SudaCall Privacy Policy

Established 2026-08-10 · Last revised 2026-09-30 · Effective 2026-09-29

This is a previous version. From 1 October 2026 the current Privacy Policy applies (what changed).

This English text is provided for convenience. The Korean version is the governing text; if the two differ, the Korean Privacy Policy prevails.

The operator of SudaCall ("the Company") complies with Korea's Personal Information Protection Act and related laws, and processes users' personal data as set out below.

1. Personal data collected, and how

Category	Items	How collected
Account (Google)	Google account email, name, profile photo	On Google sign-in
Account (Kakao)	Kakao member number, Kakao account email, nickname (gender, birthday, and birth year are used only as sign-up defaults, and only where the user has separately consented)	On Kakao sign-in (items shown on the consent screen)
Account (Naver)	Naver user identifier, email, nickname, gender, birthday, birth year	On Naver sign-in (items shown on the consent screen)
Account (Apple)	Apple account identifier, email (a relay address created by Apple if you choose to hide your email), name (if you provide it)	On Sign in with Apple in the iPhone app
Profile	Nickname, date of birth, gender (optional), profile photo (optional), confirmation that you meet the minimum age (18 in the United States, 14 in Korea), whether parent mode is on (optional)	Age confirmation and parent mode at sign-up; the rest entered by the user when needed (profile settings, creator registration, and so on)
Calls	Call transcript (text), call summary, relationship data (how you are addressed, conversational context), call time and duration, age and gender you mention in a call (used for forms of address and conversational limits when your profile does not have them)	Generated while using the Service
Requests during a call (only when you ask)	The type and time (including repeats) of scheduled calls (wake-up call, medication call, and so on) — never medicine names or other health information, the search terms and the song found when you ask for a song, the name of a destination for directions, words you ask us to pass on to your family and confirm, the device state needed to carry out a request (whether notification and alarm permissions are granted, whether a navigation or messaging app is installed), and a record of which features we suggested or explained	Generated when you make a request during a call
Sleep mode (only if you turn it on)	Your sleep-mode preferences such as sound (including a chosen song), volume, play time, whether you use YouTube Premium, and whether to keep the sleep screen on; when you used sleep mode and how often it was suggested, accepted, or declined; and the length of the part of a call in which you appeared to be asleep	Generated while you use sleep mode
Location (only with your separate consent to the collection and use of personal location information)	Your device's location (latitude and longitude) at the moment you ask during a call — used once for what you asked and not kept, except that if you ask us to save the place, those coordinates are kept with the saved place; for places you save, the name you give them, the place identifier (Google place ID), your device's coordinates when you saved it, an optional short note you add, and when you saved them (the place name and address Google returns are deleted within 30 days and fetched again when needed); what you consented to and when; and records of the use and provision of location information (who, when, for what purpose, and to whom — never the coordinates)	Collected from your device's location services when you ask during a call; the records are kept automatically
Voice	Recordings submitted when registering a voice or as a creator, and the consent-statement recording	Recorded or uploaded by the user
Payment	Subscription product, payment date and amount (app marketplace order information)	At payment
Settlement (creators)	Payout account details, identity verification data	Entered by the user
Marketing	Whether marketing consent was given (optional)	Optional consent at sign-up
Events and rewards	Invite code and who invited whom, whether the app was installed from an invite link, reward records, and (when an event runs) prize-draw entries, winners, and gift codes issued	When you install from an invite link or enter a code, and while an event runs
Collected automatically	Device information, app version, access logs, error logs, service usage records (which screens you open in the app and how long you stay, whether microphone permission was granted, whether you played a voice sample, and which in-call request features were used and whether they worked — never conversation content, anything you type, recipients, song titles, destinations, or location), a device token for notifications, an app installation identifier	Collected automatically during use
Check-in	(only if you turn it on) mood, and whether meals, sleep, going out and medication came up, plus topic tags, and how many times sleep mode was used	Derived from call transcripts and sleep-mode usage records
Check-in link (care contact)	The label, email address, and emergency text number (optional, Korea only) that the care contact enters	Entered by the care contact when creating the link

Remembered recipients for texts and calls (on your device only) — When you ask during a call, for example "text my mom", the one phone number you pick yourself on your phone's contact picker is saved only on your device, together with the name you used (for example "mom"). It is never sent to our servers or to AI processing servers, and is used only to fill in the recipient the next time you ask for the same person. SudaCall does not read your whole contact list (it does not use the contacts permission). You can delete them one by one or all at once in Settings > Remembered recipients, and they are also deleted when you sign out or uninstall the app. (Added 2026-09-30)

Information received through social sign-in is used only to identify the member and to prefill the sign-up screen. If you sign in with a different social provider using an email that already has an account, we link it to the existing account rather than creating a new one, so your call history and subscription carry over. We keep a link record showing which provider account belongs to which member; it is deleted when you delete your account.

If you disconnect SudaCall in your Kakao account settings, Kakao notifies the Company. If that account was created with Kakao only, we delete all information, the same as account deletion. If the account can also sign in with Google or Naver, we delete only the Kakao link record and keep the account.

Call audio itself is not stored. Voice during a call is used only for real-time recognition and synthesis; what is stored is the text transcript and the summary.

For requests during a call, SudaCall only opens the screen on your phone. For message, KakaoTalk, and email drafts, placing a call, adding a calendar event, and directions, we open the relevant app screen on your device, and you send, call, or save yourself. For directions we pass the place name you said to your map app, and SudaCall does not use your device's location for this. Alarms and timers are set in your device's clock app (on iPhone, as a SudaCall notification). The content of a draft or event is created from the conversation and passed to that screen on your device. The contact you pick (name and phone number) and anything stored in your device's contacts or calendar is used only on your device and is never sent to our servers.

Songs play in the official YouTube player on the call screen. When you ask, we either play a short part of a song or play it quietly in the background while the conversation goes on; if you want the whole song, we ask you first, end the call, and open it in the YouTube app on your phone (or on the web if the app is not installed). Section 3 covers the player.

Sleep mode does not decide you are asleep by listening. We do not analyse breathing, snoring, or other sounds; we judge only by how long you have not spoken. Call audio is not stored in sleep mode either. Short words heard after you seem to have fallen asleep (what looks like sleep talk) get no reply, and although they stay in the transcript with a marker, they are not used in call summaries, relationship memory, or check-in reports. If check-in reports are on, your care contact is told only how many times you used sleep mode (section 4-1). You choose the sleep-mode sound. A song you choose plays quietly in the official YouTube player on the call screen during the call; once you fall asleep and the call ends, it keeps playing on the app's sleep screen (dimmed to the lowest brightness, with the player still visible) until the time you set (section 3). If you tell us you use YouTube Premium, we hand the song to the YouTube Music app on your phone after the call, and that app plays it. If you do not use YouTube Premium and want to sleep with the screen off, we play royalty-free audio downloaded from our server (public-domain or CC0 piano pieces and the like) and sounds the app generates (such as noise), and no information is sent to an outside service to play them. We do not use sleep-mode records to judge your sleep or your health.

We check your location only if you have consented separately, and only at the moment you ask during a call. We check it once, only while the app is on screen during a call; we never check it while the app is in the background, and we never track you. Section 4-2 and the Location-Based Service Terms set out the details.

1-1. App permissions

Under Article 22-2 of Korea's Network Act, the Company tells you which device permissions the Service uses, grouped as below. Optional permissions are requested through your device's permission prompt the first time you use the feature that needs them. For location, we also ask for your consent to the collection and use of personal location information, separately from the device permission (section 4-2).

Type	Permission (device)	Used for	If you do not allow it
Required	Microphone	Voice calls with your AI friend	You cannot make calls
Optional	Notifications	Incoming calls, scheduled calls (including wake-up and medication calls), after-call messages, announcements	Scheduled and incoming calls and notifications do not arrive (calls you place still work)
Optional	Alarms & reminders (exact alarms, Android)	Ringing scheduled calls at the time you set	Calls may ring a few minutes late; a wake-up call you set by voice is set as a clock-app alarm instead
Optional	Full-screen notifications (Android 14+)	Showing the call screen over the lock screen	Calls ring as a notification banner only
Optional	Display over other apps (Android)	Showing the incoming call screen while you use another app	You tap the notification to open the call screen
Optional	Nearby devices (Bluetooth, Android 12+)	Calls through Bluetooth earphones or headsets	Calls use the phone speaker, earpiece, or wired earphones
Optional	Camera	Taking a profile photo	Choose from your gallery or use a default avatar
Optional	Photos (iPhone photo library)	Choosing a profile photo	Take a photo or use a default avatar
Optional	Location (only while using the app)	Once, at the moment you ask during a call — saving a place, finding places nearby, and (with separate consent) sending your current location to your care contact. Background location is never used	Location features are unavailable (say a place name and we will look it up by name). With approximate location only, the nearest place may be wrong
Optional	Contacts (where the feature is offered)	Finding a number by name when you ask to call or text someone during a call — on your device only	You pick the contact in the contact picker
Automatic	Internet, vibration, keeping the screen on (during calls and on the sleep-mode sleep screen), audio settings (speaker switching, call volume), restoring scheduled calls after a reboot, foreground service (Android — keeps the microphone during a call, plays sleep-mode sounds after the call with the screen off), background audio (iPhone — keeps the call going, plays sleep-mode sounds), set alarm (Android — sets alarms and timers in the clock app)	Running the Service	Normal permissions the operating system grants at install; they do not access information stored on your device

You can use the Service without allowing optional permissions; only the related feature is limited. You can change them at any time — Android: Settings > Apps > SudaCall > Permissions / iPhone: Settings > SudaCall. You can also check their status in the SudaCall app under Settings > App permissions.

Adding a calendar event does not use any calendar permission. We open your calendar app without one (on Android, its add-event screen; on iPhone, we copy the event details and open the calendar app). We never read what is stored in your device's calendar.

2. Purposes of processing

Identifying members, sign-up and sign-in, and checking the under-14 restriction
Providing the AI call service (generating conversation, call records and summaries, maintaining continuity between calls)
Reflecting conversational context for call quality — the gender and age range in your profile are used as context so the AI can choose natural forms of address, speech style, and topics
Carrying out phone actions you ask for during a call (scheduling calls, alarms and timers, playing songs during the call and opening the whole song in your YouTube app after it, opening directions, message drafts, calls, and calendar screens, and passing words on to your family)
Providing sleep mode (remembering your sound preferences, limiting how often it is suggested, leaving the part of a call after you fall asleep out of your usage (Suda), and, if check-in reports are on, telling your care contact how many times you used it)
(With consent to the collection and use of personal location information) saving a place and finding places nearby using your location at the moment you ask during a call, and (with separate consent to provision to your care contact) sending your current location to your care contact
Handling subscriptions, payments, and refunds, and managing usage (Suda)
Creator registration, review, and settlement, and verifying that a voice is the creator's own
Improving service quality (including analysing how the app is used), diagnosing errors, and safety checks (responding to prohibited content)
Preventing abuse — a minimal record that stops people from deleting and re-creating accounts to collect the free allowance and sign-up perks again (section 5)
(Optional) Sending promotional information such as events and offers to users who consented to marketing — you can withdraw consent at any time in Edit profile in the app, and refusing has no effect on your use of the Service
Meeting legal obligations and handling disputes

3. Processing entrusted to others, and overseas transfer

To the extent needed to provide the Service, processing is entrusted to the companies below and mostly takes place overseas (United States, China). The information transferred is the minimum needed to provide the Service (voice stream, conversation text, account identifiers, and location coordinates if you have consented).

Processor	Entrusted work	Country
Google (Firebase/Cloud)	Authentication, data storage, server operation, sending notifications (push) and email	United States and others
LiveKit	Real-time voice call connection	United States
Deepgram	Speech recognition (speech → text)	United States
Cartesia	Speech synthesis (text → speech), voice model creation	United States
OpenAI	Conversation generation (AI model)	United States
Anthropic	Conversation generation (AI model)	United States
Google (Gemini)	Conversation generation, summarisation, search (AI model)	United States
DeepSeek	Conversation generation (AI model)	China
Fireworks AI	Conversation generation (AI model hosting)	United States
Inworld AI	Speech recognition and synthesis (basic character voices)	United States
Fish Audio	Speech synthesis (pro voices)	United States and other countries *
ElevenLabs	Speech synthesis (some legacy features)	United States
Kakao · NAVER	Social sign-in (member identification)	Republic of Korea
NAVER Cloud	In-call search and finding places (search terms, place names), emergency check-in text messages	Republic of Korea
Google (YouTube API Services, Google Maps Platform)	Song and video search (including search during calls) and song playback on the call screen and sleep screen, finding places (search terms, place names), and finding the nearest place's name and address and places nearby from location coordinates (with consent)	United States

The Company applies each provider's opt-out from training where their API data policy offers it, and reviews those policies periodically because they can change.

* Fish Audio states in its privacy policy that it is a US (Delaware) business but does not disclose data centre locations, and says processing may occur in other countries through group companies and subprocessors. The Company is confirming the processing country with that provider and will update this table once confirmed.

YouTube (Google): SudaCall uses YouTube API Services for song and video search (including search during calls) and for playing songs on the call screen. For search we send only the search terms — never your account details — and we do not access your YouTube or Google account. Songs during a call (a short part of a song, or music playing in the background while you talk) and sleep-mode songs play in the official YouTube player, which is provided directly by Google. While the player is open, Google may collect device information and playback information, may store or read cookies or similar technologies on your device, and may show advertisements in videos. That information is governed by the Google Privacy Policy, and your use of YouTube is governed by the YouTube Terms of Service. We do not receive the information Google collects; we use only the player's state (playing, paused, ended) to run the call. Playback stops when the app leaves the screen or the call ends. The exception is sleep mode: if you fall asleep and the call ends, playback continues on the app's sleep screen (dimmed to the lowest brightness, with the player still visible) until the time you set, and it still stops if the app leaves the screen. A whole song opens in the YouTube app on your phone after the call (or on the web if the app is not installed), and if you use YouTube Premium and ask for it in sleep mode, we hand the song to the YouTube Music app after the call and that app plays it. Your use of the YouTube and YouTube Music apps is governed by the YouTube Terms of Service and the Google Privacy Policy.

3-1. Overseas transfer of personal data

To provide the AI call service, the Company transfers personal data overseas as set out below. Every processor in the table in section 3 other than the Korean companies (Kakao, NAVER, NAVER Cloud) is an overseas transfer. The recipient and country differ by the type of information.

Type	Recipient (country)	Details
Conversation content (text) — full utterances and relationship records (nickname, form of address, age range, gender, interests, and other conversational context), and the names and addresses of places saved or found during a call, and notes you add to them	OpenAI (US) — default response generation / DeepSeek (China) · Fireworks AI (US) — fallback path on latency or outage	Sent in real time during a call so the AI can compose a reply. The default path is the United States; if a fallback path is used during an outage or latency spike, data may be sent to servers located in China.
Voice — the user's voice (speech recognition), character voice synthesis and cloning, call connection	Inworld AI · Deepgram · Cartesia · LiveKit (all US), Fish Audio (pro voices)	Real-time recognition, synthesis, and call connection take place in the United States. Pro voices created by creators are synthesised through Fish Audio and sent to that provider's overseas servers (see the footnote to the table in section 3).
Additional processing — call summaries and relationship memory, quality assessment, content review, news briefings	OpenAI · Google (both US)	Conversation text is summarised and analysed after the call ends.
Search terms — song and video search terms (including search during calls), place names	Google (US) — YouTube API Services, Google Maps Platform	Only the search term is sent, when you ask or when the conversation needs a search. Account details are never sent with it. Place search in Korea uses NAVER Cloud (Republic of Korea).
Location — your device's coordinates at the moment you ask during a call (with consent to personal location information)	Google (US) — Google Maps Platform	Sent once, at that moment, to find the nearest place's name and address and places nearby. Account details are never sent with it, and the Company does not keep the coordinates sent to Google (they are kept only with a saved place, if you asked to save it — section 4-2). Without consent nothing is sent, and the call service works as usual.

Item	Details
Time and method of transfer	Sent via API over encrypted communication (TLS) at the time of use, such as during a call
Retention and use period	Per each provider's API data policy (the Company applies each provider's opt-out from training and reviews policy changes periodically)
How to refuse	If you do not want overseas transfer, you can refuse by stopping use of the Service or deleting your account
Effect of refusal	Because AI conversation is generated through overseas providers, refusing transfer means the call service cannot be used

4. Protection of call content

Call content (transcripts, summaries, relationship data) is visible only to you and is not disclosed to other users, including creators. The Company accesses call records only to the minimum extent needed to improve service quality and verify safety, under internal controls, and cooperates with state authorities only upon a lawful official request, within the procedures and scope set by law.

4-1. Check-in reports (optional feature)

Only if you turn it on yourself, SudaCall sends a periodic check-in summary drawn from your calls to a person you choose (your "care contact"). If you do not turn it on, nothing is sent and nothing else about the service changes.

Who receives it: a person who invited you and whom you approved. Their name and contact are shown on the consent screen.
Why: so they know how you are doing, and to pass on words and your location when you ask us to.
What is sent (this is the complete list)
- Call figures: how many calls, who called whom, call length, whether calls were answered (if there were noticeably fewer calls than usual this week, the report says so in one line)
- Mood: a five-point scale and the trend across the week
- Daily living: whether meals, sleep, going out and medication came up, and the gist
- Topic tags: the three subjects that came up most that week (for example: grandchildren, doctor, weather)
- Things to look at: three scheduled calls in a row (such as wake-up or medication calls you chose to receive) going unanswered, or mentions that suggest something is off — random incoming calls and the welcome call are not counted
- Sleep mode: how many times you used sleep mode that week (never when you used it, what was said in sleep mode, or anything heard after you fell asleep)
- (each time you ask) Words you ask us to pass on: only words you asked, during a call, to have passed on to your care contact, and confirmed after they were read back to you — delivered as a SudaCall app notification to your care contact, or by email if they cannot receive notifications
- (each time you ask, with separate consent to provision to your care contact) Your current location — governed by section 4-2 and the Location-Based Service Terms
What is never sent: recordings, transcripts, full call summaries, or anything you said quoted back (except that words you asked us to pass on and confirmed are passed on, and only those words), and what was said in sleep mode or anything heard after you fell asleep. Your care contact cannot read your conversations (for sleep mode they see only how many times you used it, and for location only where you were when you asked us to send it).
How often: once a week (Monday morning, your local time). There are only three immediate alerts: (1) three scheduled calls in a row going unanswered, (2) mentions during a call that suggest a health problem, and (3) your current location, when you ask us to send it. We do not send an immediate alert just because there have been no calls for a few days; the weekly report shows this week's number of calls instead. Words you ask us to pass on go each time you ask.
How long it is kept: reports are deleted after 12 weeks, and if you turn the feature off, reports already stored are deleted at that moment. Words passed on are kept for 30 days from delivery and then deleted, and are deleted immediately if you turn the feature off or delete your account. We do not keep the location we send (section 4-2). We cannot delete what has already reached your care contact's notifications or mailbox.
Turning it off: from the check-in card in the app's settings, at any time. It stops immediately (passing on words and sending your location stop too), and your care contact is told only that it stopped - not why.
If you agreed before: if you agreed to check-in reports before these items were added, they apply to you too from the effective date. Words are passed on only each time you ask and confirm during a call; your current location is sent only if you have separately consented to provision to your care contact (consent (2) in section 4-2); and how many times you used sleep mode is included in the check-in report. If you do not want this, you can turn the feature off at any time (Turning it off).
You see what they see: every report sent to your care contact is sent to you as well. Words are passed on only after you confirm them during the call, and each time we send your current location we tell you immediately who received it, when, and why (during the call, by a notification on your phone, and in the app's location records — section 4-2).

These summaries are generated automatically by AI from call transcripts. They are not a medical diagnosis or assessment and must not be used as a basis for health decisions. SudaCall is not a healthcare provider and is not a HIPAA covered entity; this feature is not medical care.

4-2. Personal location information

The Company processes personal location information as a location-based service provider under Korea's Act on the Protection, Use, etc. of Location Information (the "Location Information Act"). The details are governed by the Location-Based Service Terms.

Consent: we process personal location information only with consent given separately from your agreement to this policy. There are two consents — (1) collection and use of personal location information (saving places, finding places nearby) and (2) provision to your care contact (sending your current location in parent mode; optional). You can give (2) only if you have given (1) and a check-in link is on. Without consent, the call service works as usual.
When we collect it: during a call, while the app is on screen, once at the moment you ask. We do not collect it while the app is in the background, and we never track you.
Items: your device's location (latitude and longitude) at the moment you ask; saved places (the name you give them, the place identifier (Google place ID), and when you saved them); your location consents; and records of the use and provision of location information (who, when, for what purpose, and to whom — never the coordinates).
Purposes: (1) saving the place you asked for to "Saved places", (2) finding places nearby (restaurants, cafés, and so on), and (3) (with consent (2)) sending your current location to your care contact.
Retention and destruction
- Coordinates: those used to find places nearby or to send to your care contact are destroyed straight away and never stored; if you ask us to save a place, its coordinates are kept with the saved place.
- Saved places: the name you give, the place identifier (Google place ID), your device's coordinates when you saved it, and any short note you add 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.
- Records: kept automatically under the Location Information Act for at least 6 months (200 days at the Company), then destroyed.
- Place names said during a call: part of the call transcript, kept for 6 months, and deleted when you delete that call record.
- If you withdraw consent or ask to delete your account, saved places and the records are destroyed without delay (only the part withdrawn, if you withdraw part of it). This is not delayed by the 7-day account-deletion hold.
Provision to others: only with consent (2), each time you ask during a call, we send your current location to your linked care contact (as a SudaCall app notification, or by email if they cannot receive one). Each time, we tell you immediately who received it, when, and why — 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), and you can see it any time in the records in the app's location settings. We cannot delete a location already delivered to your care contact. Otherwise we do not provide personal location information to anyone, except where a law specifically provides for it.
Entrusted processing and overseas transfer: coordinates are sent to Google (US, Google Maps Platform) to find nearby places. The names and addresses of places saved or found, and notes you add, are used in the conversation, so they also go to the conversation-generation providers (section 3-1). The coordinates themselves are not sent to conversation-generation providers; 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). Saved places and records are stored with Google (Firebase/Cloud).
Your rights: you may at any time withdraw all or part of your consent and ask us to pause collection, use, or provision. You may ask to see, or be told about, the records of the use and provision of your location information and the reason for and content of any provision to others, and ask us to correct errors. In the app's location settings you can delete saved places, see the records, withdraw consent, or pause location features. You can also ask us at the contact details below.
Under 14: people under 14 may not sign up, so we do not process personal location information on the consent of a legal representative.
Location information manager: section 9.

5. Retention and destruction

Call transcripts (including the original and device-synced copies) are kept for 6 months (180 days) from the end of the call and then deleted automatically. Call summaries and relationship memory are kept, to provide the Service, until you delete your account, and are destroyed immediately at that point.
When you ask to delete your account, deletion is on hold for 7 days. If you sign in again with the same account during that time, the request is cancelled and your account is restored as it was; while the request is on hold, use of the Service, notifications, and check-in reports stop. After 7 days the data is destroyed without delay (in a nightly job, at the latest on day 8). Creator voice models, recordings, and consent-statement recordings are not put on hold — they are deleted immediately when you make the request. Personal location information (location consents, saved places, and records of the use and provision of location information) is not put on hold either and is destroyed immediately when you make the request. The following is retained where the law requires it:
- Records of contracts, withdrawal of purchase, payment, and supply of goods: 5 years (Act on Consumer Protection in Electronic Commerce)
- Records of consumer complaints and dispute handling: 3 years (same Act)
- Access logs: 3 months (Protection of Communications Secrets Act)
Service usage records (screens opened in the app, time spent, and the like) are destroyed automatically 1 year after collection, and without delay when you delete your account.
Information from requests during a call: scheduled-call settings (type and time) and records of features we suggested or explained are kept until you delete them or delete your account. Song search terms and destinations are part of the call transcript and are kept for the same period (6 months). Words passed on to your family follow section 4-1 (30 days from delivery, deleted immediately if you turn the feature off or delete your account).
Sleep mode: your sound (including a chosen song), volume, play-time, YouTube Premium, and sleep-screen preferences and usage records (when you used it, and how often it was suggested, accepted, or declined) are kept until you delete them or delete your account. The length of the part of a call in which you appeared to be asleep is used only to leave that part out of your usage (Suda) and is deleted with the call record after 6 months. The sleep-mode count sent to your care contact is kept for 12 weeks, like other check-in reports.
Personal location information: coordinates used to find places nearby or to send to your care contact are destroyed as soon as they have been used and are never stored. Saved places (the name you give, the place identifier, the coordinates at the time of saving, and any note) are kept until you delete them, withdraw location consent, or delete your account (the place name and address from Google are deleted within 30 days); records of the use and provision of location information are kept for 200 days and then destroyed. Saved places and records are destroyed without delay if you withdraw consent or delete your account. Place names said during a call are kept with the call transcript for 6 months (section 4-2).
Minimal record to prevent abuse: to stop people from deleting and re-creating accounts to collect the free allowance and sign-up perks again, we keep only the following for 1 year from deletion, and then destroy it automatically.
- Items: a hash of your email address (the email itself is not kept — for a social sign-in account without an email, a hash of the member identifier), when you first signed up, how much free call time you used in the month of deletion, and a record of perks received (whether you used the welcome call, the dates you received "come back for 10 more minutes", whether an invite reward was paid, and whether you ever had a call longer than 2 minutes)
- Use: only to continue the free allowance from your first sign-up and to avoid giving the same perks again if you sign up again with the same account within 1 year. We do not use it to contact you or for any other purpose. After 1 year, signing up again is the same as signing up for the first time.
Check-in reports are deleted 12 weeks after they are generated. If you turn the feature off, reports already stored are deleted at that moment.
When a creator registration is removed, the voice model and recordings are deleted immediately (settlement records are kept for the statutory period).
The consent-statement recording (evidence of identity) is kept for 1 year after registration is removed, for dispute handling, and then destroyed.

6. Your rights

You may at any time request access to, correction of, deletion of, or suspension of processing of your personal data. You can do this yourself in the app under Settings (Account), or request it at the contact details below. You can delete call records directly in the app, and delete relationship data with "Reset memory". Your rights over personal location information (withdrawing consent, pausing, access, correction) are governed by section 4-2 and the Location-Based Service Terms.

7. Children

Age is checked at sign-up by confirming that you meet the minimum age, and also by date of birth if you enter one. If the user is below the minimum age, sign-up is refused and the information entered is not stored.

United States: you must be 18 or older to sign up. The Service is not directed to children, and we do not knowingly collect personal data from anyone under 13 (Children's Online Privacy Protection Act). If we learn that we have collected such data, we delete it. A parent or guardian who believes we hold data about their child may contact us at the address below and we will delete it.
Korea: people under the age of 14 may not sign up.

7-1. Voice data and biometric identifiers (United States)

This section applies to users and creators in the United States and is provided to meet state biometric privacy laws, including the Illinois Biometric Information Privacy Act (BIPA), the Texas Capture or Use of Biometric Identifier Act (CUBI), and Washington's biometric statute.

What we collect, and when. If you register as a creator we collect the voice recordings you submit — the sample readings, the consent statement you read aloud, and any additional takes — and we derive from them a synthetic voice model used to speak your avatar's lines. A voiceprint derived from a recording is a biometric identifier. We do not collect voiceprints from ordinary callers: call audio is not stored and is not used to build any voice model.
Consent before collection. We obtain your written consent before collecting or deriving any biometric identifier. In the app this is the consent-statement recording: you are told the purpose and the retention period, and you record a statement that includes a one-time confirmation code. You do not have to provide it; without it you simply cannot register as a creator.
Why. Only to create and operate the voice you chose to publish, to verify that the voice is your own, and to keep impersonation off the platform. We use it for nothing else.
We do not sell it. We do not sell, lease, trade, or otherwise profit from your biometric identifiers or biometric information, and we do not disclose them except (i) to the processors listed in section 3, acting on our instructions and bound to the same restrictions, solely to operate the Service, (ii) with your separate consent, or (iii) where required by a valid subpoena, warrant, or other legal process.
How long we keep it (retention schedule). Recordings and the derived voice model are kept while your creator registration is active. They are permanently destroyed within 30 days of the earliest of: you deleting the voice or your creator registration, you closing your account, or the purpose for collecting it being satisfied — and in any event no later than 3 years after your last interaction with us. Destruction covers the stored recordings, the derived model, and any backup copy, and is not delayed by the retention periods in section 5, which apply to other data.
How it is protected. Recordings and models are stored encrypted in access-controlled cloud storage, using at least the standard of care we apply to other confidential information, and access is limited to the smallest number of people who need it.
Your choices. You can delete a voice, or your whole creator registration, in the app at any time; that starts the destruction above. You can also ask us at the contact details below.

7-2. Your rights in the United States

Depending on your state (for example California under the CCPA/CPRA, and comparable laws in Colorado, Connecticut, Texas, Virginia and others) you may have the right to know what personal data we hold and why, to get a copy, to correct it, to delete it, and to limit the use of sensitive personal data.

We do not sell or share your personal data for money or for cross-context behavioural advertising, and we have not done so in the preceding 12 months. We do not use your data for targeted advertising, and we do not profile you in a way that produces legal or similarly significant effects.
The in-call YouTube player. When a song plays during a call or on the sleep screen, the player is provided by Google, which collects information under its own privacy policy (section 3). We do not receive that information and do not direct its use for advertising.
Sensitive personal data. Voice recordings and derived voice models are treated as sensitive personal data and are used only to provide the Service you asked for, as described in section 7-1.
Precise geolocation. Your location is treated as sensitive personal data. We use it only with your separate opt-in consent, only at the moment you ask during a call, and never in the background, as described in section 4-2. You can withdraw consent at any time.
How to exercise your rights. Use Settings (Account) in the app, or write to the contact address below. We do not charge for this and we do not treat you differently for asking. If we have to refuse a request we will tell you why, and you may appeal by replying to that answer.
Agents. An authorised agent may make a request on your behalf with written permission from you; we may ask you to confirm it directly.

8. Security measures

Personal data is transmitted over encrypted communication (TLS) and stored in cloud storage with access controls.
Sensitive credentials such as AI provider API keys are held only on the server and are not included in the app.
Access to personal data is limited to the minimum number of people.
Access to personal location information is limited to the fewest people needed, and records of its use and provision are kept automatically.

9. Data protection officer

Data protection officer: Lee Heekyu (Development Division) · sudacall@creamhouse.net · +82-2-508-2712

Location information manager: Lee Heekyu (Development Division) · sudacall@creamhouse.net · +82-2-508-2712

Business: CreamHouse Co., Ltd. (Representative Choi Woojin, business registration number 220-86-89511) · 19 Yangpyeong-ro 21ga-gil, Rooms 208–209, Yeongdeungpo-gu, Seoul, Republic of Korea

Reports and consultation on privacy infringement (Korea): Privacy Infringement Report Centre (privacy.kisa.or.kr, 118), Personal Information Dispute Mediation Committee (kopico.go.kr, 1833-6972)

10. Changes to this policy

If this policy changes, we announce it in the app 7 days before it takes effect (30 days before, for material changes).

Revised 2026-09-09 — with the introduction of social sign-in (Kakao, Naver), Kakao and Naver account information was added to the items collected, and the handling of linking and unlinking sign-in methods was made explicit. The default processing path for conversation generation also changed, so the overseas transfer details were corrected to match reality (default path: United States). This revised policy takes effect on 16 September 2026.

Revised 2026-09-19 — account deletion now has a 7-day hold (sign in again within it to restore your account), and section 5 now sets out the purpose, items, and period of the minimal record kept for 1 year after deletion to prevent abuse. Preventing abuse was added to the purposes in section 2. This revised policy takes effect on 19 September 2026.

Revised 2026-09-29 — service usage records (which screens you open in the app and how long you stay, whether microphone permission was granted, whether you played a voice sample — never conversation content or anything you type) were added to the items collected automatically, analysing how the app is used was added to the purposes in section 2, and section 5 now sets their retention (1 year from collection, destroyed without delay when you delete your account). In addition, sections 1, 2, and 5 now set out the items, purposes, and retention for the features you can ask for during a call (scheduled calls, alarms, songs, directions, message drafts, placing calls, adding calendar events, and passing words on to your family) and for sleep mode, and a new section 1-1 lists app permissions. Sections 3 and 3-1 now name the outside services used for song and video search, song playback on the call screen, and finding places (YouTube API Services, Google Maps Platform, NAVER Cloud), and check-in reports (section 4-1) now include how many times sleep mode was used and passing on words you ask us to pass on and confirm. A new section 4-2 covers personal location information processed with separate consent (saving places, finding places nearby, and sending your current location to your care contact), and section 9 now names the location information manager. We also brought the description of features already in service — Sign in with Apple, the sign-up age check, invites and events, and sending notifications and check-in text messages — in line with how they work. This revised policy takes effect on 29 September 2026.