Studio Yonggari ("we") runs the Christmas Town app (the "app"). We follow the Personal Information Protection Act and the Network Act of the Republic of Korea and the privacy laws of the countries where the app is offered (Japan, the US, Canada, the EU/EEA including Spain, the UK, Taiwan, Mexico and other Spanish-speaking countries, Australia, New Zealand and Singapore). We are the controller of your personal data (the "controller" under the GDPR and the UK GDPR, the business handling personal information under Japan's APPI). This policy explains what we process and why.
1. What we process and how we get it
Kind
Data
When
Required
Anonymous account ID (made automatically), nickname, avatar look, friend code
First launch
Required
A backup of your game save (home, tree, diary, notes …)
While you use the app (guest accounts too)
Required
Stardust balance and history, items from gift boxes, trade and market history, your dong (village instance) and plot
While you use the app
Required
In-app position (coordinates inside the village / concert hall, channel, seat), online status (anonymous ID and time)
While walking with others or while the app is open
Optional
Email address and password (stored hashed by Google; we cannot see it)
If you create an account with email
Optional
The unique ID and email address of your Apple or Google account (may be an Apple "Hide My Email" address), Game Center player ID (where offered)
Invite code, the account IDs of inviter and invitee, invite counts, a hash of a device identifier (the device ID itself is never sent)
When you open the invite screen or enter a friend's code
Purchases
Transaction ID, product, time, environment (production / sandbox), the identifier linking a purchase to your account (appAccountToken)
If we sell something and you buy it (this version sells nothing)
Ads
Processed by the ad SDK: IP address (approximate location), device/app identifiers, ad interactions, diagnostics
When a rewarded ad is loaded or shown on the stardust screen (collected directly by Google AdMob, section 3)
Automatic
IP address, access time, device and OS type and similar connection logs
Recorded automatically by our server providers (Google Firebase, Netlify, Cloudflare) when the app connects
How we get it: you type it into the app, or it is created as you use the app.
What we do not collect: your name, phone number, real-world location (GPS), contacts, camera, microphone, or the contents of your photo library. When you save a photo we use "add photos" access only and never read your other photos.
Card and payment details are handled by Apple or Google; we never receive them.
The focus timer's "done" alert is scheduled on your device; it is not a push notification sent from our server.
2. Purposes and legal bases
Purpose
Data
Legal basis
Your account and the app's features (walking together, friends, letters, guestbooks, chat, trades, market, dongs, backup)
Required and optional data in section 1
Contract (Korean PIPA art. 15(1)(4); UK GDPR art. 6(1)(b))
Deciding stardust, boxes and trades on our server; preventing cheating (tampering, macros, double rewards); security
Contract and legitimate interests (PIPA art. 15(1)(6); UK GDPR art. 6(1)(f))
Handling reports and community-rule violations
Reports, reported chat and letters, account ID
Contract and legitimate interests
Delivering purchases, refunds and disputes (if we sell)
Purchase data
Contract and legal obligation (Korean e-commerce law)
Serving, measuring and protecting rewarded ads
Ad data
Contract (a reward feature you choose); in the UK, the EU/EEA and similar regions, consent through Google's consent form (UK GDPR art. 6(1)(a))
Personalised ads (only if you allow tracking, section 3)
Advertising identifier (IDFA) etc.
Consent
We do not sell your personal data, and we do not use it ourselves for advertising, tracking or profiling.
3. Ads, App Tracking Transparency (ATT) and marketing messages
Rewarded ads: "Watch an ad for stardust" shows an ad only when you choose to, and gives stardust when you watch it to the end. When you open the stardust screen, the Google AdMob SDK starts so that an ad can be loaded in advance, and Google processes the ad data in section 1 directly at that point. We only receive the result that a reward was earned.
This version: the app does not show the iPhone "Allow tracking" prompt (ATT), does not access the advertising identifier (IDFA), and requests non-personalised ads only. Even for non-personalised ads, Google may use device information for frequency capping, measurement and fraud prevention.
If we ask to allow tracking: a future update may add the ATT prompt (we will announce it in the app first). If you allow it, Google AdMob may use the IDFA to show ads that match your interests. If you don't, ad rewards and every app feature stay exactly the same and you see non-personalised ads. You can change this at any time in iPhone Settings → Privacy & Security → Tracking.
Consent form: in the UK, the European Economic Area, Switzerland and other places where the law requires it, Google's consent form is shown before ads. You can change or withdraw your choice at any time under "Ad privacy choices" on the stardust screen.
Street posters: the posters in the village only download images we upload. They have no ad SDK and no click tracking.
Marketing messages: we do not send advertising by push notification, email or text message (Korean Network Act art. 50). The only emails we send are account verification and password reset emails. If we ever want to send marketing, we will ask for your separate consent first, and saying no will not affect your use of the app.
4. How long we keep it
Data
Kept for
Why
Account, nickname, profile, game save, friends list, received letters, stardust wallet, items, dong
Until you delete your account (deleted immediately)
Running the service
Chat messages
6 hours after sending (deleted automatically)
Running the service
Walking position
Deleted as soon as you disconnect (leftovers within 10 minutes)
Running the service
Online status
Shown for 2 minutes; the record is deleted within 1 hour
Running the service
Reports
1 year after they are handled
Disputes and repeat abuse
Finished trade and market records (both sides' anonymous ID and nickname, items, time)
1 year after the trade (also kept as the other person's record after you delete your account)
Disputes
Purchase records (transaction ID, product, time, account ID)
5 years
Korean Act on Consumer Protection in Electronic Commerce, art. 6 and its decree art. 6
Hash of the sign-in identity (the original ID cannot be recovered from it)
After account deletion, until the service ends
Preventing linking rewards from being paid twice
Hash of the device identifier used for invites (the original ID cannot be recovered from it)
After account deletion, until the service ends (the link to your account is removed on deletion)
Preventing invite rewards from being claimed again on the same device
Letters, parcels and guestbook lines you sent to others
Until the recipient deletes them or their account
The recipient's record
Server providers' connection logs, ad SDK data
Each company's own retention rules (section 7)
Their operation and security
5. How we delete it
When a retention period ends or the purpose is achieved, we delete the data without delay. When you ask to delete your account, the server removes your account data straight away; data that the law or the table above requires us to keep is stored separately and deleted when its period ends.
Electronic files are deleted from the database so they cannot be restored. We do not keep paper records. Copies in our server providers' backups are removed on those providers' schedules.
Deleting your account also resets the save and sign-in data (Keychain) on your phone.
6. Sharing with third parties
We do not give your personal data to third parties, except where the law requires it. For rewarded ads, however, Google LLC collects the ad data in section 1 directly through its SDK in the app and uses it to serve, measure and protect ads. That data is handled under Google's Privacy Policy (https://policies.google.com/privacy) and retention rules, and deleting your account does not delete what Google holds.
7. Processors and international transfers
Recipient (contact)
Task
Country, timing and method
Data
Kept
Google LLC — Firebase Realtime Database, Authentication, Cloud Functions, Google Sign-In (https://policies.google.com/privacy)
Storage, sign-in, server-side decisions
USA / whenever you use the app, over encrypted connections
Data in section 1 (except payment and ad data)
As in section 4
Google LLC — Google AdMob (https://policies.google.com/technologies/ads)
Serving, measuring and protecting rewarded ads (section 6)
USA and others / when an ad is loaded or shown, over encrypted connections
Ad data
Google's rules
Apple Inc. — App Store, Sign in with Apple, Game Center (https://www.apple.com/legal/privacy/contact/)
Payments and refunds (if we sell), sign-in
USA and others / when you use those features
Payment data, Apple account ID and email
Apple's rules
Google LLC — Google Play (https://policies.google.com/privacy)
Android payments and refunds (if we sell)
USA and others / when you pay
Payment data
Google's rules
Cloudflare, Inc. — Workers (walking-together relay) (https://www.cloudflare.com/privacypolicy/)
Passing your walking position and state to other users in the same channel in real time (not stored), sign-in check
USA and others (nearest data centre) / while you walk together, over encrypted connections
Anonymous account ID, in-app position, IP address
Not stored (dropped as soon as it is passed on; connection logs follow Cloudflare's rules)
Netlify, Inc. (privacy@netlify.com)
Hosting the policy and support pages and the street poster images
USA and others / when a page or image is downloaded
IP address, access logs
Netlify's rules
Basis: entrusting and storing data as needed to perform our contract with you, disclosed in this policy (Korean PIPA art. 28-8(1)(3)). We require safe handling through our contracts with each company (their data processing terms).
UK users: Google LLC is certified under the EU-US Data Privacy Framework and its UK Extension (the UK-US data bridge); other transfers are covered by standard contractual clauses with the UK International Data Transfer Addendum.
EU/EEA users: Google LLC and Cloudflare, Inc. participate in the EU-US Data Privacy Framework, so transfers to them rely on the European Commission's adequacy decision. Other transfers (Netlify, Apple and others) are covered by the standard contractual clauses (SCCs) in each company's data processing terms. You can ask for a copy at support@studioyonggari.com.
Refusing and its effect: if you do not want your data transferred abroad, you can delete your account, but features such as walking together, friends, letters and backup cannot work without server storage. Ad data is not sent if you do not open the stardust screen, or if you refuse on the consent form where one is shown.
8. Children
The app is not directed to children under 13, and children under 13 may not use it. We do not knowingly collect personal data from children under 13; if we learn that we have, we delete it without delay (including under the US COPPA). Parents and guardians can ask us to delete it using the contact below.
In the Republic of Korea, users under 14 need the consent of a legal guardian before creating an account or buying anything (Korean PIPA art. 22-2). We collect only the minimum guardian information needed to confirm consent (such as an email address), and if we learn that data was processed without consent, we delete it without delay.
EU/EEA users: the app is for people aged 13 and over. The age of digital consent differs by country, from 13 to 16 (for example Spain 14, France 15, Germany and Ireland 16). A user below the age of consent in their country of residence needs the consent of a parent or other holder of parental responsibility to use the app. If we learn that data of such a user was processed without consent, we delete it without delay, and a parent or guardian can ask us to check or delete it at support@studioyonggari.com.
Parents can manage purchases with Screen Time and Ask to Buy on iPhone.
9. Your rights and how to use them
You (or your legal guardian, if you are under 14 in Korea) may at any time ask to see, correct or delete your data, stop its processing, or withdraw consent. In the UK and similar places you also have the rights to data portability (a copy) and to object.
Users in the EU/EEA and the UK have the rights of access, rectification, erasure, restriction of processing, data portability (a structured copy) and objection (including to processing based on legitimate interests), and may withdraw consent at any time where processing is based on consent (this does not affect processing before the withdrawal). We answer within 1 month, which may be extended by 2 months for complex or numerous requests, in which case we tell you why within the first month. The right to complain to a supervisory authority is in section 14.
How: in the app (change your nickname, Settings → Account → Delete account, "Ad privacy choices") or by email to support@studioyonggari.com. An authorised agent can ask for you with a letter of authorisation. To confirm it is you, we may ask for details such as your in-app friend code.
We answer within 10 days of receiving a request (1 month in the UK, 45 days in California). If the law lets us refuse, we tell you why and how to challenge it. There is no fee.
We will not treat you differently for using your rights.
10. Automated decisions
If several reports about a player's chat come in within a short time, the server automatically restricts that player's chat for a set time. You can ask for an explanation or object by emailing support@studioyonggari.com, and a person will review it (Korean PIPA art. 37-2; UK GDPR art. 22). Gift box results are random draws at the published odds and do not evaluate you.
11. Security
Encrypted connections (HTTPS / WSS) and server rules that let only you reach your data
Stardust, gift boxes, purchases and trades are recorded only by our server (not changeable from a device)
No secret keys in the app; only one person (our representative) handles personal data; minimal administrator access
Servers sit in Google's data centres (physical security)
12. Automatic collection (cookies and advertising identifiers)
The app does not use cookies. This version does not access the advertising identifier (IDFA); if we ever ask to allow tracking, section 3 applies. The Google AdMob SDK may process device information for ads, and you can refuse it as described in section 3. Performance logs (frame rates etc.) stay on your device and are not sent to us. The policy web pages do not use cookies either.
13. Privacy officer and complaints
Privacy officer and contact for access requests: Park Seobin (representative) · Email support@studioyonggari.com · Phone +82-10-7718-7778 · Address 39 Bonwon-ro, Uijeongbu-si, Gyeonggi-do, 11604, Republic of Korea
Korean complaint bodies: Personal Information Infringement Report Center (privacy.kisa.or.kr, 118 in Korea), Personal Information Dispute Mediation Committee (www.kopico.go.kr, 1833-6972), Supreme Prosecutors' Office (www.spo.go.kr, 1301), Korean National Police Agency (ecrm.police.go.kr, 182)
14. Country-specific notes
Japan: our name, address and representative are in section 13. Requests for notice of purposes, disclosure (including electronic copies), correction, suspension of use or suspension of third-party provision of retained personal data are accepted as in section 9. Our processors in a foreign country (the US) maintain, by contract, a system of measures consistent with Japan's APPI; information on the US privacy system is available from the Personal Information Protection Commission (https://www.ppc.go.jp/personalinfo/legal/kaiseihogohou/#gaikoku). Security measures are in section 11, and personal data is stored in the US. Complaints go to the email in section 13.
United States (California and other states): the categories we collect are identifiers (account ID, email, device identifiers), internet activity (in-app activity, ad interactions) and approximate location (IP); sources and purposes are in sections 1 and 2. We do not sell personal information, and this version does not share it for cross-context behavioural advertising. Personalised ads are possible only if you allow tracking, which you can refuse at any time in iPhone Settings. We do not collect sensitive personal information. You can use your rights to know, delete and correct, and to non-discrimination, as in section 9, including through an authorised agent.
EU/EEA (including Spain): we are the controller under the GDPR; our contact is in section 13. The legal bases (GDPR art. 6) are: (1) providing your account and the app's features: performance of a contract (para. 1(b)); (2) server-side decisions, preventing abuse, handling reports and security: legitimate interests (para. 1(f), within limits that respect your rights and interests, and you may object); (3) keeping payment records: legal obligation (para. 1(c)); (4) the ad SDK's use of device data and personalised ads: consent (para. 1(a), collected through Google's consent form and ATT, and withdrawable at any time under "Ad privacy choices" on the stardust screen). Retention is in section 4, international transfers (Google, Cloudflare, Netlify, Apple and others, to the USA and elsewhere) in section 7, how to use your rights in section 9 and automated decisions in section 10. We have not currently appointed an EU representative under Article 27 of the GDPR; EU users and supervisory authorities can contact us directly at support@studioyonggari.com. You can complain to the supervisory authority of the member state where you live or work or where the alleged infringement took place (Spain: Agencia Española de Protección de Datos, AEPD, www.aepd.es). If you do not provide the data we need to perform the contract (section 1), the related feature cannot be used.
United Kingdom: legal bases are in section 2, international transfers in section 7 and your rights in section 9, and you may use every right listed under "EU/EEA" in section 14 under the UK GDPR. UK transfers are covered by the standard contractual clauses with the UK International Data Transfer Addendum or the UK-US data bridge. Aged 13 or over, you meet the UK age of digital consent (13). You can complain to the Information Commissioner's Office (ICO, ico.org.uk). We have not appointed a UK representative under Article 27 of the UK GDPR; UK users and the regulator can contact us directly at the contact in section 13.
Taiwan: under the Personal Data Protection Act (個人資料保護法) you may ask to inquire about and review your data, request a copy, ask for supplement or correction, ask us to stop collecting, processing or using it, and ask for deletion. The purposes, categories, period, area, recipients and methods of use are in sections 1, 2, 4 and 7; if you do not provide the required data, the related feature cannot be used. Requests are accepted as in section 9 and handled free of charge within the legal time limits (15 days for review and copies, 30 days for other requests). If it is not resolved, you can report it to the competent authority where you live.
Mexico and other Spanish-speaking countries: in Mexico, under the Federal Law on the Protection of Personal Data Held by Private Parties (LFPDPPP), you may use your ARCO rights (Access, Rectification, Cancellation, Opposition), withdraw consent and limit the use of your data as in section 9. This policy also serves as our privacy notice (aviso de privacidad): our identity and contact are in section 13, the data in section 1, the purposes in section 2 and international transfers in section 7. We handle requests within the time in section 9 (and always within the legal limit), free of charge. If it is not resolved, you can complain to the personal data authority in Mexico. Users in other Spanish-speaking countries can use the rights given by their national data protection law as in section 9 and complain to their national data protection authority.
Canada, Australia, New Zealand and Singapore: you can use your rights as in section 9 and, if not resolved, complain to your regulator (Canada OPC, Australia OAIC, New Zealand Privacy Commissioner, Singapore PDPC). Our Data Protection Officer under Singapore's PDPA is the contact in section 13.
15. Changes
We announce changes in the app and on this web page 7 days before they take effect (30 days for changes that are important or against your interest). Where the law requires consent for a change, we will ask for it separately. Previous versions are available on request.