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Pathpin Privacy Policy
Effective: November 10, 2026 · This is the English version of the privacy policy for Pathpin (called 픽루트, PicRoute, in Korea). It is a translation of the Korean policy (픽루트 개인정보 처리방침). If the two versions ever differ, the Korean version prevails, unless the law of your country provides otherwise.
Change notice — This policy applies from
November 10, 2026. Through November 9, 2026, the previous version (effective November 2, 2026,
in Korean) applies.
What changed: we added two features to the trail map —
"Save the trail map for this route" (below, "saving in advance": saving the trail map around a planned route, imported or drawn yourself, on your phone before you go into the mountains or anywhere without internet) and
"Draw route" (drawing a planned route yourself on the map).
(1) When you save in advance,
the map area around that planned route is passed to Tracestrack (the route's coordinate list is not sent as such, but the requested map images reveal the area around the route).
(2) Trail-map images stored on your phone are
deleted when you open the app once they were downloaded more than 30 days ago (this applies to everyone who uses the trail map, under the map provider's terms). So without internet, trail-map images downloaded more than 30 days ago are not shown.
(3) When you tap "Draw route",
the map type switches to the trail map, so the map area shown on screen while you draw is passed to Tracestrack (the same as when you choose the trail map).
The coordinates of the planned route you draw are stored only on your phone and are not sent anywhere.If you neither save in advance nor use "Draw route", what is passed to Tracestrack does not change. The kinds of personal information we process (IP address, map image addresses, etc.), the purposes, the recipients and Tracestrack's retention period (35 days) stay the same; what changes is that, when you save in advance, the map images requested extend to the area around the planned route, and that tapping "Draw route" switches the map to the trail map.
What changed — comparison table (in Korean)
WATSI ("the Company", "we") publishes this privacy policy for the mobile application Pathpin ("the Service") under Article 30 of the Korean Personal Information Protection Act, so that we protect your personal information and handle your concerns smoothly. We process only the minimum personal information needed for each purpose.
Summary
- The photos, location coordinates, memos and walked tracks you record in Pathpin are stored on your phone and are not sent to us. We cannot see or keep these records.
- There is no sign-up or login, and we have not added any advertising or behavioral-analytics tools. However, the app's update check produces usage statistics such as the number of installs (Section 11).
- The personal information we process is: (1) what you give us when you contact us or ask for a refund; (2) the sales records that the app stores provide to sellers; (3) technical information (install ID, IP address, etc.) that Expo processes for us to check for app updates; (4) if you choose the trail map, technical information (IP address, and the map area you are viewing or, if you tap "Save the trail map for this route", the area around the planned route, etc.) that Tracestrack processes for us to deliver trail-map images (Sections 1 and 5).
- Separately, when maps are shown (Google; on iPhone, Apple as the base map under the trail map) and when you pay (the app stores), information such as device details, your IP address and the map area you are viewing goes directly to those companies (Section 4).
- If you live outside Korea (for example in the EU/EEA, the UK, Japan or the United States), Section 16 gives additional information required by the laws of those places.
1. Personal information we process (purpose, items, legal basis, retention)
| Purpose | Items | Legal basis (Korean law) | Retention |
|---|
| Handling requests to withdraw from a purchase, for refunds, to cancel a subscription, or to rescind a contract made by a minor |
Your email address or phone number, the app store you paid through, the order number, the date, time and amount of the payment, your request and how it was handled; if refunded to a bank account, the bank name, account number and account holder name; if a legal representative makes the request, the representative's name, contact details and relationship to the minor |
Personal Information Protection Act ("PIPA") Article 15(1)(4) (entering into and performing a contract) and (2) (legal obligations under Articles 6, 17 and 18 of the Act on Consumer Protection in Electronic Commerce) |
5 years after handling is complete (Enforcement Decree of the Act on Consumer Protection in Electronic Commerce, Article 6(1)(2)–(3)) |
| Handling consumer complaints and disputes |
Contact details (email address or phone number), the complaint or dispute and how it was handled |
PIPA Article 15(1)(4) and (2) (Article 6 of the Act on Consumer Protection in Electronic Commerce) |
3 years after handling is complete (same Enforcement Decree, Article 6(1)(4)) |
| Answering other inquiries, sending copies of the terms or of payment records, and handling objections to usage restrictions |
Contact details (email address or phone number), your inquiry and any information you include in it (for example, your phone model) |
PIPA Article 15(1)(4) |
1 year after we reply |
| Settling sales, filing taxes, and confirming refunds and subscriptions |
Sales records that the app stores provide to sellers: order number, payment date and time, product name, amount paid, country of purchase (for sales where the Company is the seller of record, the buyer's city, state/province and postal code), device model |
PIPA Article 15(1)(2) (Article 6 of the Act on Consumer Protection in Electronic Commerce; Article 85-3 of the Framework Act on National Taxes) and (4) |
Contract and payment records for 5 years (same Enforcement Decree, Article 6(1)(2)–(3)). Tax books and evidence for 5 years from the day after the filing deadline of the tax concerned, and records of cross-border transactions for 7 years (Framework Act on National Taxes, Article 85-3(2)) |
| Providing updates that fix bugs and improve features |
An install ID randomly created for each installation of the app, the operating system type, the app version, update channel and update ID, and — if the previous launch of the app failed — the error message (up to 1,024 characters) and the ID of the failed update, and your IP address |
PIPA Article 15(1)(4) (performing the contract) |
As set out in Section 5(1) |
| Providing trail-map images (only if you choose the trail map) |
Your IP address, the address of the map images requested (the map area on screen (if you tap "Save the trail map for this route", the area around the planned route), the zoom level and the language of the map labels), and basic information sent with any internet request (language setting, operating system and device type, etc.) |
PIPA Article 15(1)(4) (performing the contract) |
As set out in Section 5(3) (35 days) |
We do not receive payment details such as card numbers. The photos, locations, memos and walked tracks in the app are not information we receive (Section 2).
2. Information processed only on your phone
The following information is stored in the app's storage on your phone and is not sent to any server of ours (we do not operate servers).
- Photo entries: the coordinates (latitude and longitude) where you took the photo or of the point you picked on the map, the time recorded, the sequence number, the title and memo you entered, and the gallery ID and file name of the linked photo
- Walked tracks while walk recording is on: for each point, the coordinates (latitude, longitude and altitude), the margin of error of the position and altitude, speed and direction, and the time recorded; for each segment, its start and end time and the distance walked
- Trip names, their start and end times, and memo templates
- Trips, entries, walked tracks and planned routes (routes drawn in advance in another app) read from files you import (KML, GPX, CSV, or a ZIP containing them). Imported files are read only on your phone.
- Planned routes you draw yourself on the map with "Draw route" (the coordinates of the points you place). They are stored only on your phone.
- A temporary copy of what you were writing on the entry screen (location coordinates and time, trip name, title and memo, and the file location of the photo you picked): kept so that you can continue if the app closes unexpectedly. It is deleted when you save or close the screen, and a copy older than one day is deleted the next time you open the app.
- Trail-map images received while viewing the trail map, and those saved in advance with "Save the trail map for this route": kept in your phone's temporary storage so that they need not be downloaded again and can be seen without internet; images downloaded more than 30 days ago are deleted when you open the app. Deleted images are downloaded again if you view that place while online, so without internet, images downloaded more than 30 days ago are not shown. They may also be deleted earlier if your phone runs low on storage or you clear the app's cache.
- App settings, the start date of the free trial, and the subscription status last checked
Photos you take, and copies of photos you pick from your albums to add to entries, are saved in the "Pathpin" album of your phone's Gallery (Photos app on iPhone). (If your phone was set to Korean when you started using the app, or you were already using it before the overseas version, the album is called "픽루트". If saving to the album is not possible, the photo is saved in the Gallery's default photo folder.) The original photos in your albums are left as they are.
Deletion: You can delete entries in the app, and they are deleted from your phone when you delete the app or clear its data. However, the following may remain:
- Photos in your Gallery: they remain even if you delete the app, and you can delete them in your photos app.
- Files you have exported (KML, GPX, CSV, ZIP, and photo bundles): they remain until you delete them. A photo bundle made for sharing stays briefly in your phone's temporary storage and is deleted the next time you make a photo bundle or open the app.
- Phone backups: the Service is set to allow the operating system to back up the app. If your phone's backup is on, the app's entries and settings may be backed up to your own account. On Android, if Google backup is on and the app data is within the backup limit, it may be restored when you reinstall the app; on iPhone, it may be restored when you restore the whole phone from an iCloud backup. We cannot see these backups, and you can turn backup off in your phone's settings.
3. App permissions
| Permission | Used for | Type |
|---|
| Location (precise and approximate) | Recording where photos are taken, recording the path you walk while walk recording is on, and showing your current location on the map | Required |
| Camera | Taking photos on site | Required |
| Photos and media | Saving the photos you take and copies of photos you pick from your albums to the "Pathpin" album of your Gallery (Photos app on iPhone), linking them to entries and showing them, and reading a trip's photos when you make a photo bundle | Required |
| Notifications (Android only) | Showing in the notification bar that walk recording is on | Optional — you can use walk recording without it, but the notification that recording is on will not appear |
- Location is used only while the camera screen is open, while you are looking at a map screen, and while you have walk recording turned on.
- When you turn on walk recording, the app keeps using your location to record the path you walk even with the screen off, and stops when you tap "Stop". On Android, this works by showing a "Walk recording" notification in the notification bar during that time; the app does not ask for the separate permission to receive location when the app is not in use (background location permission). On Android 13 or later, if you do not allow notifications, the notification will not appear, so please check in the app whether walk recording is on. On iPhone, too, the app does not ask for permission to receive location when you are not using it ("Always"), and uses your location with the screen off only while walk recording is on. On iPhone, walk recording stops if you swipe the app away to close it completely.
- Your current location is calculated by your phone's operating-system location service (Google Play services on Android, iOS on iPhone) and passed to the app. How the location service uses nearby signals depends on your phone settings and the policy of that operating-system provider.
- The Service has no features — such as address search, directions or "find nearby" — that send the coordinates of your entries to outside services. However, because the map screen shows the area around your current location when the app opens, the map area shown on screen is passed to the map provider (Google; if you choose the trail map, Tracestrack and, on iPhone, Apple) in the course of loading map images (Sections 4 and 5(3)).
- When you tap "Save the trail map for this route" on a trip that has a planned route (imported or drawn yourself), trail-map images around that planned route are requested in advance, so the map area around it is passed to Tracestrack (Section 5(3)). The route's coordinate list is not sent as such, but the requested map images reveal the area around the route to Tracestrack.
- The coordinates of a planned route you draw with "Draw route" are stored only on your phone and are not sent to us or to any map provider. However, tapping "Draw route" switches the map type to the trail map, so the map area shown on screen while you draw is passed to Tracestrack (Section 5(3)).
- You can turn off any permission at any time in your phone's Settings > Apps > Pathpin > Permissions (on iPhone, Settings > Pathpin).
4. Information other companies receive directly
The following information is exchanged directly between your phone and outside services built into the app, and each company processes it under its own privacy policy. We do not pass your records (photos, lists of entry coordinates, memos, walked tracks) to these companies.
(1) Map display — Google Maps
| Recipient | Google LLC (United States) |
|---|
| When | When a map screen is shown |
|---|
| What Google receives | Request information needed to load the map (operating-system version, device model and manufacturer, map component version), a pseudonymous identifier for the map component (a random number not linked to your name) and an identifier for internal usage checks, your IP address, error and performance records of the map component, interaction information such as panning and zooming the map, and the map area shown on screen (the area around your current location when the app opens) |
|---|
| How it is handled | Google uses this information to provide maps and to operate and improve its own services, under the Google Privacy Policy. The Google Maps Platform terms provide that Google may receive information such as IP addresses and latitude/longitude coordinates in providing the service. |
|---|
| How to refuse, and the effect | Nothing is sent if you turn off your internet connection. In that case map images are not shown, and after 14 days without internet the subscription cannot be checked, so starting new trips, continuing trips and adding photos are restricted (Terms of Use, Article 8(6)). You can keep using photos, locations, memos and walk recording. |
|---|
(2) Payment and subscription checks — app stores
Subscription payments, renewals and refunds are processed by Google Play or the App Store, and personal information in that process is handled under each store's privacy policy (Google, Apple). The Service checks with the app store, from your phone, whether your subscription is active and when it expires, and stores the result of the last check (active or not, expiry date, time of the check) on your phone. When there is no internet, this result is applied for up to 14 days after the last check. This information is not sent to us.
(3) Links you tap and exports
- If you tap a link in the app to the Korea Fair Trade Commission's business information or to send us an email, your phone's browser or mail app opens. If you contact us, your contact details and message are handled as described in Section 1.
- When you tap Export, a file is created and delivered only to the app or folder you choose; what happens after that follows the policy of the service you chose.
- Record files (KML, GPX, CSV, or a ZIP containing them) contain the trip name (also used in the file name), entry titles and memos, location coordinates and times, walked tracks (with altitude in GPX files) and distances, planned routes (imported or drawn yourself), and photo file names; the photos themselves are not included.
- Photo bundles (ZIP) contain the trip's photos exactly as they are in your Gallery (the bundle's file name contains the trip name, and each photo's file name contains the date, sequence number and the entry title at the time the photo was saved — it does not change if you edit the title later). Photo files may contain information your phone saved with the photo (date and time taken, device model and so on, and, depending on the photo, where it was taken). The app does not change or remove the information inside photo files.
(4) Base map under the trail map — Apple Maps (only if you choose the trail map on iPhone)
On iPhone, when you switch the map type to "Trail map", Apple Maps is laid underneath the trail-map images (Section 5(3)) as the base map. Switching back to the standard or satellite map returns you to Google Maps. We do not pass your records (photos, lists of entry coordinates, memos, walked tracks) to Apple.
| Recipient | Apple Inc. (United States) · contact https://www.apple.com/legal/privacy/contact/ |
|---|
| When | When the trail map is shown on an iPhone |
|---|
| What Apple receives | Request information needed to load the map, your IP address, and the map area shown on screen |
|---|
| Purpose and how it is handled | Showing the base map. Retention and other matters follow the Apple Privacy Policy. |
|---|
| How to refuse, and the effect | Nothing is sent if you do not choose the trail map (standard or satellite map) and do not use "Draw route". Nothing is sent if you turn off your internet connection; in that case the base map may not appear. You can keep using photos, locations, memos and walk recording. |
|---|
5. Processing on our behalf and transfers abroad
(1) Transfer abroad (processing on our behalf) — app update checks
To deliver bug fixes and feature improvements as automatic updates that do not go through the app stores, we have the following company process personal information on our behalf, and the information is therefore transferred abroad. This is done under PIPA Article 26 (processing on behalf) and Article 28-8(1)(3)(a) (processing on behalf needed to perform a contract, disclosed in the privacy policy).
| Recipient and contact | 650 Industries, Inc. (Expo) · 624 University Ave FL1, Palo Alto, CA 94301, USA · contact form https://expo.dev/contact |
|---|
| Country | United States |
|---|
| Sub-processors | The companies on Expo's published list of sub-processors (https://expo.dev/privacy/subprocessors). Among them, the cloud and network providers are Amazon Web Services, Google, Cloudflare and Cyberlynk (all United States). We will update this policy if the list changes. |
|---|
| Items transferred | An install ID randomly created for each installation of the app, the operating system type, the app version, update channel and update ID, and — if the previous launch of the app failed — the error message (up to 1,024 characters) and the ID of the failed update, and your IP address |
|---|
| When and how | When you launch the app and when you tap "Check for updates" in Settings, sent over an encrypted internet connection (HTTPS) |
|---|
| Task | Checking whether a new update is available and delivering the update files |
|---|
| Retention | Kept while we use the Expo update service, to the extent needed to check for and deliver updates and to keep the service secure and handle outages; deleted under Expo's policies when we stop using it. |
|---|
| How to refuse, and the effect | Nothing is sent if you use the app with your internet connection turned off. In that case you cannot receive bug-fix or feature updates, and after 14 days without internet the subscription cannot be checked, so starting new trips, continuing trips and adding photos are restricted (Terms of Use, Article 8(6)). |
|---|
The install ID is a random value not linked to any device serial number, name or contact details. Photos, location coordinates, memos and walked tracks are not included in this communication. Expo states that it processes app users' information on behalf of developers as a processor, and Expo's terms of service (Section 3.2) provide that, when it processes personal data as a processor, it applies safeguards under standard contractual clauses. We use Expo on these terms so that Expo processes the information only within the task entrusted to it and protects it to the same level as promised in this policy.
(2) Processing on our behalf in Korea — inquiry email
| Processor | Task |
|---|
| NAVER Corporation | Receiving and storing the Company's email (watsi@naver.com, including mail fetched from contact@watsi.co.kr) |
| Gabia Inc. | Receiving and storing the Company's email (contact@watsi.co.kr) |
(3) Transfer abroad (processing on our behalf) — trail-map images (only if you choose the trail map)
To show you a trail map with hiking paths drawn on it, we have Tracestrack, with which we have a service contract, provide the map images, and the following information is therefore transferred abroad. This is done under PIPA Article 26 (processing on behalf) and Article 28-8(1)(3)(a).
| Recipient and contact | Tracestrack · contact https://www.tracestrack.com/contact/ |
|---|
| Country | The Netherlands |
|---|
| Items transferred | Your IP address, the address of the map images requested (the map area on screen (if you tap "Save the trail map for this route", the area around the planned route), the zoom level, the language of the map labels, and the Company's access key — a value that does not identify you), and basic information sent with any internet request (language setting, operating system and device type, etc.) |
|---|
| When and how | When the trail map is shown (tapping "Draw route" switches the map to the trail map), map images not yet stored on your phone, or stored more than 30 days ago, are requested. When you tap "Save the trail map for this route", map images around that trip's planned route are requested in advance. All requests are sent over an encrypted internet connection (HTTPS). |
|---|
| Task | Delivering trail-map images |
|---|
| Retention | Tracestrack states that it keeps IP addresses, request addresses and language settings for 35 days for billing (Tracestrack privacy policy). |
|---|
| How to refuse, and the effect | Nothing is sent if you do not choose the trail map (standard or satellite map) and do not use "Draw route". Unless you tap "Save the trail map for this route", map images around a route outside the area shown on the map screen are not requested in advance. Nothing is sent if you turn off your internet connection either; in that case only the trail-map images already stored on your phone are shown. You can keep using photos, locations, memos and walk recording. |
|---|
Photos, lists of entry coordinates, memos and walked tracks, and the coordinate list of a planned route (imported or drawn yourself), are not included in this communication. However, if you tap "Save the trail map for this route", the map images requested reveal the area around that route.
6. Disclosure to third parties
We do not provide the personal information in Section 1 to third parties. Only where a law specifically requires it (for example, a request under a warrant issued by a court), or where it is clearly necessary to protect the life, physical safety or property of you or another person from imminent danger, do we provide it, and then only to the extent allowed by PIPA Articles 17 and 18. What the Google Maps component built into the app sends directly to Google is described in Section 4(1), and what goes directly to Apple when you choose the trail map on iPhone is described in Section 4(4). Sending requests to Tracestrack for trail-map images is processing on our behalf, not disclosure to a third party (Section 5(3)).
7. Deletion
- We delete personal information without delay when its retention period ends or its purpose has been achieved.
- Information that must be kept by law (the basis, items and periods are in the table in Section 1) is moved to a separate mailbox or folder so that it is not mixed with other inquiries.
- Procedure: the privacy officer regularly selects inquiry emails whose retention period has passed and deletes them. Sales records in the app stores are deleted from the store accounts when their retention period ends, or, where they cannot be deleted, are no longer viewed.
- Method: emails are deleted from the mailbox and the trash, and electronic files are deleted in a way that cannot be recovered.
8. Children
The Service is not directed at children under 14, and we do not knowingly collect personal information from children under 14. If, while handling an inquiry, we learn that information belongs to a child under 14, we delete it without delay unless the law requires us to keep it.
9. Your rights and how to exercise them
How to ask for deletion
(1) Records in the app (photo links, locations, memos, walked tracks) can be deleted directly in the app (tap "Reset" on the trip list to delete them all at once). They are also deleted when you delete the app.
(2) For information we process (Section 1), email a deletion request to contact@watsi.co.kr; we will act on it within 10 days and tell you the result. Information that must be kept by law is deleted after the period in the table in Section 1.
- You can view and delete the records in the app yourself. Because we do not hold these records, we cannot view or delete them for you.
- For the personal information we process (Section 1), you may at any time ask to access, correct or delete it, or to stop processing it. If you contact us at the details in Section 13, we will act within 10 days and tell you the result. Where the law allows us to postpone access or not to comply, we will tell you the reason and how to object within 10 days.
- If you make a request through an agent, please submit a power of attorney with it (in Korea, Form No. 11 attached to the Notice on Methods of Processing Personal Information).
- The rights of a child under 14 are exercised by the legal representative; a minor aged 14 or older may exercise them directly or through the legal representative. We check that the person making the request is the person concerned or a proper representative.
- While information must be kept by law, deletion requests may be limited during that period.
- You can withdraw your consent to the location, camera, photo and notification permissions at any time in your phone's settings (Section 3).
10. Security
- Only the privacy officer can access the personal information we process.
- Records in the app are not stored on any server of ours, so we cannot access them.
- App update checks use an encrypted connection (HTTPS).
- Inquiry emails and sales records are viewed in password-protected company accounts, and we do not download and keep sales reports as files.
11. Automatic collection
The Service does not use cookies, does not read or use advertising identifiers, and has no advertising or behavioral-analytics tools added. However, the following two create a random identifier on your phone and send it to outside servers.
- The install ID for app update checks (Expo) (Section 5(1)): a new one is created if you delete and reinstall the app or clear its data (if you restore from a phone backup, the previous ID may carry over). Expo counts update-check requests and shows us statistics such as the number of installs.
- The pseudonymous identifier of the Google Maps component (Section 4(1)): handled under Google's policies.
Neither is sent if you turn off your internet connection.
12. Information we do not process
We do not process sensitive information (such as health or beliefs, as defined by law), unique identification information (such as resident registration numbers) or pseudonymized information, and we make no decisions that affect you based solely on automated processing without human involvement.
13. Privacy officer and where to send requests
| Privacy officer | Kunwoo Kim (김건우), Representative |
|---|
| Phone | +82-2-332-8792 (Korean only — for other languages, please email us at contact@watsi.co.kr) |
|---|
| Fax | +82-2-332-8799 |
|---|
| Email | contact@watsi.co.kr (mail sent to our former address, watsi@naver.com, still reaches us) |
|---|
| Address | 1506, Seogyo Tower, 133 Yanghwa-ro, Mapo-gu, Seoul 04032, Republic of Korea |
|---|
Requests to access, correct, delete or stop processing personal information, and questions and complaints about personal information, are also received at the contact details above.
14. Remedies
If you need advice or a remedy for an infringement of your personal information, please first contact the privacy officer in Section 13. You may also contact the following bodies in Korea (the phone numbers work only within Korea).
- Personal Information Dispute Mediation Committee: 1833-6972 (in Korea) · www.kopico.go.kr
- Personal Information Infringement Report Center: 118 (in Korea) · privacy.kisa.or.kr
- Korean National Police Agency: 182 (in Korea) · ecrm.police.go.kr
If you live outside Korea, you can also contact the authority in your country (Section 16).
15. Changes to this policy
- This English version applies from November 10, 2026. The Korean policy has applied since September 18, 2026, with amendments applying from October 26, 2026, November 2, 2026 and November 10, 2026 (what changed, in Korean · earlier versions, in Korean: effective September 18, 2026 · effective October 26, 2026 · effective November 2, 2026).
- Before we change important matters such as the items processed, the purposes, or transfers abroad (at the latest on the day of the change), we post a side-by-side comparison of the old and new wording on this page, and we also announce it inside the app when we update the app.
- Previous versions of this policy, with the periods in which they applied, remain available on this page.
- Parts about subscription payments and the free trial (the lines about sales records and payment in the Summary, the rows "Handling requests to withdraw …" and "Settling sales, filing taxes …" in the table in Section 1, the free-trial start date and the last-checked subscription status in Section 2, the subscription check in Section 4(2), and the "after 14 days without internet" notes in Sections 4(1) and 5(1)) apply from the day a version of the Service that includes the subscription feature is released, as set out in paragraph 2 of the Supplementary Provisions of the Terms of Use. Until then, the Company does not sell subscriptions and does not process information related to them.
- Parts about the trail map (the trail-map sentences in the Summary and Sections 1, 3, 4(4), 5(3) and 6, and the trail-map images in Section 2) apply from the day you can choose the trail map in the Service. Until then, publicly released versions of the app (excluding the Company's test versions) do not request map images from Tracestrack.
- Parts about "Save the trail map for this route" and "Draw route" (the sentences about these two features in the change notice at the top, the Summary and Sections 1, 2, 3, 4, 5(3) and 16) and the deletion, when you open the app, of trail-map images downloaded more than 30 days ago (Section 2) apply from the later of the effective date of this policy and the day a version of the Service including the feature concerned is first released. Until then, publicly released versions of the app (excluding the Company's test versions) do not include "Draw route", do not request map images around a route in advance, and do not delete map images older than 30 days but download them again when online.
16. Additional information for users outside Korea
This section adds information that the laws of some countries require. It does not reduce any protection in Sections 1 to 15.
16-1. Users in the EU/EEA and the United Kingdom (GDPR and UK GDPR)
| Controller | WATSI (Representative: Kunwoo Kim) · 1506, Seogyo Tower, 133 Yanghwa-ro, Mapo-gu, Seoul 04032, Republic of Korea · contact@watsi.co.kr. The privacy officer in Section 13 is the person required by Korean law; we have not appointed a data protection officer under the GDPR. |
|---|
Purposes and legal bases
| Processing (Section 1) | Legal basis |
|---|
| Handling withdrawal, refund, cancellation and minor-rescission requests | Performance of a contract (Article 6(1)(b)); our legitimate interest in meeting the record-keeping duties of Korean consumer law (Article 6(1)(f)) |
| Handling complaints and disputes | Our legitimate interest in resolving complaints and disputes and meeting Korean legal duties (Article 6(1)(f)) |
| Answering other inquiries | Performance of a contract or steps you ask for before one (Article 6(1)(b)); otherwise our legitimate interest in answering you (Article 6(1)(f)) |
| Sales records from the app stores | Performance of a contract (Article 6(1)(b)); our legitimate interest in settling sales and meeting Korean tax-law duties (Article 6(1)(f)) |
| App update checks (Expo) | Our legitimate interest in delivering bug fixes and keeping the app secure (Article 6(1)(f)) |
| Trail-map images (Tracestrack), only if you choose the trail map | Performance of a contract — showing the map you chose (Article 6(1)(b)) |
- Recipients: processors acting for us — 650 Industries, Inc. (Expo, United States), Tracestrack (the Netherlands), NAVER Corporation and Gabia Inc. (Korea, for email). Companies that receive information directly as independent controllers — Google LLC (maps, Google Play) and Apple Inc. (App Store; base map under the trail map on iPhone) (Section 4).
- Transfers outside the EU/EEA and UK: we are located in the Republic of Korea, which the European Commission has recognized as providing an adequate level of protection (Commission Implementing Decision (EU) 2022/254), as has the United Kingdom (The Data Protection (Adequacy) (Republic of Korea) Regulations 2022). For Expo in the United States, Expo's terms of service (Section 3.2) provide for standard contractual clauses. Tracestrack is located in the EU.
- Retention: as set out in Section 1 and Section 5.
- Your rights: you may ask us for access to, correction or deletion of your personal information, restriction of processing, and data portability, and you may object at any time to processing based on our legitimate interests. Send requests to the email above. We will reply within 10 days where we can, and in any case within one month (this may be extended by two further months for complex requests, in which case we will tell you why). Because we do not hold the records in the app, we cannot identify you from them; please tell us what you want us to look for (for example, the order number).
- Complaints: you may complain to the data protection supervisory authority in the EU/EEA country where you live or work, or where the alleged infringement took place. In the United Kingdom, you may complain to the Information Commissioner's Office (ico.org.uk); you may also complain to us first, and we will acknowledge your complaint within 30 days.
- Whether you must provide information: you do not have to contact us, but without your contact details we cannot reply to you or pay a refund to you. The technical information in Sections 4 and 5 is needed for map display, app updates and subscription checks; you can avoid sending it by turning off your internet connection, with the effects described there.
- Information stored on your device: the app stores on your phone a random install ID used only to check for app updates, and copies of map images used only to show the map you asked for. They are not used for advertising or tracking.
- We make no decisions based solely on automated processing (Section 12).
16-2. Users in Japan
- Business operator: WATSI · Representative: Kunwoo Kim · 1506, Seogyo Tower, 133 Yanghwa-ro, Mapo-gu, Seoul 04032, Republic of Korea.
- Purposes of use: as set out in Section 1.
- Handling in a foreign country: we handle personal information in the Republic of Korea. Korea has the Personal Information Protection Act, supervised by the Personal Information Protection Commission. Inquiry emails are stored by NAVER Corporation and Gabia Inc., both in Korea. Expo (United States, app update checks) and Tracestrack (the Netherlands, if you choose the trail map), which process information on our behalf, also handle it in those countries (Section 5). Our security measures are described in Section 10.
- Requests for disclosure, correction, suspension of use and similar: please email us (Section 13). There is no fee.
- Complaints and questions: please email us (Section 13).
- Information sent from your phone to outside parties:
| Sent to | Information | Purpose |
|---|
| Google LLC | Request information for the map, identifiers of the map component, IP address, map area on screen, etc. (Section 4(1)) | Showing maps |
| 650 Industries, Inc. (Expo) | Install ID, operating system type, app version information, error message of a failed launch, IP address (Section 5(1)) | Checking for and delivering app updates |
| Tracestrack (only if you choose the trail map) | IP address, address of the map images (map area being viewed or, if you tap "Save the trail map for this route", the area around the planned route; zoom level; label language), language setting, etc. (Section 5(3)) | Delivering trail-map images |
| Apple Inc. (only for the trail map on iPhone) | Request information for the map, IP address, map area on screen (Section 4(4)) | Showing the base map |
| Google LLC (Google Play) or Apple Inc. (App Store) | Information needed to check purchases and subscriptions (Section 4(2)) | Payment and subscription checks |
16-3. Users in the United States
- We do not sell your personal information, and we do not share it for cross-context behavioral advertising.
- Do Not Track: we do not track your activity across other websites or online services, and we use no advertising or analytics tools, so a "Do Not Track" signal does not change how we process information. Other companies may receive information directly through the app: the Google Maps component sends information to Google (Section 4(1)), and the other companies in Section 4 receive what is described there.
- To review or correct information we hold about you, see Section 9. We announce changes to this policy as described in Section 15, with the effective date shown at the top.
- The Service is not directed at children under 13, and we do not knowingly collect personal information from children under 13.
16-4. Other countries
If the law of your country gives you further rights over your personal information, you can exercise them by contacting us (Section 13).
WATSI (왓시) · Representative Kunwoo Kim · Korean business registration no. 678-34-00813 · Mail-order business report no. 2026-Seoul Mapo-2141 · Terms of Use