Location-Based Service Terms

Article 1 (Purpose)

These Terms set out the rights, obligations and responsibilities of the Company and personal location information subjects, and other necessary matters, regarding the use of the location-based services provided by the Company.

Article 2 (Rules outside these Terms)

Matters not set out in these Terms are governed by the Location Information Act, the Personal Information Protection Act, the Act on Promotion of Information and Communications Network Utilization and Information Protection and other applicable laws, and by the Company’s Terms of Service and Privacy Policy.

Article 3 (Services and fees)

The location-based services are free of charge. However, data charges follow the plan of your mobile carrier.

The Company receives, through the App, the location measured by your device’s operating system and Google Play services using GPS, Wi-Fi, cell towers and similar means, and only while you are using the App.

When you use ‘Flex nearby’, your device sends its location to our server while the AR screen is open, so that people who are together in the same place can connect without a room or code. The server uses this location only to check whether you are near each other (within about 50 m), keeps it briefly in memory (about 1 minute) and then discards it; it is not stored. Your location and distance are never shown or provided to other users. If, together with your location consent, you agree to the clause ‘Flex with people nearby’ (location is used only briefly to check proximity and is never stored or shared) and keep the setting on, you are connected automatically, without tapping anything, with people nearby who have done the same. People who are not your friends then see only a temporary nickname (a number) used for that connection alone, and you see each other’s money only after your floors are aligned (before that, only the number of people nearby is shown). If you do not agree or turn the setting off, you are never connected automatically with people who are not your friends (you connect only when both of you tap ‘Flex together’, and you then become friends), and you can block or report anyone you are connected with at any time. It is not available to users under 18 (19 in Korea). As required by law, the fact that location was used (date only, no location) is recorded for 6 months.

Article 4 (Consent and age)

• Right before your first location action (whichever comes first of opening the map, Share, Pick up and ‘Remember this spot’), the Company asks for your agreement to these Terms (required) and your consent to the provision of personal location information to third parties (for public drops, required). Before consent, no coordinates are sent to our server or to Google.
• Because children under 14 cannot use the App, there is no procedure for consent by a legal representative. If we learn that location information of a child under 14 has been collected, we destroy it without delay.
• Users under 19 are not offered features in which their location relates to other users, such as public drops, pickups, display of nearby public drops and nearby rooms.

Article 5 (Provision of personal location information to third parties)

The Company uses and provides personal location information only within the scope of your consent. The consent to provision to third parties for public drops reads as follows.

When you create a public drop, its location (accuracy about 1 m) is provided to other users who come within a 50 m radius. Recipients: users looking for the drop / Purpose: finding and picking up the drop / Retention: until the drop expires (max. 72 hours) / We will notify you of the provision history collectively every 30 days through your inbox (consent to collective notification).

Unless the law specifically provides otherwise, the Company does not use personal location information or provide it to third parties beyond the scope of consent.

Article 6 (Notification of provision to third parties)

Under Article 19(3) of the Location Information Act, notification is in principle given each time information is provided to a third party; if you have consented, however, we collect the provision history for up to 30 days and notify you at once under paragraph 4 of the same article. The Company notifies you of the recipients (users who looked for the drop), the number of provisions, the range of provision dates and times, and the purpose, through ‘Location sharing history’ in the in-app inbox.

Article 7 (Purpose and period of retention of personal location information)

• Coordinates of public drops: kept to provide the public drop service and destroyed immediately when the drop expires (max. 72 hours) or is fully picked up.
• Coordinates of Flex Together rooms: kept to provide the room service and destroyed immediately when the room ends.
• Device coordinates used for nearby searches and pickups: used only to process the request and not stored. However, to prevent location spoofing (teleporting), the one most recent location from when you create a public drop or request an exact location is stored coarsened to about 11 m (overwritten by the next request) and deleted after 1 hour.
• Locations of ‘Only me’ drops: stored only on your device and not received by the Company. They disappear when you delete the App.

Article 8 (Basis and period for keeping records of use and provision of location information)

Under Article 16(2) of the Location Information Act, the Company automatically records the use and provision of location information (hashed install ID, type of use, drop number, grid cell number of about 500 m, hashed ID of the person who received the location, date and time), keeps these records for 6 months and then deletes them automatically. If you withdraw your consent, we destroy them without delay (Article 24(4)).

Article 9 (Rights of personal location information subjects)

• You can withdraw all or part of your consent at any time. Tapping ‘Delete my data on the server’ in the App settings is treated as withdrawal of consent, and the collected personal location information and records are destroyed without delay. If you turn off the device’s location permission, we stop receiving your location from then on.
• You can request a temporary suspension of the collection, use and provision of location information, and you can suspend it at any time by turning off the device’s location permission or not using location features.
• You can request access to, or notification of, your records of use and provision of location information and the reasons for and details of the provision of your personal location information to third parties, and you can request correction of errors. The Company will not refuse without good reason.
• Requests can be made at yoonho@zoopiter.co.kr or +82-2-333-3140. Because there are no accounts, you may need to use the in-app feature or give us information that identifies the data.

Article 10 (Rights of guardians of children aged 8 or under, etc.)

Because the App does not allow use by children under 14, we do not provide location-based services based on the consent of guardians of children aged 8 or under, adults under guardianship and similar persons.

Article 11 (Location Information Manager)

The Company designates a Location Information Manager to protect personal location information and handle related complaints: Yoonho Myoung (CEO) · yoonho@zoopiter.co.kr · +82-2-333-3140

Article 12 (Changes and suspension of the services)

The Company may change or stop all or part of the location-based services due to technical circumstances, circumstances of external services (such as Google), laws, or operating policies by country or region, and will announce this in the App in advance. In urgent cases, we will announce it right after stopping.

Article 13 (Compensation for damage)

If you suffer damage because the Company violated Articles 15 to 26 of the Location Information Act, you may claim compensation from the Company. The Company is not liable if it proves that it acted without intent or negligence.

Article 14 (Exemptions)

The Company is not liable when it cannot provide the services or damage occurs because of natural disasters, the user’s intent or negligence, intentional interference by third parties, or location errors arising from devices, satellites or the communication environment, unless the Company acted intentionally or negligently.

Article 15 (Dispute resolution)

For disputes relating to location information, you may apply to the Korea Media and Communications Commission for a ruling under Article 28 of the Location Information Act, or apply to the Personal Information Dispute Mediation Committee (+82-1833-6972, www.kopico.go.kr) for mediation under Article 43 of the Personal Information Protection Act.

Article 16 (Business information)

Company: ZOOPITER Soft Corp. · CEO: Yoonho Myoung · Address: 3F, 222 Seokchonhosu-ro, Songpa-gu, Seoul, Republic of Korea · Phone: +82-2-333-3140 · Email: yoonho@zoopiter.co.kr · Business registration no.: 105-87-76709

Addendum

These Terms (version 1.0) take effect on December 8, 2026.