SUMTEO · PRIVACY DRAFT
Unreleased Privacy Policy Draft
This notice explains personal-data processing; it is not a bundled consent form.
- Version
- 2026-09-23-public-beta-draft-1
- Last updated
- 2026-09-23
- Effective date
- Not set
- Controller
- 장현정
- Minimum age
- 14 years
Unreleased draft — not effective
This draft cannot take effect for the public beta until active-provider legal details, overseas transfers, retention, and the public effective date are verified.
1. Controller and contact
The controller for 숨터(Sumteo) is 장현정. Privacy questions and rights requests may be sent to sumteo.official@gmail.com.
Sumteo is currently a free beta and does not sell personal information.
2. Data, purpose, basis, and retention
Data needed to create an account is separated from data created only when a user chooses a feature. Contract-based processing and processing based on separate consent are not bundled into one consent.
| Service stage | Data | Purpose | Basis | Retention |
|---|---|---|---|---|
| Account creation and sign-in | Privy user identifier, authentication-method information, embedded-wallet address | Sign-in, account identification and protection, wallet connection | Processing necessary to perform the service contract | Sumteo-held account records: until the account-deletion process completes |
| Profile use | Nickname, character settings, visibility | Profile and world features | Processing necessary to perform the service contract | Until the account-deletion process completes |
| Reading use | Book identifiers, sessions, time, pages, completion, impressions, quotes, and reading list | Save progress and validate progress or rewards | Processing necessary to perform the service contract | Until the account-deletion process completes |
| Quiz use | Answers, scores, results, and ratings | Provide quizzes and validate results or eligibility | Processing necessary to perform the service contract | Until the account-deletion process completes |
| Social use | Friends, follows, public status, interactions, and notifications | Friends, world, and notification features | Processing necessary to perform the service contract | Until the account-deletion process completes |
| Questions and feedback | Message or feedback text and a user-selected image | Respond to the request and improve the service | User-requested response and separate user choice | Until the account-deletion process completes |
| Security and access | Access time, IP address, browser or device information, authentication, API, and security records | Authentication, abuse prevention, incident and security response | Processing needed to deliver and protect the service | Destroyed when the purpose ends, or retained for a period required by law |
3. Automatically generated information
Access time, IP address, browser or device information, and authentication or security records may arise during sign-in and service requests. Sumteo processes them only as needed for authentication, service stability, abuse prevention, and incident response.
4. Optional processing
Feedback and an attached image are processed only when a user submits them. First-party usage analytics is enabled only after a separate optional consent, is off by default, and can be withdrawn in settings without blocking ordinary service use.
AI and mint-related data are processed only if the relevant feature is enabled and the user requests it.
5. Third-party disclosure
Sumteo does not sell personal information. User-directed book search, login, wallet connection, or public-network publication is distinguished from a processor acting on Sumteo's instructions.
No disclosure for an independent third party's own purpose is currently identified, except where law provides a basis or a user separately requests or consents to it.
6. Processing contractors
If Sumteo delegates hosting, data storage, authentication, or another operational task to an external service, the effective final policy identifies the contractor, delegated task, and other information required by law.
7. Overseas transfers
If personal information is transferred overseas, the effective final policy identifies the recipient, country, data, timing and method, purpose, retention, legal basis, and other information required by law.
Overseas processing is not mechanically treated as requiring separate consent; notice or consent is determined under applicable law and the actual relationship.
8. Destruction and account deletion
An in-app deletion request restricts account use and profile display and allows recovery through the same Privy account for 30 days. After recovery ends, a server job attempts to purge Sumteo-held off-chain account data and delete the Privy user.
Account recovery and a privacy deletion request are distinct. Users may separately request deletion in the app or by email. Public-network records, information legally required to remain, or minimum records needed to resolve an unfinished mint may have deletion limits.
9. Blockchain and public networks
Only when minting is enabled and a user requests it may a public wallet, transaction, book or completion information, and selected public content or metadata be submitted to Solana or another public network.
The user must separately confirm the public fields and deletion limits immediately before minting. Public-network information can be copied and may remain beyond account deletion where Sumteo cannot alter or erase it.
10. Cookies and browser storage
Sumteo may use cookies and browser storage for country or market choices, language and screen settings, authentication transitions, offline reading records, and unsent work.
Clearing browser data may remove settings, offline records, or an authentication flow. It does not automatically delete the server account or public-network records.
11. Your rights
Users may request access, correction, deletion, restriction of processing, or withdrawal of consent. Use profile, visibility, analytics, or account-deletion settings, or email sumteo.official@gmail.com.
Minimum identity verification may be requested to protect the user and others. If law limits a request, Sumteo explains the basis and available procedure.
12. Safeguards
Sumteo maintains safeguards implemented for the service, including authentication checks, account-scoped access, protected transmission, request limits, separated secrets, input validation, and restricted operational access.
If an incident is confirmed, Sumteo investigates its scope and effect and takes notices and protective steps required by applicable law.
13. Restriction for children under 14
Sumteo does not accept users under 14 and has no guardian-consent flow. Contact the public email address if information from a child under 14 may have been processed.
14. Privacy officer
Privacy officer: 장현정
Privacy contact: sumteo.official@gmail.com
15. Changes and effective date
Sumteo announces changes and their effective date through an accessible channel. A processing change that legally requires separate consent receives separate consent.
This is an unreleased draft last updated on 2026-09-23. No public effective date has been set; it will be set only after release blockers and final review are complete.