This Privacy Policy governs Archivy, a personal organization service by FourBrains. It applies to Archivy web, iOS, and Android applications (the “Service”). It addresses data practices in compliance with applicable global laws: EU GDPR, CA CCPA/CPRA, KR PIPA and others .

2. Personal Data We Collect

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Email Address: Collected for OTP-based login, account access, notifications, and subscription management.

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Location Data: Processed on-device only for personalized experiences; not transmitted to or stored on our servers.

No additional personal or sensitive categories are collected or stored.

3. Legal Basis & Purpose of Processing

Purpose	Legal Basis (GDPR Art. 6)
Authentication & Account Access	Consent / Contractual Necessity
Location-Based Features & Recommendations	Legitimate Interest
Email Marketing & Retargeting (Opt-In Only)	Explicit Consent
Service Analytics (Crashlytics, Google Analytics)	Legitimate Interest

Purposes include user verification, personalized service delivery, subscription billing, marketing (if opted in), and crash/usage analytics.

4. Data Retention

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User data, including email, is deleted immediately upon account termination.

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Anonymized backups may persist up to seven (7) days before secure deletion.

5. Third-Party Processing & International Transfers

Service	Function	Data Shared	Region
Supabase (Seoul Region)	Storage & Authentication	Email Address	South Korea
Google Places API	Location information service	None	Global
Google Vision API	Image/Text metadata extraction	None	Global
Google Gemini API	AI-based content summarization	None	Global

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No full Instagram content or private data is collected or stored.

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For EU-based users, international transfers comply with GDPR’s Standard Contractual Clauses (SCCs) .

6. Instagram Compliance & Content Handling

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Archivy uses only user-submitted Instagram post links; it does not store, cache, copy, or reproduce original media or text.

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Only metadata—such as place names, keywords, and brands—extracted via Google Gemini API or on-device processing is used.

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Every displayed item always hyperlinks back to the original Instagram post, ensuring content attribution and honoring copyright.

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Archivy does not scrape Instagram in violation of its Terms of Service, and does not store protected content—thus minimizing legal risk under policies prohibiting automated scraping and content storage .

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If copyright infringement is alleged, Archivy will promptly remove all associated metadata and links.

7. Your Rights & How to Exercise Them

Under GDPR, CCPA, and PIPA, users may:

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Access, amend, correct, or delete personal data.

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Object to or restrict our processing.

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Withdraw consent at any time.

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Under CCPA: opt-out of “sale” or sharing of personal information.

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Request data portability.

Exercise such rights by emailing minjae‑[email protected] or via unsubscribe links in marketing emails.

8. Children’s Privacy

Our Service is intended for users aged 13 and above. We do not knowingly collect data from younger children. Guardians may request data deletion if their minor’s personal data was collected in error.

9. Security Measures

We implement robust safeguards including:

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SSL/TLS encryption for data in transit.

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Access control and encryption via Supabase.

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Anonymization and encryption for crash analytics.

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Secure, time-limited backups.

10. Cookies & Tracking

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Archivy does not currently use cookies or web trackers.

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If retargeting technologies such as Meta Pixel or Google Ads are introduced, we will obtain opt-in consent and provide clear opt-out mechanisms .

11. Policy Updates

Changes to this Policy will be communicated at least 30 days prior via email and on our website/app. Continued use after updates constitutes agreement to the revised terms.

12. Contact & Legal Disclosures

For privacy-related matters:

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Company: FourBrains (Product: Archivy)

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Representative: Minjae Lee

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Email: [email protected]

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Address: 15 Jeongbalsan‑ro 166beon‑gil, Ilsandong‑gu, Goyang‑si, Gyeonggi‑do 10411, Republic of Korea

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Business Reg. No.: 213‑16‑75239