Maplog Privacy Policy

Version 1 · Effective date: [EFFECTIVE DATE]

This version: https://maplog.day/privacy/v1 · Current version: https://maplog.day/privacy

Introduction

ideaccept Inc. ("we", "us" or "our") provides Maplog, a camera app that turns a day spent with friends into a map video just by taking photos, and its website (https://maplog.day) (together, the "Service").

This Privacy Policy (this "Policy") explains, for people who use the Service ("you"), what information we collect about you, why and how we collect and use it, who we show it to, and how long we keep it, as well as the choices you have and the requests you can make. Because Maplog is built around location, we explain how we handle location information in particular detail.

1. Structure: This Policy consists of a main part that applies in every country and region (Sections 1–20 and 22) and additional terms for specific regions (Section 21: Japan, the Republic of Korea, the EEA/UK/Switzerland and the United States). If the additional terms for the region where you live say something different from the main part, the additional terms prevail for people living in that region.
2. How this Policy relates to our other documents: The conditions for using the Service are set out in our Terms of Service (https://maplog.day/terms), and the conditions for collecting, using and providing location information are set out in Chapter 10 (Location Information) of the Terms of Service. Unless defined otherwise, words used in this Policy have the same meaning as in the Terms of Service. If anything in this Policy conflicts with the Terms of Service (including Chapter 10), the Terms of Service prevail, and we will correct this Policy.
3. How we obtain consent: Regardless of where you live or the language of the app, we ask everyone for consent item by item with checkboxes on the sign-in screen in the app (or, if you were already using Maplog, on a one-time confirmation screen shown the next time you open the app). The four [Required] items are agreeing to the Terms of Service, consenting to the collection and use of personal information (this Policy), consenting to the collection and use of your location (Chapter 10 of the Terms of Service), and consenting to the provision of your location to third parties (such as friends); the [Optional] item is consent to usage analytics and its transfer abroad (Article 3(1) of the Terms of Service). If you're in the EEA, the UK or Switzerland, we don't treat the [Required] checkboxes as consent under the GDPR; the legal bases for processing are as set out in Section 21.3. Optional features (such as sending photos to AI) are subject to separate consent in the app, feature by feature (Section 4.2).
4. Authoritative version: The Japanese version of this Policy is the authoritative version. However, for people living in the Republic of Korea, the Korean version is authoritative. This English version is a translation.

Key points (summary)

This summary is here to make this Policy easier to understand. It is not binding on its own, and the main text prevails.

• We never show your current location (coordinates) to anyone — not even your friends. Our server keeps only your latest location, and deletes it if it hasn't been updated for 24 hours. While Ghost mode is on, your location isn't sent.
• What friends can see is where you took photos (the spot's point on the map). For 36 hours after you first take a photo at that place, friends can see them along with the photo, caption and place name. We don't show them to friends while Ghost mode is on (or show photos taken during Ghost mode, even after you turn it off). By default, we also don't show friends photos taken near your home (within about 400 m) (if you turn off "Hide my home on friends' map" in settings, they're visible to friends just like any other place).
• "Together" detection happens only inside our server. We never return anyone's coordinates to anyone. It's an estimate, so it can be wrong. Both the person who took the photo and the person detected can remove the "together" mark later.
• People nearby is on by default if you're 18 or over (19 or over in the Republic of Korea), wherever you are (you can turn off "Show me to people nearby" in Settings at any time; minors (under 18 in Japan and most other places, under 19 in the Republic of Korea) can't use it). It doesn't show coordinates, distance or direction, but the fact that you are nearby is itself revealed to the other person.
• Maplog is for people aged 13 and over (14 and over in the Republic of Korea; 16 and over in the EEA, the UK and Switzerland). When you start, we ask for your date of birth (Section 19).
• The route you walked stays only on your device, and is deleted after 7 days. It isn't sent to our server.
• We don't sell your personal information, and we don't track you for advertising. We don't send your location, place names, photos or captions to our usage analytics (PostHog and Google's Firebase Analytics). Wherever you are, we send usage data only if you consent.
• You're in control. At any time, you can change Ghost mode, per-friend "together" detection, People nearby, whether to hide your home on friends' map, "Always" location access, whether to share usage data, and whether to send photos to AI. You can also delete your account in the app.
• We can't delete things after they've been shared. Anything a friend has saved, or a video you posted on an external social network, is handled by that person or that social network.
• Location and "together" detection can be inaccurate or wrong. Maplog is not a service for monitoring people, emergency calls, navigation or tracking people. Our liability is set out in the Terms of Service (we don't limit any liability that can't be limited under the laws of the country or region where you live).
• If a data breach or similar incident happens, we'll report it to the authorities and notify you as required by law. No system can be called completely secure, but we'll keep taking the measures described in Section 16.

1. Who we are and how to contact us

• Person responsible for handling personal information (Personal Information Protection Manager): Kaito Asano, Representative Director
• Chief Privacy Officer (개인정보 보호책임자) and Location Information Manager (위치정보관리책임자) for the Republic of Korea: Kaito Asano, Representative Director (contact: contact@ideaccept.com) (Section 21.2)
• EU representative and UK representative: [TO CONFIRM: appoint by the effective date of this Policy, and state their names, addresses and email addresses. Check with EU counsel whether Article 3(2)(b) GDPR applies to users while traveling; if we conclude that it doesn't, record the reasons] (Section 21.3)

2. What this Policy covers

2.1 What's covered

• The Maplog iOS app (whether you sign in or use it as a guest without signing in)
• The App Clip (a small version of Maplog that opens from a friend's QR code or link)
• Displays on the Lock Screen and Dynamic Island (Live Activities)
• The website https://maplog.day (including the page for adding friends and the pages for our terms and policies)
• How we handle inquiries, reports and requests

If we support other devices (such as Android), we'll update this Policy accordingly.

2.2 What's not covered

• Apple and Google accounts, iOS features, external social networks (such as TikTok and Instagram), and services that the Service links to. How information is handled there is governed by each provider's own privacy policy and terms. We can't control how those providers handle it.
• How videos and images you make with Maplog are handled after you share them outside Maplog (Section 6.4).

2.3 Information about people who don't use Maplog

Photos and videos may show other people or pick up their voices. We treat these as part of the post of the person who took them. People who don't use Maplog can also ask us, through the contact points in Section 22, to delete posts that show them or to take other action.

3. Information we collect

3.1 List of information we collect

The original photos and videos you take are stored on your device (inside the app). Saving them to your camera roll is a setting you can choose (off by default). What we send to our server are downsized photos (2048 px and 512 px on the long side) and videos (including audio). Location and other information attached to photos and videos (metadata) is removed before upload.

3.2 Information we receive through other users' actions

We may receive the following information through the actions of users other than you:

• Records that you were detected as, or added as, someone who was "together" with another user when they took a photo
• Your image or voice in other users' photos and videos
• Friend requests sent to you, and comments and reviews on your posts
• Reports about you or your posts

3.3 Information we don't collect

• Your device's contacts (address book)
• The route you walked (including places you stopped at and the times you arrived and left; it stays only on your device and isn't sent to our server)
• Motion records (Motion & Fitness). These are used only on your device, and aren't sent to our server or to analytics (Section 12)
• Your home address as text (we store only a point)
• Location and other metadata attached to photos and videos (removed before upload)
• The advertising identifier (IDFA) (we use the IDFV and the Firebase app instance ID for analytics, as described in Section 13)
• Data used to recognize faces in photos (face templates)
• Payment information such as credit card details (the Service currently has no payments)

We never ask you for sensitive information such as your religion, health or medical history. However, such things may become apparent from the photos, videos and captions you post, or from the type of places where you take photos. See also Section 21.2 (12).

4. How we use information

4.1 Purposes and the information used

We use information only for the following purposes.

We don't currently send promotional notifications (such as announcements of campaigns). If we start, we'll ask for your separate consent first.

4.2 What we do only with your consent

We do the following only after you give consent in the app, separately from your agreement to the Terms of Service, or after you choose it in settings. You can change or withdraw your consent at any time. We've made withdrawing about as easy as giving consent. "Share usage data" is also sent only if you consent, wherever you are (Section 13).

In addition, when you make a report, the report screen tells you that our staff will review the reported content, and by sending the report you consent to this. For consent from the parent or other legal guardian of minors, see the Terms of Service and Section 19.

Consent records: We record every time you give consent, decline to give consent or withdraw consent, without overwriting earlier records (Article 3(6) of the Terms of Service). We record who (the account identifier), what it concerns (the type and purpose of the consent), what was done (consented, declined or withdrew), which version (the document and its version), when (the date and time), on which screen and in which language, as well as the app version and the type of device. We also record when you turn on the location row on the permissions screen (consent to the collection and use of location information). For providing your location to third parties, our servers check these records and don't provide the location of people who haven't consented or have withdrawn consent. For usage analytics and sending photos to AI, consent is managed by the settings on your device, and data is sent only for people who have consented. Retention periods are described in Section 14.

4.3 What we don't do

• We don't sell your personal information. We also don't "sell" or "share" it as those terms are used in US state laws. We don't let our analytics providers (PostHog and Google) use it for their own purposes either (Section 13).
• We don't track you for advertising. We don't use the advertising identifier (IDFA), and we don't ask for App Tracking Transparency permission. We don't follow your activity across other companies' apps or websites.
• We don't use location information to make decisions about advertising, creditworthiness, insurance, hiring or similar matters.
• We don't profile you. We don't infer your interests or build a picture of who you are from your activity, the places you go or what you photograph, and we don't use any such inferences. We don't infer your health, religious beliefs, sex life or similar matters from the categories of places where you take photos (such as hospitals or places of worship).
• We don't make decisions that have legal effects, or similarly significant effects, based solely on automated processing. Actions such as suspending an account are reviewed by our staff.
• We don't create data used to recognize faces in photos (face templates).
• We don't look at the content of posts and comments that are shown only to a limited audience, such as friends or the people you were with, except: when reviewing reported content with the consent of the person who reported it, when running automated filters with the consent of the person posting (Article 24(5) of the Terms of Service), when required by law, when urgently needed to protect someone's life or physical safety, and when minimally necessary to deal with outages, unauthorized access or spam.

5. How we handle location information

This section explains the key points about location information. The detailed conditions are set out in Chapter 10 (Location Information) of the Terms of Service (https://maplog.day/terms).

5.1 How we collect it

• We receive the results measured by your device's location services (GPS, Wi-Fi and cell towers). We don't work out your position ourselves.
• While the app is open ("While Using"): We receive your location with high accuracy, each time you move about 10 m or every 15 seconds.
• If you allow "Always": While the app is closed (even if you've quit it), iOS wakes the app with its "significant location change" and "visit" notifications. While you're moving, we receive your location precisely using GPS (about every 15 m), and we stop receiving it when you stop. For places you stopped at, we also record the times you arrived and left. Only the latest record of your current location is sent to our server; everything else goes only into the route stored on your device.
• Other times: When you open the People nearby screen, and when you tap "Set my current location as home".
• To get together detection and place names right, we ask you to turn on iOS "Precise Location".

5.2 Where we keep it and for how long

5.3 Together detection

1. When you take a photo, our server compares your latest location held on our server (used only if the point where you took the photo is within about 150 m of it) with your friends' current locations (the latest one each, sent within the last 10 minutes, or within the last 60 minutes for friends who allow "Always").
2. Friends who were within about 50 m (allowing for positioning error) are estimated to be people who were "together" with you, and their IDs are recorded in the post.
3. We notify the people who were with you (for example, "Yui took a photo at Café Clover").
4. This detection happens only inside our server. We never return anyone's coordinates or distance — not to you, not to them, and not to anyone else. All we return is the IDs of the people who were with you.
5. The following are left out of detection: people in Ghost mode; cases where you or the other person has turned off per-friend "together" detection; people whose location is out of date; and people who aren't your friends.
6. Because it's an estimate, people may be missed or wrongly included. Both the person who took the photo and the person detected can later remove that person from "together". We record removals and never undo them automatically.

5.4 Who can see what

While "Show me to people nearby" is on (on by default if you're 18 or over, or 19 or over in the Republic of Korea; Section 4.2), even though coordinates, distance and direction aren't shown, the fact that you are nearby (within about 50 m) is itself revealed, including to people you don't know. Combined with your profile photo and name, someone might be able to guess where you are. We recommend turning it off in places where there aren't many people around, and near your home, school or workplace.

5.5 Ghost mode and how to stop sharing

When you turn on Ghost mode:

• Your current location isn't sent to our server (not even while the app is open; our server also doesn't record any location while Ghost mode is on). When you turn it on, the current location stored on our server is deleted.
• You're left out of together detection (whether you take the photo or a friend does).
• You no longer appear in friends' Log and Map, in People nearby, or in Friends nearby.
• The route you walked is still recorded on your device during Ghost mode (it isn't sent anywhere).
• Even during Ghost mode, the spot points and capture points of the photos and videos you take are stored on our server as your own records. Those posts aren't shown to friends, even after you turn Ghost mode off. To stop this recording as well, turn off Maplog's location permission in iOS Settings (features that need location information will then be unavailable).

You can stop or limit how your location is used in these ways:

• iOS Settings: turn location off, choose "While Using" only, or turn off "Precise Location" (however, while location can't be used, you can't take photos or use together detection, Friends nearby, People nearby or your route; you can still view your friends' posts, Logs and the map and use settings)
• Ghost mode (pauses sending your current location and showing you to other users; the location of posts you take is still recorded)
• Turning off per-friend "together" detection (you're left out of detection with that friend and out of Friends nearby; your posts stay visible to them as a friend)
• Turning off "Show me to people nearby"
• Removing yourself from "together" on a post, or deleting a post
• Removing or blocking friends
• Deleting your account

5.6 Home

• Your home location is stored rounded to a grid of about 100 m, and only you can read it. We don't store your address as text. Turning an address into a point is done by iOS on your device (Apple), and the address you enter is sent to Apple.
• The area within about 400 m of your home is left out of Community Places. By default, it's also left out of what friends see (photo pins on the Map and the Log). If you turn off "Hide my home on friends' map" in Settings > Home, spots you took near your home are visible to friends just like any other place, and friends may be able to tell roughly where your home is (your home location itself isn't visible to friends, even if you turn this off).
• In exported videos and images, the map around your home is hidden and the place name is shown as "Home". The hidden area is a circle with its center shifted, so that your home isn't at the center. In the "Map on top" layout, if you turn off "Hide my home" (on by default) in the export settings, the area around your own home is also shown on the map (in the "Photo on top" layout, it's always hidden). The area around the homes of people you were with is always hidden. Even where the area is hidden, the photos are shown with the name "Home", so viewers can tell that those photos were taken near your home.
• However, your home's location may still be guessed from things like photo backgrounds, the times you took photos and captions. We can't guarantee that your home will be completely hidden.

5.7 Limits of location information

• Location information has errors. Indoors, underground or among tall buildings, it may be off by tens of meters or more, be delayed, or not be available at all. As a result, together detection, place names, what's shown on the map and routes may differ from reality.
• Maplog is not a service for monitoring others, crime prevention, emergency calls, checking on someone's safety, navigation or tracking people. Please don't use it to check where someone is or whether they're safe. In an emergency, call 110 or 119 (112 or 119 in the Republic of Korea) or other emergency services.
• We can't technically stop friends from saving screenshots of posts they can see, or from showing them to others. Only add people you actually know and trust as friends.
• Our liability for location errors and detection mistakes is set out in the Terms of Service (Articles 34 and 57).

5.8 Requests from law enforcement and others

• We provide location information (including current location, photo locations and home location) to investigative authorities only in accordance with a warrant issued by a judge (in the Republic of Korea, including a court's permission). We don't provide location information in response to requests without a warrant (such as investigation inquiries under Japanese law).
• If police, fire or other rescue authorities ask for it on the grounds that someone's life or body is in imminent and serious danger, we respond in accordance with the law and Japan's "Guidelines on the Protection of Personal Information in Telecommunications Business".
• Information other than location information is provided only in the cases described in Section 7, such as where required by law.
• Requests from authorities outside Japan are assessed under the laws of that country or region and the laws of Japan.
• Because we keep only the latest record of your current location and delete it if it isn't updated for 24 hours, we can't provide past records of your current location.

6. What other users can see

6.1 Our approach and consent

Showing your information to friends, people you were with, people nearby and others may legally count as "providing your information to a third party". So we decide in advance who can see what, and we do this only after getting your consent as described below (Section 4.2).

• Everywhere: Together detection, showing friends the spots where you took photos, and showing Friends nearby are Maplog's core features, so you need to give this consent to use Maplog. You give it with the "[Required] Agree to provide my location to third parties" checkbox on the sign-in screen and elsewhere (or, if you were already using Maplog, on the one-time confirmation screen), and can withdraw it with "Provide my location to third parties" in Settings. In the EEA, the UK and Switzerland, we don't treat this checkbox as consent under the GDPR, and we do this to perform our contract with you (Section 21.3 (2)).
• If you don't consent or withdraw your consent: You can't use the Service (when you open the app, you will be asked to choose whether to consent again or delete your account; you can withdraw at any time in Settings). While you haven't consented (including after withdrawing), we exclude you from together detection, showing spots to friends, Friends nearby and People nearby, and don't send your current location to our servers. Spots you take while you haven't consented are not shown to friends even if you consent later (if you're in the Republic of Korea, see also Section 21.2).
• Show me to people nearby is on by default if you're 18 or over (19 or over in the Republic of Korea), wherever you are. The note for the checkbox above tells you that you may also be shown to people nearby, that it's on at first, and what others will see (profile photo, name and ID), and we obtain your consent with that checkbox. You can turn it off in Settings at any time. Your face and name appearing in exports made by friends you were with (Section 4.2) is also done within the scope of this checkbox.
• Your profile (ID, display name and profile photo) is shown to people who search for your user ID, the other person in a friend request, and people who open a friend link or QR code you sent on the basis of your agreement to the Terms of Service (Article 6(2) of the Terms of Service).
• Community Places show the name you chose or entered for a place that isn't on the map (if you chose the place in place search, whichever of its Japanese, Korean and English names matches the viewer's language). When you take a photo at a place with that name, the place's name, point and category appear on every user's map (we don't show who added it, when, or how many people did). Places are not added near your home (about 400 m), while you are in Ghost mode, or from spots taken while you were in Ghost mode. The name is sent to AI to decide the category. A photo taken with the rear camera is sent only if you've allowed it (Section 11). The screen where you choose the name tells you about these things.
• We will keep records of these disclosures (location use and disclosure records; no coordinates) for 1 year from the date recorded (if people in the Republic of Korea delete their account or withdraw consent, we destroy the records covered without delay; Section 21.2 (10)). For people in the Republic of Korea, we will notify you each time we make a disclosure (Section 21.2) [TO CONFIRM: implementation (there is no table for the Location Disclosure Records, no screen for viewing them, and no notice to Korean Users each time their location is provided (or in a summary); in Korea these are obligations under Articles 16(2) and 19(3) of the Location Information Act, so they must be implemented before release)].

6.2 What each audience sees and how to stop it

People you've blocked can't see your profile, your posts or you in People nearby, and together detection and friend requests between you are stopped. We don't tell the other person that you blocked them. You can unblock people at any time from "Blocked people" in your friends list (unblocking doesn't make you friends again). If you have both blocked each other, each block stays in place.

6.3 Friends outside Japan

Your posts, the places where you took photos and the fact that you were together are also shown on the devices of friends who are outside Japan (such as in the Republic of Korea). Because this may count as providing information to individuals in a foreign country, we tell you about it as part of the consent to the provision of your location to third parties (Section 4.2), and ask for your consent.

• Recipient countries: We can't know which countries your friends will be in at the time we ask for consent, so we can't name them. The main country we expect is the Republic of Korea.
• Those countries' systems: You can look up each country's personal information protection system in the "Survey of Personal Information Protection Systems in Foreign Countries" on the website of Japan's Personal Information Protection Commission (https://www.ppc.go.jp/personalinfo/legal/kaiseihogohou/#gaikoku).
• Measures taken by recipients: Because the recipients are individuals, we can't make them commit to measures to protect personal information.

6.4 After you share

• We can't technically stop friends or people you were with from saving, screenshotting or forwarding posts they can see.
• Sharing exported videos and images on external social networks is something you do yourself. Once shared, a video is governed by that social network's terms and privacy policy, and we can't delete it. Exports include maps and place names, and the photos, faces and names of friends you were with. Before sharing, check that the people in it are OK with it.
• If you want something a friend saved or shared to be deleted, please ask that friend first. We'll also help as far as we can if you ask us.
• Our liability for these matters is set out in the Terms of Service.

7. Providing information to third parties

Apart from the cases in Section 6 (what other users can see) and Section 8 (outsourcing, and provision to place search providers), we don't provide your personal information to third parties except in the following cases:

1. With your consent
2. When required by law (including court orders, warrants, inquiries made under the law, and requests or orders for disclosure of sender information under Japan's Information Distribution Platform Act; for location information, see Section 5.8)
3. When it's necessary to protect someone's life, body or property and it's difficult to get your consent
4. When it's especially necessary to improve public health or promote the healthy development of children and it's difficult to get your consent
5. When we need to cooperate with a national government agency, a local government or a similar body in carrying out duties prescribed by law, and asking for your consent could get in the way of those duties
6. When the business is taken over through a merger, company split, business transfer or similar (we'll require the successor to handle your information to the same standard as this Policy, and we'll notify you in advance in the app or on the website)

If we learn of a possible crime that threatens someone's life or safety, we may notify the relevant authorities in accordance with the law. Information about people living in the Republic of Korea is provided only where Korean law allows it (Section 21.2).

8. Outsourcing and external providers

To run the Service, we entrust the handling of information to, or use the systems of, the following providers.

• Map data comes from OpenStreetMap. Map tiles are delivered from our own server (tiles.maplog.day, which runs on Cloudflare's services). For areas outside Japan and the Republic of Korea, zoomed-out maps (below zoom level 6) and tiles that cross the edges of our map data coverage (each region of Japan, and the Republic of Korea), our server fetches the tiles from OpenFreeMap on your behalf; only the tile numbers are sent to OpenFreeMap, and your IP address isn't. Only the lettering on the map (fonts) is downloaded by your device directly from OpenFreeMap (tiles.openfreemap.org); your device's IP address reaches OpenFreeMap, but your location doesn't.
• Walking routes and routes along railway lines are calculated on your device, from the roads and railway lines in the map tiles. Coordinates aren't sent anywhere.
• Place name and address search, place search and map lettering work by sending information to each provider's systems and getting results back. We limit what we send to what's necessary.
• Provision to place search providers: Because Google LLC (place search; United States) and Kakao Corp. (Republic of Korea) may also handle the information they receive under their own policies, for the purposes of Japan's APPI we treat this not as outsourcing but as provision to a third party (Articles 27 and 28), and we provide it based on your Location Consent (Article 3(2) of the Terms of Service). We send only the coordinates, search terms, language and place IDs needed for the search, and never your ID or name. You can look up the personal information protection systems of the United States and the Republic of Korea in the "Survey of Personal Information Protection Systems in Foreign Countries" by Japan's Personal Information Protection Commission (https://www.ppc.go.jp/personalinfo/legal/kaiseihogohou/#gaikoku). The measures each company takes are described in its privacy policy (Google: https://policies.google.com/privacy ; Kakao: [TO CONFIRM: URL of Kakao's privacy policy]) [TO CONFIRM: whether, under the Kakao Local terms of use, Kakao uses the coordinates it receives for its own purposes]. For people in the Republic of Korea, see Section 21.2 (3).
• Analytics providers: We entrust PostHog and Google (Firebase Analytics) only with processing analytics for us, and we don't let them use the data for their own purposes (such as advertising or improving their own services) (we've turned off Google Analytics' data sharing settings and Google signals [TO CONFIRM: settings in the Firebase and Google Analytics consoles, and acceptance of Google's data processing terms]).
• If we use the feature for making exported videos on a server, we'll add that provider to this table before we start.
• When choosing providers, we check their security arrangements; by contract, we require them not to use information for any other purpose, to keep it confidential and to report breaches, among other things; and we check how they handle it. We require any provider we share your information with to protect it in the same or an equivalent way as required by this Policy and by Apple's App Review Guidelines.
• External social networks (such as TikTok and Instagram) are places you choose to share to yourself; they aren't our service providers.

9. International transfers and where information is stored

9.1 Where we store information

• We are a Japanese company. Our database is on servers in Japan (Tokyo).
• Photos and videos are stored on Cloudflare's servers in the Asia-Pacific region [TO CONFIRM: country of storage].
• Many of the providers in Section 8 are US companies, and some processing may take place in the United States or elsewhere.

9.2 Information under Japanese law

• With our providers located outside Japan, we have put in place, by contract, measures in line with the purpose of Japan's Act on the Protection of Personal Information (APPI) (a system that meets the prescribed standards). We also regularly check that those measures are being followed.
• On request, we'll tell you how that system has been set up, an outline of the measures, how often and how we check them, the names of the foreign countries, and any of those countries' systems that could affect the measures (contact us as described in Section 22).
• For displays to friends outside Japan, see Section 6.3. For provision to place search providers (Google and Kakao), see Section 8.
• As part of our understanding of the external environment, the countries we have identified are the United States, the Republic of Korea, Japan and [TO CONFIRM: country of OpenFreeMap's operator, and country of Cloudflare's storage location] (Section 16).

9.3 People in the Republic of Korea, the EEA and elsewhere

• For people living in the Republic of Korea, the details of overseas transfers are summarized in Section 21.2 (4).
• For people in the EEA, the UK and Switzerland, the grounds for transfers are summarized in Section 21.3.

10. External transmissions

When you use the Service, information is sent from your device to the destinations below. (This section also serves as the public notice under Article 27-12 of Japan's Telecommunications Business Act.) You can also open this section from "Privacy" in the app's settings.

What our server sends to external providers (such as for place search, AI and notification content) is described in Section 8. Before we add or change any destination that your device sends information to, we'll update this table.

11. Use of AI

• What it's for: When a new place is added to Community Places, we use AI only to decide its category (one of the map's 18 categories) and a more detailed type (for example, Korean restaurant), and to produce the detailed type in Japanese, Korean and English. Place names are not translated by AI. The Japanese, Korean and English names of a place come from the name suggestions in place search (Google's Places API in Section 8).
• What's sent: For this, our server sends the place name and language to Google's Gemma model running on Cloudflare Workers AI. If you've allowed it, a copy of a photo you took at that place with the rear camera, downsized to 512 px on the long side (with location and other information removed), is also sent. The photo is used only to decide the type (category) of the place. Photos taken with the front camera, and videos, are not sent. Coordinates, your ID and your name are never sent to AI.
• Storage and training: We don't store photos sent to AI. We store the decided category and detailed type (in Japanese, Korean and English) as information about the place in Community Places. How Cloudflare handles what is sent (including whether the photos and names sent are stored or used to train AI) is governed by Cloudflare's Workers AI terms of use (under those terms, the photos and names sent are stated not to be stored by Cloudflare or used to train AI) [TO CONFIRM: Cloudflare Workers AI terms of use].
• If people appear in the photo: Photos may show people. We instruct the AI not to look at the people in them, and we don't run any processing to recognize faces.
• When data is and isn't sent: Photos are sent to AI only if you've allowed it. Before a photo is sent for the first time (when you first choose a place that isn't on the map), we ask you once whether you allow it. On that screen, we tell you which photo is sent, the type of recipient (an external image recognition service (USA)), why, and that it isn't stored, and, under "Details" on that screen, we show everyone, wherever they are, the information on the transfer of personal information abroad (the items transferred, the country (the United States), when and how it is transferred, the name and contact details of the recipient (Cloudflare, Inc., privacyquestions@cloudflare.com), the purpose of use, the retention period, and how to refuse and what happens if you refuse; these are the items under Article 28-8(2) of the PIPA). Until you answer, and if you don't allow it, no photo is sent and the category is decided from the place name alone. You can withdraw your permission at any time in Settings > Map building > "Help build the map for everyone" (this doesn't affect photos sent before you withdraw). The app on your device checks whether you've allowed it, and if you haven't, your photos aren't sent from your device to our servers. If no place is added to Community Places (including near your home, while you're in Ghost mode, and for spots taken in Ghost mode), neither the name nor any photo is sent to AI (Section 6.1). When there is no photo (for example, when you only took front-camera photos or videos), the category is decided from the place name alone. If you're in the EEA, the UK or Switzerland, sending your photos to AI is based on your consent (Section 21.3 (2)).
• Fixing mistakes: AI can only choose categories from our own list of map categories. AI does not assign detailed types relating to adult entertainment, medical care or politics. AI results (including the detailed types in Japanese, Korean and English) may be wrong or inappropriate. You can ask for a correction, or report it, through Contact in the app (people who don't use Maplog can also report it through the contact point in Section 22). When we receive a report, we'll check it and correct it if needed. If we receive a report of an error that may harm someone's reputation, credit or privacy, we won't show that type until we've finished checking.
• We don't make decisions based solely on AI results that have legal effects or significant effects on you.
• Our liability for AI mistakes is set out in the Terms of Service.

12. Device permissions

Before asking for an OS permission, we explain in the app what it will be used for. However, for the Motion & Fitness permission, people who were already using Maplog before we added this permission (people who have set location access to "Always") get the explanation in the text of the iOS prompt, shown only once when they open the app. Separately from the OS permission, we ask for your Location Consent (Article 3(2) of the Terms of Service) for location information. Location and camera permissions are not required. Without them, you can still view your friends' posts, Logs and the map, use settings and contact us. Features that use your own location (taking photos, together detection, Friends nearby, People nearby and your route) are unavailable until you allow them, and we show this on screen. If you open the camera without permission, we guide you to the permissions screen.

We don't ask for permission to access your contacts, Bluetooth or tracking (App Tracking Transparency). Our analytics tools (PostHog and Firebase Analytics) are set up without the advertising identifier (IDFA), so we don't ask for tracking permission. The microphone is used only while you're recording a video. Even from the screens that ask for location or camera permission, you can still open Settings, contact us, read this Policy and delete your account.

13. Usage analytics and tracking

• Where it's sent: To improve the app, we send usage data to two providers: PostHog, Inc. (United States; receiving server: us.i.posthog.com) and Google LLC's Firebase Analytics (Google Analytics; United States). Both are our service providers.
• What's sent: (a) Event names and small values (started as a guest, signed in (method), took a photo or video, posted (whether stars or a caption were added), sent or accepted a friend request, commented, shared, made a video, deleted the account, and so on, including events recorded automatically, such as installing or opening the app). (b) Your Maplog user ID (we don't send your name or email address). (c) Device information (OS, model, app version, language). (d) The Firebase app instance ID (a number Firebase assigns to each app installation) and the IDFV (a number Apple assigns to each device for apps from the same developer; it can't be used for advertising). (e) Your IP address (sent as part of how internet communication works).
• What's not sent: Your location, place names, photos and videos and their URLs, the text of captions and comments, your name, your email address, who you were with, and the advertising identifier (IDFA).
• Location estimates: We've set PostHog up so that it doesn't estimate location from IP addresses. Google may estimate your approximate country or region from your IP address, but we've set it up not to collect location more precise than that (such as your city) [TO CONFIRM: turn off "granular location and device data collection" in Google Analytics].
• No use for providers' own purposes: We entrust PostHog and Google only with processing analytics for us, and we don't let them use the data for their own purposes (such as advertising or improving their own services). We don't use Google Analytics' data sharing settings, Google signals, ads personalization or links to Google Ads or similar products [TO CONFIRM: settings in the Firebase and Google Analytics consoles, and acceptance of Google's data processing terms].
• No tracking: We don't use the advertising identifier (IDFA), and we don't ask for App Tracking Transparency permission (neither we nor Google receive the IDFA). We don't include any advertising SDKs. We don't let other companies collect information about your activity across other apps and websites through Maplog.
• Do Not Track: Because we don't track you across apps or websites, we don't respond differently to Do Not Track signals.
• Consent and how to stop it: Wherever you are, usage data is sent only if you consent with the "[Optional] Agree to usage analytics and transfer abroad" checkbox on the sign-in screen or elsewhere (or, if you were already using Maplog, on the one-time confirmation screen) (off by default; until you consent, not even automatically recorded events, such as first launch, are sent). You can use every feature of the Service even if you don't consent. Turning off Settings > "Privacy" > "Share usage data" stops sending to both PostHog and Google at any time. On the checkbox screen, the recipients are shown by type as "external analytics services (USA)"; the company names, the items sent and other details are described in this section and in Sections 8, 10 and 21.2 (4).
• Link to your user ID: Usage data is linked to your Maplog user ID, but we use it only in aggregate to improve the app, and never for advertising or to make decisions about you.
• Each provider's privacy policy: PostHog: https://posthog.com/privacy ; Google: https://policies.google.com/privacy
• Before adding any analytics or crash reporting tool, we'll update this section and the tables in Sections 8 and 10.

14. How long we keep information, and deletion

• When a retention period ends, or when information is no longer needed, we delete it without undue delay in a way that can't be undone. We also run regular checks so that nothing is left behind. Photos, videos and other items you have deleted (within 30 days), expired exported videos and unused guest accounts are deleted from our database and our photo and video storage by a deletion job that runs once a day [TO CONFIRM: start of the deletion job (Edge Function purge) in production].
• Where the law requires us to keep information, or where we need it to handle disputes or requests made under the law, we may keep it for that period, separately from other information.
• For what happens when people in the Republic of Korea withdraw their location consent (including by deleting their account), see Section 21.2 (10).

15. What's deleted and what remains when you delete your account

15.1 How to delete your account

• You can delete your account at any time from Settings > "Delete account" in the app (because it can't be undone, we ask you to confirm twice). The same applies to guest accounts. If you sign in with Apple or Google after using a guest account, we delete the guest account once we have finished moving its items to the account you signed in to (Section 14). If the deletion fails, we try again the next time you open the app.
• A guest account created in the App Clip is carried over to the full app when you install it, and you can then delete it from settings. If you don't install the full app, ask us to delete it through the contact points in Section 22. Even without a request, it is deleted as an unused guest account 1 year after it was last used (Section 14).

15.2 What's deleted

• We immediately delete your account, profile, date of birth, location, what you took, posts, comments, reviews, friends, settings, home location and so on from our database and from our photo and video storage.
• We delete the link to your Apple or Google account (the identifiers in our database). You can remove the app's Sign in with Apple or Google connection that remains on Apple's or Google's side from your account settings with them.
• The files that account took and the photos and videos restored from our server are deleted from the device on which you delete your account. Items taken with other accounts on that device (and their spots) remain (they are not shown). The route you walked, the cache of found routes, places you picked yourself and that device's settings are deleted regardless of which account they belong to, and recording of your location while the app is closed stops (it does not resume until someone signs in again). Items on other devices are deleted, and location recording is stopped, the next time the app is opened on that device or as otherwise described in Section 15.3, item 10.

15.3 What remains

1. Things on friends' devices, and things friends saved or shared (including photos and videos that show you, and videos that include your name)
2. Things you saved to your camera roll
3. Things you shared on external social networks
4. Inquiries (unlinked from you, for the period in Section 14)
5. Places in Community Places that other people also added (unlinked from you)
6. Records needed to comply with the law and handle disputes: consent records (3 years), records of reports (3 years; reports you made are kept with your identifier removed), location use and disclosure records (1 year; for people in the Republic of Korea, destroyed without delay when they delete their account) [TO CONFIRM: implementation (there is no table for the Location Disclosure Records, no screen for viewing them, and no notice to Korean Users each time their location is provided (or in a summary); in Korea these are obligations under Articles 16(2) and 19(3) of the Location Information Act, so they must be implemented before release)]
7. Server access logs (for the period in Section 14)
8. Backups (deleted within 30 days at most)
9. Usage data (what was sent to PostHog and Google). When you delete your account, we ask PostHog and Google to delete your data. How long it takes for each provider to actually delete it depends on that provider's own rules (in the meantime, it is still deleted when the period in Section 14 ends). Aggregated figures remain
10. The original files you took, photos and videos restored from our server, the route you walked, and similar items on devices other than the one on which you delete your account (they are deleted the next time the app is opened on that device, and we then also sign out and stop recording your location while the app is closed; until then, and when there is no connection or in similar cases, they remain. If the sign-in on that device has already ended, we delete the route you walked (including what was recorded while the app was closed) and the cache of found routes, and stop location recording (places you picked yourself and that device's settings remain); the items you took remain on the device without being shown, and are deleted the next time someone signs in to a different account on that device. In either case, recording of your location while the app is closed is not resumed while no one is signed in. If that device had switched to a different account before the deletion, the deleted account's items remain on that device without being shown)

16. Security measures

We take the following measures to protect your information. However, no system that uses the internet can be called completely secure.

16.1 Organizational measures

• We have appointed a person responsible for handling personal information, and we have written rules for handling it.
• We limit which staff can handle personal information and what they can handle.
• We have set procedures for reporting and responding to breaches and similar incidents.
• When choosing service providers, we check their security arrangements, sign contracts with them, and check how they handle information.
• We regularly review how information is being handled.
• We review reports within 24 hours of receiving them (except where circumstances beyond our reasonable control prevent this).

16.2 Personnel measures

• We require our staff to keep information confidential, and train them on handling personal information.

16.3 Physical measures

• Data is stored in the data centers of cloud providers that control who can enter and leave, among other measures.
• The devices we use have screen locks and encryption to protect against theft and loss.

16.4 Technical measures

• Designed never to return current locations: Together detection, Friends nearby and People nearby are calculated only inside functions on our server, and never return anyone's coordinates, distance or direction. These functions don't accept arbitrary coordinates; they use only the user's own location stored on the server. Friends nearby and People nearby are listed by name, not by distance.
• Measures against fake locations: Locations can be written only through our own functions, and we don't accept values that are out of range, writes that come too soon after the previous one, or locations further from the previous location than is possible to move in the time. Right after someone makes a large move (for about 2 minutes, or about 30 seconds if they had not sent their location for a while), and when they have no previous location, such as right after their location is first placed or right after they turn off Ghost mode (for about 30 seconds), we don't return People nearby or Friends nearby to them, and we limit both how often these can be called and how many times the answer for each friend can change. However, because our server can't verify whether a location sent from a device is genuine, we can't completely prevent the use of fake locations to find out whether someone is in a particular area (Article 55 of the Terms of Service).
• Capture points and home locations: Capture points and their accuracy can't be read by anyone other than you (friends see only spot points). Home locations are stored rounded to a grid of about 100 m.
• Database access control: Row-level security (RLS) is applied to every table. No one can read other people's data, or information meant only for the user (such as home location).
• Photos and videos: Storage is private. Only after our server confirms that you're allowed to view something do we issue a short-lived signed URL. Location and other metadata are removed before upload.
• Encryption in transit and at rest: Communications are encrypted (TLS), and stored data is also encrypted using the cloud providers' systems.
• Key management: Server keys are managed in a dedicated secrets management system and are never included in the app.
• Administrator operations: We limit who can access production data and keep logs of what they do.
• Analytics: We don't send location, place names or photo URLs to analytics.

16.5 Understanding the external environment

We take the measures above with an understanding of the personal information protection systems of the following countries:

• United States (where Supabase, Cloudflare, Google (sign-in, place search and Firebase Analytics), Apple, Expo and PostHog are based)
• Republic of Korea (where Kakao is based; users and friends in the Republic of Korea)
• Japan (where the database is stored)
• Asia-Pacific region (where photos and videos are stored) [TO CONFIRM: country of storage]
• [TO CONFIRM: country of OpenFreeMap's operator]

17. If a breach happens

1. If we become aware of a leak, loss or damage of information, unauthorized access or similar (including where a setting such as Ghost mode, blocking or home protection fails because of a defect and information becomes visible to someone who shouldn't see it) (a "breach"), or the possibility of one, we'll investigate immediately and act to stop the harm from spreading (including by hiding information that has become visible, and temporarily suspending all or part of the Service if necessary). We'll look into the cause and take steps to prevent it from happening again.
2. We'll report to the authorities and notify you as required by law.
   • Japan: For breaches specified by law (such as those affecting more than 1,000 people, those caused for wrongful purposes such as unauthorized access, those that could cause financial harm, and those involving special care-required personal information), we report to the Personal Information Protection Commission and notify you. If we have filed a notification as a telecommunications business, we report any leak of the secrecy of communications to the Minister of Internal Affairs and Communications.
   • Republic of Korea: As described in Section 21.2 (19).
   • EEA, UK and Switzerland: We report to the supervisory authority, in principle within 72 hours of becoming aware of the breach, and notify you without undue delay if there is a high risk to your rights.
   • United States: We notify you in accordance with each state's laws.
3. We notify you through in-app notices and notifications, by email if we have your email address, and on our website.
4. Our liability for damage caused by a breach is set out in the Terms of Service (https://maplog.day/terms). Liability that can't be limited under the laws of the country or region where you live is not limited by the Terms of Service or by this Policy.
5. To protect your account and device, use a screen lock on your device, and don't let anyone else use your Apple or Google account.

18. Your rights and how to use them

18.1 What you can request

You can request the following regarding your information that we hold, as provided by law:

• Notice of the purposes of use (being told individually what we use your information for)
• Disclosure (you can choose how you receive it, for example electronically)
• Correction, addition or deletion
• Stopping its use, or erasure
• Stopping its provision to third parties
• Disclosure of records of its provision to third parties
• Data export (getting the photos, videos, posts and so on that you stored in the Service, in a machine-readable format)
• Withdrawal of consent
• Objection to how we handle your information

18.2 What you can do in the app

18.3 How to make a request

• For anything you can't do in the app, make a request through the contact points in Section 22 (Contact in the app, or email).
• Checking it's you: A request made in the app while you're signed in is treated as coming from the owner of that account. For email requests, we check using your account information. For guest accounts, we check by having the request come from the device that uses that account.
• Agents: A legal representative, or an agent you've authorized, can also make a request. We'll ask for proof of their authority (such as a power of attorney) and to verify both you and the agent.
• How long it takes: Without undue delay, and in principle within 30 days of receiving your request (within 10 days for people in the Republic of Korea; for people in the EEA and elsewhere, as described in Section 21.3).
• Fees: Free.
• If we can't do what you ask, we'll tell you why.
• We won't treat you unfavorably because you made a request.

19. Children and minors

• The Service is for people aged 13 and over. However, people living in the Republic of Korea must be 14 or over, and people living in the EEA, the UK or Switzerland must be 16 or over [TO CONFIRM: review the age for each country when we start offering the Service in the EEA, the UK and Switzerland]. People living in the United States must be 13 or over (Section 21.4 (5)). People below these ages may not use the Service. If we find out that we've collected information from someone below these ages, we'll delete it, except anything the law requires us to keep.
• The Service is not directed to children under 13.
• Date of birth: When you first use the Service (whether you start as a guest or sign in with Apple or Google), we ask for your date of birth. This is to check your age and apply restrictions for minors. Your age is determined under the rules of whichever is stricter about age: the country or region in your device's region setting, or your App Store country or region. Your date of birth is stored where only you can read it, and kept until you delete your account. You can't change it yourself later (if you entered it incorrectly, contact us through the contact points in Section 22).
• People under 16 in Japan: We confirm that you have consent from a parent or other legal guardian through the "I have my parent or guardian's permission" checkbox on the date of birth screen (APPI; the Personal Information Protection Commission's Q&A 1-62; the 2026 amendments; Section 21.1 (8)).
• If you're a minor (under 18 in Japan and most other places, under 19 in the Republic of Korea; the same applies below), get consent from your parent or other legal guardian before using it.
• Minors can't use People nearby, and aren't shown in anyone's People nearby. Our server determines this from your date of birth (people who haven't entered their date of birth yet also can't use People nearby, and aren't shown in it).
• With ID search, QR codes and friend links, minors can also add friends, and may receive friend requests from others. A friend request has no effect unless the other person accepts it. Once you're friends, features don't differ by age.
• We may suspend the accounts of people who misrepresent their age (Article 5 of the Terms of Service).
• Age information is used only to check age and apply restrictions for minors.
• We set default settings with the best interests of minors as our first consideration.
• We accept inquiries from parents and guardians (such as requests to delete a child's account) through the contact points in Section 22.

20. Changes to this Policy

1. Each version of this Policy has a whole number. The current version is at https://maplog.day/privacy, and past versions are at https://maplog.day/privacy/v{version} (for example, version 1 is at https://maplog.day/privacy/v1).
2. For changes that benefit you or are minor, we'll let you know in the app and on the website at least 7 days before they take effect.
3. For changes that are unfavorable to you or significant, we'll let you know in the app and on the website at least 30 days before they take effect, and notify you again in the app.
4. Before we expand the purposes of use, provide information to new recipients, transfer it to new countries, or start using location information in new ways, we'll ask for your consent again in the app before we start. If you don't consent, we won't do that processing (some features may stop being available).
5. If you don't accept how your information will be handled after a change, you can delete your account before the change takes effect.
6. Changes are recorded in the revision history at the end of this Policy.

21. Additional terms by region

21.1 Japan

For people living in Japan, the following applies in addition to the main text.

(1) Matters concerning retained personal data (Article 32 of the APPI)

(2) Records of provision to third parties: Our records of displays to friends and others (provision to third parties) consist of the Terms of Service (including Chapter 10; see Article 52(3)), each user's consent records and the location use and disclosure records (Article 19(3) of the Enforcement Rules of the APPI), and we will keep them for 1 year from the date of the last provision (Article 21(1) of the same Rules) [TO CONFIRM: implementation (there is no table for the Location Disclosure Records, no screen for viewing them, and no notice to Korean Users each time their location is provided (or in a summary); in Korea these are obligations under Articles 16(2) and 19(3) of the Location Information Act, so they must be implemented before release; the Japanese records of provision to third parties (Article 29 of the APPI) are also made from these records)]. We disclose them on request (Article 33(5) of the APPI).

(3) Third parties in foreign countries: As described in Sections 9.2 and 6.3, and in Section 8 (provision to place search providers).

(4) Telecommunications Business Act: We protect the secrecy of communications in accordance with the Telecommunications Business Act. Telecommunications business notification: [TO CONFIRM: whether a notification is required, and the notification number]. External transmissions from devices are made public as described in Section 10.

(5) Location information: In accordance with the "Guidelines on the Protection of Personal Information in Telecommunications Business", we collect location information, and show it to friends and others, only after getting your prior consent. We obtain consent to collection and use, and consent to provision to friends and others (provision to third parties under Article 27(1) of the APPI), separately, with the "[Required] Agree to the collection and use of my location" and "[Required] Agree to provide my location to third parties" checkboxes on the sign-in screen and elsewhere (Article 59(6) and (7) of the Terms of Service). Provision to investigative authorities is as described in Section 5.8.

(6) What we don't create: We don't create pseudonymously processed information or anonymously processed information. We also don't create face templates.

(7) Personally referable information: We don't provide advertising identifiers or similar information to third parties in a form that the recipient can link to an individual. We treat the IDs used for analytics (your Maplog user ID, the Firebase app instance ID and the IDFV) as personal data, and pass them only to our service providers PostHog and Google.

(8) People under 16 and responding to amendments of the law: For people under 16 in Japan, we confirm that a legal guardian has given consent through the "I have my parent or guardian's permission" checkbox on the date of birth screen (Section 19). We'll review this Policy and our consent screens when the 2026 amendments to the APPI (including how consent from people under 16 is handled) take effect.

(9) Where to get advice: In addition to our contact points (Section 22), you can consult the Personal Information Protection Commission's "APPI Consultation Dial" (+81-3-6457-9849).

21.2 Republic of Korea

For people living in the Republic of Korea, the following applies in addition to the main text. This section includes the content of the privacy policy (개인정보 처리방침) under Article 30 of Korea's Personal Information Protection Act (개인정보 보호법; "PIPA") and the personal location information processing policy (개인위치정보 처리방침) under Article 21-2 of the Act on the Protection, Use, etc. of Location Information (위치정보의 보호 및 이용 등에 관한 법률; the "Location Information Act"). For people living in the Republic of Korea, the Korean version is authoritative. If you are in the Republic of Korea, as for everyone else, we ask for your consent to the collection and use of personal information on the sign-in screen (or, if you were already using Maplog, on the one-time confirmation screen) with a checkbox separate from the one for the Terms of Service ("[Required] Agree to the collection and use of personal information"); that screen shows the main items, purposes and retention periods, and tells you that you may refuse and what happens if you do [TO CONFIRM: Korean counsel (whether it is appropriate to obtain required consent for processing that is necessary to perform the contract)].

(1) Purposes of processing, items and retention periods (처리 목적・항목・보유 기간)

(2) Provision to third parties (개인정보의 제3자 제공): We don't provide personal information to third parties except with your consent, or where Articles 17 and 18 of the PIPA allow it (such as where a law has special provisions). We provide personal location information to people you designate, such as friends, and, while "Show me to people nearby" is on, to the nearby Maplog users defined by that setting (people within about 50 m who open the People nearby screen), only after telling you the recipients and the purpose and obtaining your consent under Article 19(2) of the Location Information Act, and we will notify you each time we provide it ((10)) [TO CONFIRM: implementation (the note on the consent screen does not mention Friends nearby and the item provided to them (that you are within about 300 m), the purpose of provision, or that the recipients are determined by our servers' estimates; there is also no notice each time (or in a summary) yet)]. Consent to providing your location to friends and others ("[Required] Agree to provide my location to third parties") is required because it is essential to the core features of the Service, and if you don't consent or withdraw your consent, you can't use the Service (when you open the app, you will be asked to choose whether to consent again or delete your account). While you have not consented (including after withdrawing), we exclude you from together detection, showing spots to friends, Friends nearby and People nearby, and don't send your current location to our servers. Spots you take while you have not consented are not shown to friends even if you consent later (Article 60(4), item 2 of the Terms of Service). For being shown in People nearby, the note for this checkbox also tells you that you may be shown to people nearby, that it's on at first, and what others will see (profile photo, name and ID), and we obtain your consent with this checkbox. If you consent and are 19 or over, "Show me to people nearby" is turned on, and you can turn it off in Settings at any time.

(3) Outsourcing of processing (개인정보 처리 위탁): We outsource the tasks listed in the table in Section 8 to the providers listed there (for people in the Republic of Korea, what we send to the place search providers (Google and Kakao) is also treated as outsourcing of place search processing [TO CONFIRM: characterization under Korean law]). If we change outsourcees, we'll make this public in this Policy. Our outsourcing contracts cover matters such as prohibiting processing for other purposes, technical and managerial safeguards, restrictions on re-outsourcing, supervision and compensation for damages.

(4) Overseas transfers (개인정보의 국외 이전)

As outsourcing of processing and storage necessary to enter into and perform our contract with you, we transfer personal information overseas as shown below (excluding usage analytics), and make this public in this Policy (Article 28-8(1)3 of the PIPA). Our contracts with the recipients set out measures to protect your information.

[TO CONFIRM: each company's latest contact details]

Showing your information to friends outside the Republic of Korea: Your posts, spot points, the fact that you were together and the fact that you're nearby are also shown on the devices of friends outside the Republic of Korea (for example, in Japan). In the note for the "[Required] Agree to provide my location to third parties" checkbox, we tell you that being shown to friends in another country is a transfer to that country, and we set out here the recipient of the transfer (the friend, an individual), the country (the country where the friend is; this can't be identified at the time of consent and is mainly Japan), when and how the transfer takes place (over the network when the friend views it in the app), the items, the purpose (friend features), the period, and how to refuse and the effect of refusing (if you don't consent or withdraw consent, you can't use the Service and the information isn't shown to friends) (Articles 47 and 60(4)(2) of the Terms of Service).

Overseas transfers for usage analytics: Because usage analytics isn't necessary to perform our contract with you, wherever you are, we carry it out only if you consent to "[Optional] Agree to usage analytics and transfer abroad" (on the Korean-language screen, "[선택] 이용 통계 수집 및 국외 이전 동의") on the sign-in screen or elsewhere (Article 28-8(1)1 of the PIPA). On that checkbox screen, the recipients are shown by type (external analytics services (USA)), and the items in the following table (the names and contact details of the recipients, when and how the data is transferred, retention periods and so on) are set out in this Policy (which you can open from "View" next to the checkbox). The "Details" link on the checkbox also shows the matters under Article 28-8(2). You can use the whole Service even if you don't consent.

(5) Where processing takes place: We are a Japanese corporation. We collect the personal information of people in the Republic of Korea directly and process it in Japan (the database is in Tokyo), and also in the countries listed in the tables in (4) (the United States, the region where photos and videos are stored [TO CONFIRM: country of storage], and so on).

(6) Destruction procedures and methods (파기 절차 및 방법): When the retention period ends or the purpose has been achieved, we destroy personal information without delay. Electronic files are deleted in a way that can't be undone. Paper documents are shredded or incinerated. Information that other laws require us to keep is stored separately from other information, and destroyed when that period ends. We also run regular checks so that nothing is left behind.

Even after you delete your account, or after the purpose has been achieved, we keep the following information separately from other information, and destroy it when the period ends.

For how records confirming the collection, use and provision of location information are handled when people in the Republic of Korea delete their account or withdraw location consent, see (10).

(7) Rights of data subjects and legal representatives, and how to exercise them (정보주체와 법정대리인의 권리・의무 및 행사방법): You can at any time request access to, correction or deletion of your personal information, suspension of processing, or withdrawal of consent. You can also refuse automated decisions, or ask for an explanation of them (Article 37-2 of the PIPA) (we don't make automated decisions that significantly affect your rights or obligations). You can exercise these rights through features in the app (Section 18.2) or through the contact points in Section 22, and we'll respond within 10 days of receiving your request. Legal representatives and authorized agents can also exercise them (a power of attorney is required).

(8) Measures to ensure security (개인정보의 안전성 확보조치): We take measures such as establishing and carrying out an internal management plan, managing access rights, controlling access, encryption, keeping access records, security programs and physical measures (Section 16). For location information, we take the managerial and technical protective measures required by Article 16 of the Location Information Act. If we meet the criteria in Article 39-7 of the PIPA, we will, in accordance with that Article, take measures such as obtaining insurance to meet our liability for damages [TO CONFIRM: whether we meet the criteria].

(9) Installation and operation of tools that automatically collect personal information, and how to refuse them (개인정보 자동 수집 장치의 설치・운영 및 거부): The app includes usage analytics tools (the PostHog SDK and Google's Firebase Analytics SDK; Firebase uses the app instance ID and the IDFV, and automatically records events such as the first time you open the app) and a push token mechanism. Wherever you are, the analytics tools run only if you consent (until you do, not even automatically recorded events are sent). You can stop them at any time by turning off Settings > "Privacy" > "Share usage data". You can stop notifications in iOS Settings. We don't show personalized ads based on information about your behavior. Our website doesn't use cookies or other tracking tools for analytics or advertising (only your choice of light or dark display is stored in your browser).

(10) Processing of personal location information (개인위치정보의 처리)

The details are set out in Chapter 10 (Location Information) of the Terms of Service (https://maplog.day/terms).

• Confirmation records (수집・이용・제공사실 확인자료): Under Article 16(2) of the Location Information Act, we will have these recorded automatically and kept for 1 year from the date recorded [TO CONFIRM: implementation (there is no table for the Location Disclosure Records, no screen for viewing them, and no notice to Korean Users each time their location is provided (or in a summary); in Korea these are obligations under Articles 16(2) and 19(3) of the Location Information Act, so they must be implemented before release)]. They don't include coordinates.
• Destruction: Personal location information whose purpose has been achieved is destroyed immediately, in a way that can't be undone (Article 23 of the Location Information Act). Confirmation records are destroyed when their retention period ends.
• Withdrawal of consent: If you withdraw all or part of your location consent (including by deleting your account), we destroy without delay the personal location information and confirmation records covered by the withdrawal (Article 24(4) of the Location Information Act; except those that other laws require us to keep).
• Temporary suspension: When you turn on Ghost mode, the collection of your current location (sending it to our server) and its provision to other users stop immediately. The spot points and capture points of photos and videos you take during Ghost mode are kept as your own records (they aren't shown to friends). The route you walked is still recorded during Ghost mode, but only on your device (we don't collect it). To stop these kinds of collection as well, turn off Maplog's location permission in iOS Settings. We also accept requests for temporary suspension by other means through the contact point in Section 22, and we won't refuse them (Article 24(2) of the Location Information Act).
• Provision to third parties and notification: When we provide personal location information to people you designate (friends, people who were with you when you took a photo, Friends nearby, and friends' exports you've allowed yourself to be included in) or, while "Show me to people nearby" is on, to Maplog users within about 50 m who open the People nearby screen, we will notify you immediately each time of the recipient (their display name and ID; when you're recorded as someone who was with another user, this includes the list of people who can see your face and name on that post), the date and time, and the purpose, through an app notification and the "Location Disclosure Records" screen [TO CONFIRM: implementation (there is no table for the Location Disclosure Records, no screen for viewing them, and no notice to Korean Users each time their location is provided (or in a summary); in Korea these are obligations under Articles 16(2) and 19(3) of the Location Information Act, so they must be implemented before release)]. The text of these notices doesn't include coordinates. If you can't receive notifications, we send them to the email address or other destination you've specified in advance, or, if you haven't specified one, we show them when you open the app (Article 50 of the Terms of Service). If you separately consent, we'll notify you in batches every 30 days. We will let you switch back to a notice each time in settings at any time.
• Rights of guardians of children aged 8 or under and others: Guardians with a duty of protection (보호의무자) of children aged 8 or under, adults under guardianship and people with severe mental disabilities (Article 26 of the Location Information Act) may, to protect that person's life or body, give written consent and exercise the rights set out in Article 53 of the Terms of Service (see also Article 60(22) of the Terms of Service). However, Maplog is not a monitoring service, and we don't offer a way to use it based on a guardian's consent.
• Location Information Manager (위치정보관리책임자): As in (16).
• Location-based service business report (위치기반서비스사업 신고): [TO CONFIRM: report number]

(11) Processing by AI (인공지능 처리): What information is input into AI (the name and language of places in Community Places, and photos taken with the rear camera), the fact that we don't store the photos, how the AI provider handles the data, how to avoid sending it (photos are sent only if you've allowed it, and you can withdraw this at any time in settings), and how to object to results are as described in Section 11.

(12) Possibility that sensitive information (민감정보) is revealed, and how to avoid it: We don't ask for sensitive information (such as ideology or beliefs, health or sex life) or unique identification information. However, such matters may become apparent to friends, people you were with and people who watch exported videos, from the photos, videos and captions you take, or from the type of place where you took photos (such as hospitals or places of worship). If you don't want them seen, you can choose not to take photos, delete posts, use Ghost mode, or not show place names in exports.

(13) Pseudonymized information (가명정보): We don't process pseudonymized information.

(14) App access permissions (앱 접근권한): There are no required permissions. The optional permissions are Location (While Using and Always), Camera, Microphone, Photos, Notifications and Motion & Fitness; you can use the Service without allowing them (however, while Location (While Using) and Camera are not allowed, you can't take photos or use together detection, Friends nearby, People nearby or your route). The reasons, and what happens if you don't allow them, are described in Section 12. You can change them in iOS Settings > Maplog.

(15) Advertising information (광고성 정보): We don't send it now. If we start, we'll get your separate consent, and a further separate consent for sending it at night (from 9 p.m. to 8 a.m. the next day). Every 2 years from the date you consented, we'll check whether you want to keep consenting.

(16) Chief Privacy Officer, Location Information Manager and complaints department (개인정보 보호책임자・위치정보관리책임자・고충처리 부서)

(17) Domestic representative (국내대리인): Under the current criteria (Article 31-2 of the PIPA and Article 32-5 of the Network Act), we aren't required to designate a domestic representative. If we designate one, we'll state their name, address, phone number and email address in this Policy.

(18) Remedies for infringement of rights (권익침해 구제방법): In addition to our contact points (Section 22), you can seek advice, file a report or apply for mediation with the following organizations.

For disputes about location information, either you or we can apply to the Personal Information Dispute Mediation Committee for mediation (Article 28(2) of the Location Information Act). We may also apply to the Broadcasting, Media and Communications Commission (방송미디어통신위원회) for a ruling (Article 28(1) of the same Act).

(19) If a breach happens: If we become aware of a breach or a possible breach, we'll notify you within 72 hours (of the items leaked, when and how it happened, what you can do to reduce harm, our response and the remedy procedures, the contact point, and your rights, such as to compensation, and how to exercise them), and, where required by law, report it to the Personal Information Protection Commission or the Korea Internet & Security Agency (KISA) within 72 hours. We'll report infringement incidents under Article 48-3 of the Network Act to the Minister of Science and ICT or KISA within 24 hours.

(20) Age: People living in the Republic of Korea must be 14 or over to use the Service (Section 19). Because we don't have a system for obtaining and verifying the consent of a legal representative for children under 14 (Article 22-2 of the PIPA; Article 25 of the Location Information Act), children under 14 can't use the Service, and we don't process the personal information of children under 14. If the date of birth screen shows that you're under 14, you can't continue and can't use the Service (you can re-enter your date of birth in case you made a mistake). If you're under 19, get consent from your legal representative before using the Service. People under 19 can't use People nearby, and aren't shown to people nearby either (they can add friends with ID search, QR codes and friend links).

(21) Changes: When we change this Policy, we'll make public the effective date, the reasons for the change and a comparison of the old and new versions, and keep earlier versions available (Section 20).

21.3 EEA, UK and Switzerland

If you are in the European Economic Area (EEA), the United Kingdom or Switzerland (including while traveling), and the EU General Data Protection Regulation (GDPR), the UK GDPR, the Swiss Federal Act on Data Protection or similar laws apply, the following applies in addition to the main text.

(1) Controller and representatives

• Controller: ideaccept Inc. (as in Section 1)
• EU representative (Article 27 GDPR): [TO CONFIRM: appoint by the effective date of this Policy, and state name, address and email address. Check with EU counsel whether Article 3(2)(b) GDPR applies to users while traveling; if we conclude that it doesn't, record the reasons]
• UK representative (Article 27 UK GDPR): [TO CONFIRM: appoint by the effective date of this Policy, and state name, address and email address (with the same check as for the EU representative)]
• Swiss representative: [TO CONFIRM: whether an appointment is required]
• Data Protection Officer (DPO): [TO CONFIRM: whether an appointment is required, and contact details]
• Points of contact under the Digital Services Act (DSA) (for authorities and for users): contact@ideaccept.com (languages: Japanese, Korean and English)

(2) Legal basis for each purpose (purpose numbers refer to Section 4.1). If you're in the EEA, the UK or Switzerland, we ask for your consent with the same checkboxes as everyone else (Article 3(1) of the Terms of Service), but we don't treat the [Required] checkboxes (the Terms of Service, the collection and use of personal information (this Policy), the collection and use of your location, and the provision of your location to third parties) as consent under Article 6(1)(a) GDPR. Those checkboxes serve to confirm your intention to enter into the contract and that you have been informed about the processing; the legal bases for processing are as set out in the following table (processing necessary for Maplog's core features, including providing your location to friends, is based on performance of a contract). Of the checkboxes and the question about photos for AI, the only ones we treat as consent under Article 6(1)(a) are the [Optional] usage analytics checkbox and sending photos to AI. If you withdraw the "Provide my location to third parties" checkbox, stopping your use of the Service does not place a condition on the withdrawal of consent; we treat it as termination of the contract (Article 61(17) of the Terms of Service) [TO CONFIRM: EEA counsel (not treating the [Required] checkboxes as consent under Article 6(1)(a), and characterizing stopping Users who withdraw as termination of the contract)].

(3) Right to object: Where we process your information on the basis of legitimate interests, you have the right to object at any time on grounds relating to your particular situation. We will stop that processing unless we can demonstrate compelling legitimate grounds that override it. You can object through the contact points in Section 22 (email: contact@ideaccept.com). Sending photos to AI is based on consent ((2)), and you can withdraw that consent at any time in Settings > Map building > "Help build the map for everyone". If you withdraw it, we stop sending photos to AI and decide the category from the place name alone.

(4) Whether you have to provide information: Your account information, user ID and display name, and date of birth are necessary for the contract for the Service. If you don't provide them, you can't use the Service. "While Using" location and what you capture with the camera are necessary for taking photos, together detection, Friends nearby, People nearby and your route; if you don't provide them, you can't use those features (you can still view your friends' posts, Logs and the map, and so on). Everything else is optional, and you can use the Service's core features without providing it.

(5) Where we get information from: In addition to collecting it directly from you, we get information from other users ("together" records, photos, comments and reports), from Apple and Google (sign-in), and from providers of map and place information (Section 8).

(6) Grounds for international transfers

The grounds for transfers to each recipient are as follows.

• If the DPF can no longer be used, we'll switch to the SCCs.
• You can ask for a copy of these safeguards (such as the SCCs) through the contact points in Section 22.

(7) Your rights: You have the rights of access, rectification, erasure, restriction of processing, data portability and objection, and the right to withdraw consent (withdrawing doesn't affect the lawfulness of processing carried out before you withdrew). We'll respond, in principle, within one month, and where necessary we may extend this by up to two months, telling you why.

(8) Complaints to a supervisory authority: You can lodge a complaint with the supervisory authority of the country where you live or work, or where the alleged infringement took place (list of EEA supervisory authorities: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en ; UK: Information Commissioner's Office (ICO) https://ico.org.uk ; Switzerland: Federal Data Protection and Information Commissioner (FDPIC) https://www.edoeb.admin.ch ). If you're in the UK, you can also complain to us first; we'll acknowledge your complaint within 30 days of receiving it, and look into it and respond without undue delay.

(9) Automated decision-making: We don't make decisions that have legal effects, or similarly significant effects, based solely on automated processing. Actions such as suspending an account are reviewed by our staff.

(10) Special categories of personal data: We don't ask for special categories of personal data such as health, religion or sex life, and we don't infer them from things like the categories of places where you take photos (Section 4.3).

(11) Usage analytics: In the EEA, the UK and Switzerland, as everywhere else, we don't send usage data to PostHog or Google until you consent (including events that Firebase records automatically), and we don't use analytics IDs on your device until you consent.

(12) Children: People living in the EEA, the UK or Switzerland must be 16 or over to use the Service (Section 19).

(13) Language: If the language versions of this Policy differ, the version in the language you had displayed in the app applies (Article 61(12) of the Terms of Service). [TO CONFIRM: preparing versions in the languages of the countries where we offer the Service]

21.4 United States

For people living in the United States, the following applies in addition to the main text. We follow the approach below. This section does not admit that we are a business subject to the California Consumer Privacy Act (CCPA) or other state laws, and does not create any rights or grounds for claims other than those provided by applicable law.

(1) Categories of information we collect

• Our purposes of use are described in Section 4, and our retention periods in Section 14.
• We don't sell or share: We don't sell personal information, and we don't "share" it for cross-context behavioral advertising. This has also been true for the past 12 months.
• Precise geolocation: We use and disclose precise geolocation only to provide the features you request and for the other purposes permitted by the CCPA regulations (Cal. Code Regs. tit. 11, § 7027(m)), such as keeping the Service safe and secure, preventing fraud and misuse, and complying with the law (we may create statistics aggregated enough that no individual or home can be inferred). For that reason, we don't handle it in any way that would give rise to the right to limit the use of sensitive personal information. We collect and use precise geolocation, and provide it to other users, only after you give prior consent (opt-in) with the respective [Required] checkboxes (Article 3(1), items 3 and 4 of the Terms of Service), and where state law requires consent to process sensitive data, we treat those checkboxes as that consent (Article 62(10) of the Terms of Service). Provision to other users is an intentional disclosure at your direction, and we don't treat it as a sale or sharing. You can stop it at any time in iOS Settings or with Ghost mode, and you can withdraw your consent to provision to third parties at any time in Settings (if you do, you can no longer use the Service).

(2) Your rights under state privacy laws: Depending on the laws of the state where you live, you have the right to know (access), to delete, to correct, to data portability, and to opt out of sale, sharing, targeted advertising and profiling (we don't do any of these).

• You can make requests through the contact points in Section 22. We verify your identity using your account information.
• An authorized agent can also make requests for you (we'll ask for written authorization and to verify your identity).
• If you disagree with our response, contact us through the contact points in Section 22 within a reasonable period after receiving it, and say that it's an "appeal". We'll tell you the outcome and our reasons within the period required by state law. If you disagree with the outcome, you can contact your state's Attorney General.
• We won't treat you unfavorably for exercising your rights.

(3) California Online Privacy Protection Act (CalOPPA): The types of information we collect are described in Section 3, the types of parties we share it with in Sections 6 and 8, how you can review and correct your information in Section 18, how we tell you about changes in Section 20, and the effective date at the top of this Policy. How we respond to Do Not Track signals is described in Section 13. We don't let other companies collect information about your activity over time and across other services through Maplog (we've turned off Google Analytics' data sharing settings, Google signals and ads personalization; Section 13).

(4) California Civil Code Section 1798.83 (Shine the Light): We don't disclose personal information to third parties for their direct marketing purposes.

(5) Children (COPPA): People living in the United States must be 13 or over to use the Service (Section 19). The Service is not directed to children under 13. If a date of birth showing an age under 13 is entered on the date of birth screen, we don't store that date of birth and we won't let that person continue (the date of birth can be re-entered in case of a mistake). For people who consented with the [Optional] checkbox on the sign-in screen, usage analytics are sent from before the date of birth screen. If we find out that we've collected information from a child under 13, we'll delete it. Parents and guardians can ask us to delete their child's information through the contact points in Section 22.

(6) Health information: We don't infer health-related information from things like where you take photos, and we don't sell health-related information. The place names, categories and spot points of posts you take at places such as hospitals and pharmacies may be "consumer health data" under Washington's My Health My Data Act and similar laws. We collect and share them only for the features you request (storing your records and showing them to your friends and the people you were with), don't use them for any other purpose, and don't provide them to anyone else. Posts you take at places such as hospitals may be visible to your friends and the people you were with (as also described in Section 21.2 (12)). For details, see our Consumer Health Data Privacy Policy (https://maplog.day/privacy/health) [TO CONFIRM: create a consumer health data privacy policy for Washington and Nevada and link to it from the homepage of our website].

(7) Breaches: We'll notify you in accordance with each state's laws (Section 17).

22. Contact us

We accept questions about this Policy and how your information is handled, the requests described in Section 18, and complaints and consultations through the following contact points. We respond in Japanese, Korean and English.

• In the app: Menu > "Contact & feature requests"
• Email: contact@ideaccept.com
• Mail: ideaccept Inc., Attn: Maplog, Kuwano Building 2F, 6-23-4 Jingumae, Shibuya-ku, Tokyo 150-0001, Japan

For places to get advice and supervisory authorities in each region, see Section 21.

Revision history

ideaccept Inc. (株式会社ideaccept) Kuwano Building 2F, 6-23-4 Jingumae, Shibuya-ku, Tokyo 150-0001, Japan Representative: Kaito Asano, Representative Director Email: contact@ideaccept.com https://maplog.day