You certain products, services or promotions. - With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile. Retention of Your Personal Data The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods. Transfer of Your Personal Data Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction. Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer. The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information. Disclosure of Your Personal Data Business Transactions If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy. Law enforcement Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency). Other legal requirements The Company may disclose Your Personal Data in the good faith belief that such action is necessary to: - Comply with a legal obligation - Protect and defend the rights or property of the Company - Prevent or investigate possible wrongdoing in connection with the Service - Protect the personal safety of Users of the Service or the public - Protect against legal liability Security of Your Personal Data The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security. Personal information protection officer Name: Wonsuk Oh Department: Product Operations Position: Manager Contact: momentaehub@gmail.com ※ It leads to the personal information protection department. Detailed Information on the Processing of Your Personal Data Service Providers have access to Your Personal Data only to perform their tasks on Our behalf and are obligated not to disclose or use it for any other purpose. Analytics We may use third-party Service providers to monitor and analyze the use of our Service. - Google Analytics: You may opt-out of certain Google Analytics features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. - Firebase: You may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy. For more information on what type of information Firebase collects, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy. We also encourage you to review the Google's policy for safeguarding your data: https://support.google.com/analytics/answer/6004245. Firebase is an analytics service provided by Google Inc. - Airbridge: For more information on the privacy practices of Airbridge, please visit their Privacy & Terms web page: https://www.airbridge.io/privacy-policy - Braze: For more information on the privacy practices of Braze, please visit their Privacy & Terms web page: https://www.braze.com/company/legal/privacy Advertising We may use Service providers to show advertisements to You to help support and maintain Our Service. - AdMob by Google: You can opt-out from the AdMob by Google service by following the instructions described by Google: https://support.google.com/ads/answer/2662922?hl=en. For more information on how Google uses the collected information, please visit the "How Google uses data when you use our partners' sites or app" page: https://policies.google.com/technologies/partner-sites or visit the Privacy Policy of Google: https://policies.google.com/privacy. AdMob by Google is provided by Google Inc. - InMobi: You can opt-out from InMobi service by following the instructions as described on the InMobi Opt-out page: http://www.inmobi.com/page/opt-out/. For more information on the privacy practices and policies of InMobi, please visit the InMobi Privacy Policy: http://www.inmobi.com/privacy-policy/ - AppLovin: If you'd like to opt-out from AppLovin service, please visit the AppLovin Opt-out page: https://www.applovin.com/optout. If you'd like to learn more about AppLovin, please visit the Privacy Policy page of AppLovin: https://www.applovin.com/privacy - Facebook Audience Network: Their Privacy Policy can be viewed at https://developers.facebook.com/docs/audience-network/policy/ - Amazon Publisher Service: Their Privacy Policy can be viewed at https://www.amazon.com/gp/help/customer/display.html/ref=hp_left_sib?ie=UTF8&nodeId=468496 - Mintegral, Smaato, IronSource, OpenX, Conversant, Xandr, Rubicon Project, MobFox, Liftoff, TripleLift, YieldMo: Consult each service's respective privacy policy link. Payments We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors). We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council. - Apple Store In-App Payments: https://www.apple.com/legal/privacy/en-ww/ - Google Play In-App Payments: https://www.google.com/policies/privacy/ - Stripe Payment: https://stripe.com/privacy Behavioral Remarketing The Company uses remarketing services to advertise on third party websites to You after You visited our Service. - Google Ads (AdWords): http://www.google.com/settings/ads - Facebook: https://www.facebook.com/help/164968693837950 - Apple Search Ads: https://searchads.apple.com/privacy/ Usage, Performance and Miscellaneous - Zendesk: https://www.zendesk.com/company/privacy-and-data-protection/ GDPR Privacy Legal Basis for Processing Personal Data under GDPR We may process Personal Data under the following conditions: - Consent, Performance of a contract, Legal obligations, Vital interests, Public interests, Legitimate interests. Your Rights under the GDPR - Request access, Request correction, Object to processing, Request erasure, Request transfer, Withdraw Your consent. CCPA Privacy - The right to notice, The right to access, The right to request, The right to say no to the sale of Personal Data, The right to know about Your Personal Data, The right to delete Personal Data, The right not to be discriminated against. Do Not Sell My Personal Information We do not sell personal information. However, the Service Providers we partner with (for example, our advertising partners) may use technology on the Service that "sells" personal information as defined by the CCPA law. Contact Us If you have any questions about this Privacy Policy, You can contact us: - By email: lockmomentapp@gmail.com - By visiting this page on our website: https://lockmoment.momentae.app/