Privacy Policy

Last Updated: Feburary 10, 2025

Introduction

dobStudio, Inc. and devutai (“Company”, “we”, or “us”) respect your privacy. We are committed to protect your personal information and privacy through our compliance with this Privacy Policy.

This Privacy Policy describes how and why we may collect, store, use, and/or share (“process”) your personal information when you use our services (“Services”). This includes but is not limited to:

1. Using our apps and content.
2. Communicating with us through email, text, and other electronic messages.
3. Interacting with us in other related ways, such as through sales, marketing, or events.

Please read this Privacy Policy carefully to understand our practices regarding your personal information and how we handle it. If you do not agree with our Privacy Policy, you may choose not to use our Services. By accessing or using our Services, you agree to the terms of this Privacy Policy. This Privacy Policy may change from time to time. Your continued use of the Services after any changes constitutes your acceptance of the updated policy. Please review this Privacy Policy periodically for any updates.

Children under the Age of 13 or Minimum Age

Our Services are not intended for children under the age of thirteen (13) or sixteen (16) if you are located in the EU (“Minimum Age”), and we do not knowingly collect personal information from anyone under Minimum Age. If you are under Minimum Age, please do not use or provide any information on our app or through its features. This includes registering, making purchases, or submitting any personal information such as your name, address, telephone number, email address, or any screen name or username. If we learn or become aware that we have collected personal information from a child under Minimum Age without verified parental consent, we will promptly delete that information. If you believe we have collected information from or about a child under Minimum Age, please contact us at hello@devutai.com.

By accessing our Services, you confirm that you are at least 13 (or 16) years old and meet the minimum age required by the laws of your country. If you are not old enough to provide consent to our terms, your parent or legal guardian must do so on your behalf.

Information We Collect About You and How We Collect It

Information You Provide to Us

The information we collect on or through our Services may include:

1. Information that personally identifies you, including your name, age, occupation, gender, country of residence, address, email address, or telephone number ("personal information").
2. User-generated or original content such as facial data, images, videos (including audio and voice recordings), and any other data contained in such content.
3. App activity details, including visit history, search history, purchase history, and advertising identifiers (ADID/IDFA).
4. Technical and usage data, such as advertising identifiers (ADID, IDFA), basic login identifiers, device model, mobile carrier information, operating system and version, app usage history, and consultation records.

Information We Collect through Automatic Means

We may use automatic data collection technologies to collect certain information about your device, browsing actions, and usage patterns, including:

1. Details of your visits to our app, including purchase history within our app, logs, communication data, and the resources that you access and use on our app.
2. Simplified login information from services such as Apple, Google, Naver, and Kakao, along with associated login identifier.
3. Name, email address and consultation details.
4. Original photos, images, or videos (with voice) owned by the user.

Use of Tracking Technologies

We may use tracking technologies, such as device identifiers (e.g. Advertising IDs like ADID/IDFA and SDKs), to automatically collect information about your interactions. This includes details about app usage, traffic patterns, app performance and related statistics. The information collected may include your device type, device ID or other unique identifiers, operating system version, carrier details, and geolocation data.

We may combine certain automatically collected information with other information we obtain about you, including data from third parties.

1. Meta Platforms Ireland Limited: We may allow Meta Platforms Ireland Limited to access and process information collected through tracking technologies, such as your app activity, purchase history, advertising identifiers (ADID/IDFA). This information may be used to enhance advertisements, personalize features and content, improve product security, enhance user experience , and support research and development efforts.
2. TNK Factory Corporation: We may allow TNK Factory Corporation to access and process non-personally identifiable behavior information collected through tracking technologies, such as your app activity, purchase history, advertising identifiers (ADID/IDFA), device model, carrier details, operating system and version. This information may be used to deliver personalized advertisements, manage reward points, handle customer inquiries, and generate statistical data for advertisers.

We do not control these third parties' tracking technologies or how they use the data they collect. If you have any questions about an advertisement or other targeted content, we encourage you to contact the provider directly. For information about opting out of targeted advertising from many providers, please refer to Choices About How We Use and Disclose Your Information.

How We Use and Process Your Information

We use information that we collect about you or that you provide to us;

1. To facilitate account creation and authentication and otherwise manage user accounts.
2. To communicate with you about products, or services provided by us or to deliver the products or services you request, including services that convert images and videos;
3. To provide subscription services and process in-app payments;
4. To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including preventing misuse or unauthorized use of our Services;.
5. To send you notices, updates, support and administrative messages and to respond to your comments, questions, and customer service requests;
6. To communicate with you about your account, including expiration and renewal notices;
7. To enable the creation of AI-generated styles using a comprehensive big dataset;
8. To analyze and monitor trends, usage patterns, and activities based on user interests and preferences, generate statistical insights, and manage customer relationships (CRM) in connection with our Services;
9. To conduct surveys and deliver promotional or survey-related prizes;
10. To host and conduct service-related meetings and invite you to participate in, or informing you of the results of, customer satisfaction or market research surveys;
11. To facilitate promotional events and process and deliver entries and rewards;.
12. To deliver personalized advertisements and recommend services tailored to your preferences; and
13. To develop new products or services, as well as conducting new trials and studies of new products

What Legal Bases Do We Rely on to Process Your Information

If you are located in the EU or UK, this section applies to you

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your information.

1. Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
2. Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
3. Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
4. Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests, and those interests do not outweigh your interests and fundamental rights and freedoms.
5. Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
6. Public Task. We may process your information for the purposes of public interest.

How Long We Keep Your Information

We keep your personal information for the period of your use of our Services for as long as necessary to provide the products or services you have requested, fulfill your requests, comply with legal obligations, enforce agreements, and other legitimate and lawful business purposes, and for six (6) months after you delete your account or withdraw your consent, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). You may withdraw your consent at any time by emailing us at hello@devutai.com. When we no longer have a legitimate business need to process your personal information, we will either delete such information or securely store it in a separate database if deletion is prohibited by applicable law.

Disclosure of Your Information

We may disclose personal information that we collect, or you provide as described in this Privacy Policy:

1. To our subsidiaries and affiliates for the purpose of providing our Services.
2. To contractors, service providers and other third parties we engage to perform support Services for us. These third parties are contractually obligated to keep your personal information confidential and use it solely for the purposes specified by us. They are prohibited from processing your personal information for any purpose outside the scope of the agreed-upon tasks.
   Our agreements with these third parties require them to implement technical and managerial protection measures to protect your personal information and prohibit re-outsourcing without prior authorization. We also manage and monitor their handling of your personal information to ensure it is safely processed. If there are any updates to the outsourced tasks or the third parties involved, we will update this Privacy Policy accordingly. The following is a list of contractors or service providers we engage to perform support Services for us:
   1. Amazon Web Services, Inc. (AWS): Responsible for storing and managing databases, sending notifications, managing server infrastructure, and temporarily storing image and video data for conversion (deleted immediately after conversion).
   2. Google Inc., Meta Platforms Ireland Limited, and Wisetracker Inc.: Involved in analyzing user behavior based on interests, generating statistical insights, managing CRM, providing personalized recommendations, and sending messages.

We may also disclose your personal information:

1. To comply with any court order, law, or other legal process, and also to response to any government or regulatory requests;
2. To enforce or apply our terms of use and other agreements for billing and collection purposes;
3. To protect the safety, rights, or property of you, our customers, or others; and
4. With your consent or at your direction.

International Transfer

Your personal information may be transferred across international borders to our other affiliates, or to other companies, located outside your country of where you live.

If you live in the European Economic Area (EEA) and your personal information is transferred to countries outside the EEA, we ensure that such transfers comply with applicable data protection laws. This includes implementing safeguards such as the EU Standard Contractual Clauses (SCC) under Article 46 of the GDPR or ensuring the recipient is covered by a positive adequacy decision under Article 45 of the GDPR.

For transfers to other countries, we adopt appropriate measures, such as approved contractual clauses, to ensure that your personal information is treated securely and in accordance with applicable privacy laws. In all cases, your rights and protections remain with your personal data regardless of its location.

Data Security and Deletion

We prioritize the security, integrity, and confidentiality of your information. To safeguard your information, we have implemented technical, administrative, and physical security measures designed to protect personal information from unauthorized access, disclosure, use, and modification. Our security procedures are regularly reviewed and updated to incorporate advancements in technology and best practices. However, please note that no security measures or systems are completely perfect or impenetrable.

When the retention period of personal information expires, we delete your personal information from our records, ensuring that it is irrevocably destroyed. If case where applicable laws require us to retain your personal information beyond the expiration of the retention period or after your use of our Services, we will securely store the information in a separate database or storage location to comply with legal obligations.

Choices About How We Use and Disclose Your Information

We are committed to providing you with choices or control over your personal information. Below are the options available to manage how your information is used and shared:

1. Disclosure of Your Information with Third-Parties for Advertising: If you prefer that we do not share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by adjusting your user preferences in your account settings or by sending a request to us at hello@devutai.com.
2. Promotional Offers from the Company. If you do not wish to receive promotional communications about our products or services, you can opt-out by adjusting your user preferences in your account settings or by sending an email request to us at hello@devutai.com. If you receive a promotional email, you may unsubscribe by following the instructions provided in the email.
3. Targeted Advertising. If you do not want us to use information for targeted advertising, you can opt-out by adjusting your user preferences in your account settings or emailing us at hello@devutai.com.

If you are located in a region governed by GDPR or similar laws, we will only share, use or send your information with your explicit consent for the following:

1. Sharing your information with unaffiliated third parties for advertising purposes
2. Sending promotional communications about our products or services with subscription checkboxes remaining unchecked by default
3. Using your information for targeted advertising

You may withdraw your consent at any time by contacting us at hello@devutai.com or adjusting your preferences in your account setting.

We do not control or oversee how third parties collect or use your information for interest-based advertising. However, these third parties may offer options to choose whether your information is collected or used for this purpose.

Your State Privacy Rights

If you are resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to process your personal information. These rights may be limited in some circumstances by applicable law.

The exact scope of these rights may vary by state. To exercise any of these rights, please email us at hello@devutai.com. To appeal a decision regarding a consumer rights request, please email us at hello@devutai.com noting which decision you are appealing within 30 days.

Accessing and Correcting Your Information

You may also access, correct, or delete your personal information through [My Page] section in the app. Please note that deleting your personal information will also result in the deletion of your user account. We may decline requests to modify information if we believe the changes violate any law or legal requirements or result in accurate information.

Additional Information for California Residents

Exercise Your Rights

If you are a California resident, you may exercise your rights for the personal information covered by this Privacy Policy as follows:

1. Right to Know: You have the right to request that we disclose to you the categories of personal information we have collected about you, as well as the sources of such personal information, the purposes, and the categories of third parties with whom such personal information is shared.
2. Right to Access: You have the right to request access to categories and specific pieces of personal information about you that we collect, use, and disclose.
3. Right to Delete: You have the right to request that we delete personal information that we collect from you, subject to applicable legal exceptions.
4. Right to Correct: You have the right to request that we correct inaccurate personal information that we maintain about you, subject to applicable legal exceptions.
5. Right to Opt Out of Sale or Sharing of Personal Information: you have the right to “opt out” of the “sale” or “sharing” of your “personal information” to or with “third parties” (as those terms are defined by applicable law).

Right not to Receive Discriminatory Treatment: We will not discriminate against you because of your exercise of any of the foregoing rights, or any other rights under the California Consumer Privacy Act. We may, however, charge different prices or rates, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by your personal information.

Your California Privacy Rights under California’s Shine the Light Law

Under California’s “Shine the Light” law (Civil Code Section § 1798.83), California residents who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their direct marketing purposes. To make such a request, please contact us via email, or write to us at the address below.

Additional Information for EU/UK Residents

If you are located in the EU or UK, the following protection rights under GDPR apply to you:

1. Right to Access: You have the right to request for copies of your personal information
2. Right to Rectification: You have the right to request that we correct any information you believe is inaccurate
3. Right to Erasure (right to be forgotten): You have the right to request that we erase your personal information, which may lead to deleting your account and ending your use of our Services
4. Right to Restriction of Processing: You have the right to request that we restrict the processing of your personal information under specific circumstances such as if you contest the accuracy of the data or object to its processing
5. Right to Withdraw Consent: You have the right to withdraw your consent, which may lead to deleting your account and ending your use of our Services
6. Right to Data Portability: You have the right to request we transfer your personal information to another organization or to you
7. Right to Object: You have the right to object to the processing of your personal data in certain circumstances
8. Right to Submit a Complaint to a Supervisory Authority:Should you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you may contact the Information Commissioner’s Office (https://ico.org.uk/for-the-public/)

To exercise your rights, please contact our Privacy Department (see Contact Information below).

Changes to Our Privacy Policy

We will post any updates to our Privacy Policy on our app and this page, along with a notice on our app and this page indicating the Policy has been updated. For significant or material changes affecting how we handle your personal information, we will notify you via email sent to the address associated with your account or through a notice on our app and this page. The date of the most recent revision is displayed at the top of this page. It is your responsibility to ensure we have a current, active, and deliverable email address on file and to periodically review this page for any updates.

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at:

Min Byungjoon & Kwon Youngjune
Positions: Co-Representatives
hello@devutai.com
+82-2-2088-5766

Lee Jaeyoung
Privacy Department/Client Team Lead
hello@devutai.com
+82-2-2088-5766