Privacy Policy
Feedle (AIR) — International Privacy Policy
Effective Date: February 1, 2023
This Privacy Policy describes how Feedle (the "Company") collects, uses, discloses, and protects the personal information of buyers ("Buyers") located outside the Republic of Korea who use the AIR Service at https://air.feedle.me.
For Buyers in the Republic of Korea, please refer to the separate Korean Privacy Policy (개인정보처리방침).
1. Personal Information We Collect
1.1 Information You Provide
| Purpose | Items | Retention |
|---|---|---|
| Order processing and shipping | Full name, email, phone number, shipping address, country of residence | Until order completion + 5 years (commercial record retention) |
| Customer support | Email, phone number, message content | Until inquiry resolution + 1 year |
| Import compliance (where applicable) | Personal customs clearance number, identification document number | As required by destination country law; otherwise until order completion + 5 years |
1.2 Automatically Collected Information
- Cookies, IP address, browser type, device information, referring URL, pages viewed, timestamps
- Used for service operation, fraud prevention, and statistical analysis
2. How We Use Your Information
The Company uses personal information for the following purposes:
- To process and fulfill orders, including arranging international shipment;
- To communicate with the Buyer regarding orders, inquiries, and customer support;
- To comply with applicable legal obligations, including tax recordkeeping and CITES export reporting;
- To prevent fraud, abuse, and unauthorized transactions;
- To improve the AIR Service through analytics and statistical analysis.
3. Disclosure to Third Parties
3.1 Service Providers (Data Processors)
| Recipient | Purpose | Retention |
|---|---|---|
| Supabase, Inc. | Authentication, database, file storage, real-time infrastructure | Until account deletion or termination of processing agreement |
| Amazon Web Services, Inc. | Cloud infrastructure underlying Supabase | Same as above |
| Cloudflare, Inc. | Real-time communication server, image and video storage and streaming | Same as above |
| Google LLC | Mobile push notifications (Firebase Cloud Messaging), app usage analytics (Firebase Analytics), Google account sign-in | Same as above |
| Vercel Inc. | Web service hosting and traffic analytics | Same as above |
| FedEx and regional logistics partners | International shipping and customs clearance | Until shipment completion + record retention period required by law |
| Banking partners | Receipt and verification of international wire transfers | As required by applicable banking and tax law |
3.2 Government and Law Enforcement
The Company may disclose personal information to government authorities or law enforcement when required by valid legal process or where necessary to protect the Company's legal rights.
4. International Data Transfer
The Company is based in the Republic of Korea. By using the AIR Service, the Buyer acknowledges that personal information will be transferred to and processed in the Republic of Korea and in the locations of the service providers listed in Section 3.
| Recipient | Country | Items | Retention |
|---|---|---|---|
| Supabase, Inc. | Republic of Korea (AWS ap-northeast-2 region) and the United States (operating headquarters) | All collected personal information | Until account deletion or termination of processing agreement |
| Amazon Web Services, Inc. | Republic of Korea (ap-northeast-2 region) | All collected personal information | Same as above |
| Cloudflare, Inc. | United States | Chat messages, images, videos | Same as above |
| Google LLC | United States | Email, device identifiers (FCM token, advertising ID), app usage records, Google account information | Same as above |
| Vercel Inc. | United States | Access logs, device information, page usage | Same as above |
5. Retention and Deletion
5.1 The Company retains personal information only for the period necessary to fulfill the purposes set out in this Privacy Policy and to comply with applicable legal obligations.
5.2 Upon Buyer's request for deletion, the Company will delete personal information except where retention is required by law (e.g., for tax, customs, or commercial record purposes).
6. Buyer Rights
6.1 General Rights (All Buyers)
Regardless of the Buyer's jurisdiction, the Company honors the following rights:
- Access: to obtain confirmation of and access to personal information held by the Company;
- Rectification: to correct inaccurate or incomplete personal information;
- Erasure: to request deletion of personal information, subject to legal retention obligations;
- Withdrawal of consent: to withdraw previously given consent, without affecting the lawfulness of processing before withdrawal.
Requests can be submitted via the contact information in Section 9. The Company endeavors to respond without undue delay and in any event within 30 days of receipt.
6.2 Additional Rights for Buyers in the European Union, EEA, and the United Kingdom (GDPR)
If the Buyer is ordinarily resident in the EU, EEA, or the UK, the General Data Protection Regulation (Regulation (EU) 2016/679) and the UK GDPR grant the following additional rights:
- Legal bases for processing. The Company processes personal information on the following legal bases under Article 6(1) GDPR:
- Contract performance (Art. 6(1)(b)): order processing, shipping, customer support;
- Legal obligation (Art. 6(1)(c)): tax recordkeeping, commercial record retention;
- Legitimate interests (Art. 6(1)(f)): fraud prevention, network security, service improvement (the Buyer may object to processing under this basis at any time);
- Consent (Art. 6(1)(a)): where specifically requested (e.g., marketing communications, optional cookies).
- Restriction of processing (Art. 18): the right to restrict processing in certain circumstances.
- Objection (Art. 21): the right to object to processing based on legitimate interests.
- Data portability (Art. 20): the right to receive personal information in a structured, commonly used, machine-readable format.
- Right not to be subject to automated decision-making (Art. 22): the Company does not engage in solely automated decision-making that produces legal or similarly significant effects on the Buyer.
- Right to lodge a complaint (Art. 77): the Buyer may lodge a complaint with the supervisory authority of the Buyer's place of residence (e.g., the Information Commissioner's Office in the UK).
- International data transfers. Personal information is transferred outside the EU/EEA/UK to the Republic of Korea and the United States. The Republic of Korea has been granted an adequacy decision by the European Commission (effective 19 December 2023). For transfers to the United States and other jurisdictions, the Company relies on Standard Contractual Clauses or other appropriate safeguards under Chapter V GDPR.
6.3 Additional Rights for California Residents (CCPA)
The Company honors the following rights for California residents under the California Consumer Privacy Act (Cal. Civ. Code § 1798.100 et seq.) and the California Privacy Rights Act, even where the Company is not strictly required to do so by law:
- Right to know: what categories of personal information have been collected, the sources, purposes, and categories of third parties to whom it has been disclosed (see Sections 1, 2, 3).
- Right to delete: to request deletion of personal information, subject to legal retention obligations (see Section 5).
- Right to correct: to request correction of inaccurate personal information.
- Right to opt out of sale or sharing: the Company does not sell personal information and does not share personal information for cross-context behavioral advertising as those terms are defined under CCPA.
- Right to non-discrimination: the Company will not discriminate against the Buyer for exercising any CCPA rights.
- Right to limit use of sensitive personal information: the Company does not use sensitive personal information beyond purposes permitted by CCPA § 1798.121.
To exercise CCPA rights, contact the Company via Section 9. The Company will verify the Buyer's identity and respond within 45 days (extendable by 45 additional days where reasonably necessary).
7. Cookies
The AIR Service uses cookies to maintain login sessions, analyze usage, and improve service performance. Buyers may disable cookies through browser settings, but doing so may limit the functionality of the AIR Service.
8. Security Measures
The Company applies technical and organizational measures consistent with the Korean Personal Information Protection Act and applicable international standards, including:
- Encryption of personal information in transit (TLS) and sensitive data at rest;
- Access control with least-privilege principle and multi-factor authentication for administrators;
- Audit logging of access to personal information processing systems;
- Regular security training of personnel;
- Use of cloud infrastructure providers with recognized security certifications.
9. Contact
For privacy-related inquiries or to exercise the rights described in Section 6, please contact:
- Email: support@feedle.me
- Service hours: 10:00–20:00 GMT+9 (Korean Standard Time)
For unresolved privacy concerns, Buyers may also contact:
- Korean Personal Information Protection Commission: https://www.pipc.go.kr
- Korea Internet & Security Agency (Privacy Infringement Report Center): https://privacy.kisa.or.kr (call 118)
10. Changes to This Privacy Policy
The Company may update this Privacy Policy from time to time. Material changes will be announced on the AIR Service at least 7 days before the effective date (or 30 days where required by applicable law).
Effective Date: February 1, 2023