Privacy Policy — 돈계산 (MoneyCalc)
Effective date: 30 May 2026
This Privacy Policy describes how personal data is processed in the mobile application “돈계산 - 모임 정산을 쉽고 빠르게” (MoneyCalc) (the “App”), developed by Jitae Kim (“we”, “us”). It is written to satisfy the requirements of the EU General Data Protection Regulation (GDPR) as a global baseline, with a dedicated section for California residents (CCPA/CPRA).
1. Data Controller
Jitae Kim Email: wlxo0401@gmail.com
(No Data Protection Officer is appointed; the controller may be contacted directly at the email above.)
2. Categories of Personal Data
The App does not require an account.
2-1. Data you enter into the App (stored on-device only)
- Group names, member names, and any labels you enter
- Settlement records: item names, amounts, payer info, dates, memos
This data is stored only in on-device SwiftData. It is never transmitted to any server we operate. iCloud (CloudKit) synchronization is intentionally disabled, so your settlement data does not leave your device. Widget data is shared within the same device via App Group and never leaves the device.
2-2. Data collected automatically (by third-party SDKs / system)
The data below is not collected or stored directly by us; it is collected and processed automatically by the third-party SDKs integrated into the App, or by the Apple system, each for its own purpose. We do not store this data in a directly identifiable form and only see aggregated/anonymized results.
| Category | Examples | Collected by |
|---|---|---|
| Device identifiers | IDFV | Firebase Analytics, Google AdMob |
| Advertising identifier | IDFA (only when you consent via App Tracking Transparency) | Google AdMob |
| Device & environment | OS version, device model, app version, locale | Firebase Analytics, Google AdMob |
| Approximate location | Country/region derived from IP address | Firebase Analytics, Google AdMob |
| Usage data | In-app events, screens viewed, feature interactions | Firebase Analytics |
| Advertising data | Ad impressions, clicks | Google AdMob |
| Advertising attribution | App install/conversion attribution | Apple SKAdNetwork |
| Diagnostic / crash data | System-level crash logs and performance metrics, only when you have enabled iOS Settings → Privacy & Security → Analytics & Improvements → “Share with App Developers” | Apple (App Store Connect) |
The App does not use a separate crash-reporting SDK (e.g., Firebase Crashlytics). Crash/diagnostic data is collected only at the Apple system level on an opt-in basis, as described above.
2-3. External Communication (App Version Check)
To inform you of the latest version, the App queries Apple’s public iTunes Lookup API (itunes.apple.com), sending only the app identifier (bundleId). No personally identifying information is included in this request.
3. Purposes and Legal Bases (Art. 6 GDPR)
| Purpose | Legal basis |
|---|---|
| Providing core features (groups, members, settlement, widget) | Art. 6(1)(b) — performance of a contract |
| Analytics & service improvement (Firebase Analytics) | Art. 6(1)(f) — legitimate interest |
| Personalized advertising (AdMob, IDFA) | Art. 6(1)(a) — consent (via ATT) |
| Non-personalized advertising | Art. 6(1)(f) — legitimate interest |
| Obtaining & managing advertising/tracking consent (Google UMP) | Art. 6(1)(c) — legal obligation / Art. 6(1)(f) — legitimate interest |
| Crash/diagnostic reporting (Apple system level, opt-in) | Art. 6(1)(a) — consent |
| Legal compliance | Art. 6(1)(c) — legal obligation |
4. Recipients / Processors
We do not share the data you enter into the App with any third party. Only the automatically collected data above is processed by the following providers:
| Processor | Purpose | Country |
|---|---|---|
| Google LLC (Firebase Analytics) | Analytics | United States |
| Google LLC (AdMob / UMP) | Advertising; advertising/tracking consent management | United States |
| Apple Inc. | App distribution, SKAdNetwork attribution, system crash reporting | United States |
Provider privacy practices:
- Google: https://policies.google.com/privacy
- Google Ads: https://policies.google.com/technologies/ads
- Apple: https://www.apple.com/legal/privacy/
5. International Transfers
Personal data may be transferred to the United States via our processors. Such transfers rely on the EU-US Data Privacy Framework where applicable, and/or Standard Contractual Clauses (SCCs).
6. Retention
| Item | Retention |
|---|---|
| Data you entered into the App | On-device only — retained until you delete it in the App or uninstall the App |
| Analytics data | up to 14 months |
| Advertising identifiers / data | per Google AdMob and Apple SKAdNetwork policies |
| Crash / diagnostic data | per Apple App Store Connect policies |
7. Your Rights under GDPR (Arts. 15–22)
You have the right to:
- Access (Art. 15)
- Rectification (Art. 16) — you can directly edit or delete entries within the App
- Erasure (Art. 17) — deleting the App removes all on-device data
- Restriction of processing (Art. 18)
- Data portability (Art. 20)
- Object to processing based on legitimate interests (Art. 21)
- Withdraw consent at any time (without affecting prior lawful processing)
- Lodge a complaint with your local supervisory authority
To exercise any right, contact wlxo0401@gmail.com.
8. California Residents (CCPA / CPRA)
If you are a California resident, you have the right to:
- Know what personal information is collected and how it is used
- Delete personal information collected from you
- Correct inaccurate personal information
- Opt out of “sharing” of personal information for cross-context behavioral advertising (under CPRA, advertising identifiers passed to AdMob may qualify as “sharing”)
- Limit the use of sensitive personal information (we do not collect sensitive PI as defined by CPRA)
- Non-discrimination for exercising your rights
We do not “sell” personal information for monetary consideration. To opt out of tracking-based advertising, decline the ATT prompt or disable tracking in iOS Settings.
To submit a CCPA/CPRA request, email wlxo0401@gmail.com.
9. Withdrawing Tracking / Diagnostic Consent
- iOS Settings → Privacy & Security → Tracking → MoneyCalc (toggle off)
- In-app Google UMP consent form — when prompted on launch, you can change your advertising/tracking consent choices
- iOS Settings → Privacy & Security → Apple Advertising → reset advertising identifier
- iOS Settings → Privacy & Security → Analytics & Improvements → Share with App Developers (toggle off)
10. In-App Feedback Email
The App includes a feedback feature that opens the Apple Mail app for you to compose a message. The email is sent directly through the Apple Mail app and does not pass through any server we operate. The content of the email and any personal information it contains are determined entirely by you; once sent, it is handled by Apple’s mail infrastructure and your email provider.
11. Automated Decision-Making
The App does not perform automated decision-making or profiling that produces legal or similarly significant effects under Art. 22 GDPR.
12. Children
The App is not directed to children under 16, and we do not knowingly collect personal data from children under 16 (under 13 in jurisdictions where COPPA applies). If you believe a child has provided us with personal data, contact us and we will delete it.
13. Changes to This Policy
We may update this Privacy Policy from time to time. Material changes will be announced in-app or at the published URL. All prior versions are retained in the same repository, organized by effective date.
14. Contact
Jitae Kim — wlxo0401@gmail.com