SudaCall Location-Based Service Terms

Established 2026-09-29 · Revised 2026-10-10 · Effective 2026-10-10 · Previous version (effective 2026-10-01) · What changed

This English text is provided for convenience. The Korean version is the governing text; if the two differ, the Korean Location-Based Service Terms prevail.

Article 1 (Purpose)

These Terms set out the rights, obligations, and responsibilities of CreamHouse Co., Ltd. ("the Company") and the person whose location information is processed ("you") when you use SudaCall's location-based service ("location features"), and other matters needed for that use.

Article 2 (Other rules)

Matters not covered by these Terms are governed by relevant Korean law, including the Act on the Protection, Use, etc. of Location Information (the "Location Information Act"), the Personal Information Protection Act, the Act on Promotion of Information and Communications Network Utilization and Information Protection, and the Telecommunications Business Act, and by the SudaCall Terms of Service and Privacy Policy.

Article 3 (What the service does)

1. Using your location at the moment you ask during a call, the Company provides the following.

   Service	What it does	Consent needed
   Saving a place	If you ask during a call to save where you are, we use your location at that moment to find the nearest shop or place and add it to "Saved places" under the name you give it, with any short note you add, its place identifier, and your location at that moment. You can see and delete the list in the app	Article 5(1)
   Information based on your current location during conversation	When a user who has consented to location use asks during a conversation about weather, fine dust, nearby places, or directions, we provide information based on their current location (weather, fine dust, nearby places, public transit start points, and similar information). If you name a place or start point, we use that place	Article 5(1)
   Finding places nearby	We find restaurants, cafés, and similar places near your location at that moment and tell you during the call	Article 5(1)
   Weather where you are	If you ask during a call about the weather where you are ("what's the weather like here?"), we use your location at that moment to find the name of your neighbourhood (district and city) and look up the weather there. The weather search uses only that place name, never your coordinates	Article 5(1) (consent under the revision of 1 October 2026)
   Start point for transit directions	If you ask during a call how to get somewhere by public transport and do not say where you are starting from, we use your location at that moment as the start point to find bus and subway routes. If you tell us the start point, we do not use your location	Article 5(1) (consent under the revision of 1 October 2026)
   Sending your current location to your care contact (parent mode)	When you ask, we send your location at that moment to your linked care contact	Article 5(1) and (2)

2. We check your location only once, at the moment you ask, during a call while the app is on screen. We do not check it while the app is in the background, and we never track you.
3. Location features use the location your device's operating system provides (GPS, Wi-Fi, cell towers, and the like). It may be inaccurate depending on your device and surroundings.

Article 4 (Charges)

Location features are free. Because they are used during a call, call time is counted in Suda under Article 4 of the SudaCall Terms of Service, and data charges follow your mobile carrier's plan.

Article 5 (Consent to collection, use, and provision of personal location information)

1. The Company provides saving places, finding places nearby, weather where you are, and the start point for transit directions only to users who agree to these Terms and consent to the collection and use of personal location information. Weather where you are and the start point for transit directions are provided only to users who give new consent covering those purposes under the revision of 1 October 2026; consent given before then remains valid for the existing services (saving places and finding places nearby).
2. Sending your current location to your care contact is provided only if, in addition to (1), you separately consent to provision of personal location information to your care contact and a check-in link is on. This consent is optional.
3. The consents in (1) and (2) are obtained separately from your agreement to the Privacy Policy. Without them, the SudaCall call service works as usual.
4. You must give consent yourself. No one else may consent on your behalf.

Article 6 (Use, retention, and destruction of personal location information)

1. Coordinates (latitude and longitude) used to find places nearby, for weather where you are, as the start point for transit directions, or to send your current location to your care contact are destroyed straight away and never stored. If you ask to save a place, its coordinates are kept with the saved place under (2).
2. For saved places, the name you give, the place identifier (Google place ID), your device's coordinates when you saved it, any short note you add, and when you saved it are kept until you delete them in the app, withdraw consent, or delete your account. The place name and address from Google Maps Platform are deleted within 30 days and fetched again with the place identifier when shown to you. The coordinates kept with a saved place are used only to reopen that place in a map or navigation app on your device when it has no place identifier (for example, where you parked), and are never sent to conversation-generation providers.
3. Under the Location Information Act, the Company automatically keeps records of the use and provision of location information (who, when, for what purpose, and to whom), without the coordinates. The purpose is recorded as one of: saving a place, finding places nearby, weather where you are, start point for transit directions, or sending your location to your care contact, and you can see it under that name in the app's location settings. The records are kept for at least 6 months (200 days at the Company) and then destroyed.
4. If you withdraw all or part of your consent or ask to delete your account, the Company destroys saved places and the records without delay (only the part withdrawn, if you withdraw part of it). This is not delayed by the account-deletion hold. Database copies made automatically for disaster recovery may still hold the destroyed information for up to 14 days, after which they are deleted automatically; these copies are never used for anything other than recovery.
5. Place names said during a call are part of the call transcript, kept for 6 months, and deleted when you delete that call record. The personal location information destroyed when you withdraw consent is your saved places and the records.

Article 7 (Provision to others, and notice)

1. Only if you have given the consent in Article 5(2), each time you ask during a call, the Company sends your location at that moment to your linked care contact.
   • Recipient: your linked care contact
   • Purpose: telling them your location because you asked
   • How: a SudaCall app notification to your care contact, or email if they cannot receive one
2. Each time the Company provides personal location information to someone else, it tells you immediately who received it, when, and why, in these ways:
   • the character tells you during the call;
   • a notification appears on your phone (shown by the app itself, and on Android also sent from our server);
   • you can see it any time in the records in the app's location settings.
3. You may ask to receive the notice in (2) on another device or at an email address.
4. The Company cannot delete a location already delivered to your care contact.
5. Other than under (1), the Company does not provide personal location information to anyone without your consent, except where a law specifically provides for it.

Article 8 (Entrusted processing and overseas transfer)

To provide location features, the Company entrusts processing of, or transfers overseas, personal location information as follows.

• Time and method: sent over encrypted communication (TLS) when you use a location feature.
• How to refuse: if you do not consent, or withdraw consent, nothing is sent, and the call service works as usual.

Article 9 (Your rights)

1. You may withdraw all or part of the consents in Article 5 at any time.
2. You may at any time ask the Company to pause the collection, use, or provision of your personal location information. The Company will not refuse and keeps the technical means to do so.
3. You may ask the Company to show you, or tell you about, the following, and ask it to correct any error:
   • records of the use and provision of your location information
   • the reason for, and content of, any provision of your personal location information to others
4. In the app's location settings you can delete saved places, see the records, withdraw consent, or pause location features. You can also ask at the contact details in Article 12. Turning off your device's location permission also stops location features.

Article 10 (Rights of legal representatives)

People under 14 may not sign up for SudaCall, so the Company does not collect, use, or provide personal location information of children under 14 and has no procedure for a legal representative's consent. If the Company learns that personal location information of someone under 14 has been processed, it destroys it without delay.

Article 11 (Guardians of children aged 8 or under and others)

The Company does not provide any service in which a guardian consents on behalf of a child aged 8 or under, a person under adult guardianship, or a person with a severe disability to have their personal location information processed.

Article 12 (Location information manager)

The Company has a location information manager to protect personal location information and handle related complaints.

• Location information manager: Lee Heekyu (Head of Strategic Planning, Strategic Planning Office)
• Contact: sudacall@creamhouse.net · +82-2-508-2712

Article 13 (Compensation)

1. If you suffer loss because the Company breached Articles 15 to 26 of the Location Information Act, you may claim compensation from the Company. The Company is not released from liability unless it proves it acted without intent or negligence.
2. If the Company suffers loss because you breached these Terms, it may claim compensation from you.

Article 14 (Disclaimer)

1. The Company is not liable for loss where it cannot provide location features for the following reasons, except where the Company acted with intent or negligence:
   • natural disaster or other force majeure
   • reasons attributable to you, such as turning off your device's location permission or pausing location features
   • location measurement error on the device, communication failure, or an outage at an outside provider (such as a map service)
   • deliberate interference with the service by a third party
2. Sending your current location to your care contact is not an emergency service, and there is no guarantee your care contact will see it straight away. In an emergency, contact your local emergency number (such as 911 in the United States, or 119 or 112 in Korea) directly.
3. Information about nearby places (opening hours, addresses, and so on), weather, and public transit routes and travel times comes from outside services, and the Company does not guarantee its accuracy. Transit times may differ from actual service.

Article 15 (Dispute resolution)

1. The Company handles your opinions and complaints about location information promptly.
2. Where a dispute about location information cannot be settled by agreement between the parties, either party may apply for a ruling to the Korea Media and Communications Commission under the Location Information Act, or for mediation to the Personal Information Dispute Mediation Committee under the Personal Information Protection Act.
3. Advice and reports (Korea): Personal Information Dispute Mediation Committee (kopico.go.kr, 1833-6972), Privacy Infringement Report Centre (privacy.kisa.or.kr, 118), Supreme Prosecutors' Office Cyber Investigation (1301), Korean National Police Agency Cyber Bureau (182).
4. These Terms are governed by the laws of the Republic of Korea, and lawsuits are brought before the court having jurisdiction under the Korean Civil Procedure Act.

Article 16 (Changes to these Terms)

1. If the Company changes these Terms, it announces the change in the app and on its website 7 days before it takes effect (30 days before, for changes unfavourable to you).
2. If the recipient of personal location information or the purpose of its use or provision changes, the Company asks for your consent again.

Article 17 (Business information)

• Company: CreamHouse Co., Ltd.
• Representative: Choi Woojin
• Address: 19 Yangpyeong-ro 21ga-gil, Rooms 208–209, Yeongdeungpo-gu, Seoul, Republic of Korea
• Contact: +82-2-508-2712 · sudacall@creamhouse.net
• Business registration number: 220-86-89511

Addendum

Addendum (29 September 2026) These Terms take effect on 29 September 2026.

Addendum (1 October 2026) (1) This revision takes effect on 1 October 2026, the day it was announced. (2) Weather where you are and the start point for transit directions under Article 3(1) are provided only to users who consent anew under this revision (Article 5(1), Article 16(2)); consent given before it remains valid for the existing services (saving places, finding places nearby, and sending your current location to your care contact). The previous version is here.

Addendum (10 October 2026) This revision takes effect on 10 October 2026. Article 3 now states the purpose of providing information based on your current location during conversation (weather, fine dust, nearby places, public transit start points, and similar information). The previous version is the version effective 1 October 2026.

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