Privacy Policy

Last Updated: November 29, 2025

1. IN GENERAL

We, the team of Middleware Inc. process your personal data when you use our app ("LounZI," "us," "we," "our" or "app") or website ("Website" and, together with the app, "Products"). The processing of your personal data takes place in compliance with the General Data Protection Regulation ("GDPR") and the South Korean Personal Information Protection Act (PIPA) in its current form.

In this privacy policy ("Privacy Policy") we want to provide you with information about us, the nature, scope and purposes of the data collection and use, giving you insights into the processing of your personal data.

2. CONTROLLER

Controller. The controller of data processing is Middleware Inc. You can contact us via e-mail under the address provided in Section 9.

Data Protection Officer. Our data protection officer can be contacted under the e-mail address provided in Section 9. Should you have any questions regarding the processing of your personal data, please do not hesitate to contact him/her.

3. COLLECT AND PROCESS

This Privacy Policy applies to websites, apps, and other services operated by us. We process personal data that you as a user of the Products make available to us, for example by using our Products, and that users provide to us ("Data").

We can’t help you develop meaningful connections and location-based interactions without some data about you. We also collect information generated as you use our services, for example access logs, as well as information from third parties. If you want additional info, we go into more detail below.

Data you give us

You choose to provide us with certain information when using our services. This includes:

• Registration Information (Mandatory): You have to provide us with certain information to register with us: E-mail address, gender, and nickname.
• Optional Information: Certain information is optional during registration and can also be added or deleted later on by you, such as profile pictures. You may allow us to access your camera or photo album to share moments in the Cells.
• User Content: We process your chats with other users as well as the content you publish (text, images) in the Cells, as part of the operation of the services.
• Customer Support: If you contact our customer care team, we collect the information you give us during the interaction. We may monitor or record these interactions to ensure a high quality of service.

Data from others

In addition to the information you provide us directly, we receive information about you from others, including:

• Registration via Social Media: You may be able to use your social media login (such as Google or Apple Login) to create and log into your account. We will receive your basic profile information as permitted by the provider.
• Other Users: Other users may provide information about you as they use our services. For instance, we may collect information about you from other users if they contact us about you.

Data collected when you use our services

When you use our services, we collect information about which features you’ve used, how you’ve used them, and the devices you use to access our services:

• Usage Information: We collect information about your activity on our services, for instance how you use them (e.g., date and time you logged in, Cells you entered, features you’ve been using) and how you interact with other users.
• Device information: We collect information from and about the device(s) you use to access our services, including: hardware and software information such as IP address, device ID (UUID), device-specific settings, app crashes, browser type, version and language, operating system, time zones, and identifiers associated with cookies.
• Location Information (Crucial): If you give us permission, we collect your precise geolocation (latitude and longitude) through GPS, Bluetooth, or Wi-Fi connections. This is essential for LounZI to verify which "Cell" (location-based chat room) you are in. If you decline permission, you may not be able to enter specific Cells.

Cookies

The website uses 'cookies' – small text files that are placed on your computer, mobile device and/or stored by the browser. The basis for the processing of Data via cookies are our legitimate interests. We use and may allow others to use cookies and similar technologies to recognize you and/or your device(s).

4. PURPOSE

We use your data to deliver our services and help keep you safe.

Operating the Products

• Create and manage your account
• Provide you with customer support and respond to your requests
• Communicate with you about our services
• Connect with other users: Verify your location to allow entry into specific Cells and enable real-time communication with others in the same area.

Business Needs

• Performance: Monitor, analyse and improve the use of our Products, as well as protect the security or integrity of the Products.
• Research and Development: Conduct research for further development in order to develop new features and provide you with a better, more intuitive experience.

Marketing General

• Push Message Marketing: With your explicit consent, we will send you service-related or marketing push messages.
• Notice Regarding Commercial Email: Members consent to receive commercial email messages from the company.

Compliance and Enforcement

• Address ongoing or alleged misbehavior on and off-platform.
• Comply with our obligations and in compliance with all applicable laws and regulations.

5. SHARING OF PERSONAL DATA

With other users

You share information with other users when you voluntarily disclose information on the service (including your public profile and chat messages). Please be careful with your information and make sure that the content you share is stuff that you’re comfortable being publicly viewable.

With our service providers and partners

We share your information to others who help us provide and improve our Products. Service providers will have access to your information as reasonably necessary to perform these tasks on our behalf.

We use processors such as Cloudflare, Google (Firebase, Maps), and OpenAI.

For corporate transactions

We may transfer your data if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.

When required by law

We may disclose your data if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime; or (iii) to protect the safety of any person.

6. HOW LONG WE STORE DATA

Storage Period. We store your Data as long as you are a registered user of the Products. Beyond that, we only store Data if it is legally necessary (because of warranty, limitation or retention periods) or otherwise required.

Location Data. Real-time location data used for Cell verification is processed instantly and is not permanently stored as a movement history log, to protect your privacy.

Account Deletion. If you decide to delete your account, all Data we have about you will be deleted, with the exception of data required for compliance with statutory retention obligations (e.g., login logs for 3 months under Korean law).

7. WHICH RIGHTS YOU HAVE

We want you to be in control of your information, so we have provided you with the following tools:

• Access / Update tools in the service: Tools and account settings that help you to access, rectify or delete information that you provided to us.
• Device permissions: You can change your settings on your device to either consent or oppose the collection of location information or notifications. Of course, if you do that, certain services (like entering a Cell) may lose functionality.
• Deletion: You can delete your account by using the corresponding functionality directly on the service.

Reviewing your information. Applicable privacy laws may give you the right to review the personal information we keep about you. If you want to request a copy of your personal information, please contact our customer care team.

Uninstall. You can stop all information collection by an app by uninstalling it using the standard uninstall process for your device.

Accountability. You have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information.

8. FURTHER IMPORTANT INFORMATION

We work hard to protect you from unauthorized access to or alteration, disclosure or destruction of your personal information. As with all technology companies, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information will always remain secure.

We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security.

9. HOW TO CONTACT US

If you have any questions about this Privacy Policy, please contact us at the email above.

10. PRIVACY POLICY CHANGES

Because we’re always looking for new and innovative ways to help you build meaningful connections, this policy may change over time. We will notify you before any material changes take effect so that you have time to review the changes.