Europe Privacy Policy Addendum

Effective: March 6, 2025

PeekabooLabs Co., Ltd.’ main Privacy Policy outlines how we collect and use your personal information. This Europe Privacy Policy Addendum is intended for individuals residing in the European Economic Area (EEA), the United Kingdom (UK), and Switzerland (collectively, “Europe”). It provides additional information specific to Europe that supplements our main Privacy Policy.

1. Data Controller

For individuals in Europe, PeekabooLabs Co., Ltd., with its registered office at 13, Jongam-ro, Seongbuk-gu, Seoul, Republic of Korea, Seoul, 02841, is the controller of your personal information as described in this Addendum.

2. Legal Basis

We process your personal information on various legal bases, including:

  • To provide and maintain our Service:
    We process account information and device performance data (e.g., battery status, device type) necessary to deliver and maintain Ollie—a private AI solution for grown-ups that performs AI computations on-device. This processing is required to perform our contract with you.

  • To improve and develop our Service:
    We use anonymized technical data (such as performance metrics) to analyze and enhance our Service. This processing is based on our legitimate interests.

  • For customer support:
    When you contact us, we process your contact information to respond to your inquiries. This is necessary to perform our contract and serves our legitimate business interests.

  • For compliance with legal obligations:
    We process personal information as required by law, regulation, or to secure evidence for dispute resolution.

  • For business purposes:
    We may use personal information to analyze usage trends, develop new product features, and support our business activities—all based on our legitimate interests.

We do not intend to collect sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion, health, biometric data, criminal background, or trade union membership) and request that you refrain from providing such information.

When processing your personal information on the basis of legitimate interests, we conduct a balancing test to ensure that our interests do not override your rights. You may request further details regarding this balancing test by contacting us.

3. Processing Purposes and Data Categories

We process the following categories of personal information for specific purposes:

  • To provide and maintain our Service:
    We process identifiers (e.g., your email address and username) and device performance data to deliver Ollie’s functionality, maintain your account, and improve the Service. Because Ollie performs AI operations on-device, no chat data or sensitive personal information is collected.

  • To improve and develop our Service:
    We process anonymized technical data (e.g., battery status, device type) to analyze usage patterns, monitor technical errors, and enhance service stability.

  • For customer support and inquiry handling:
    We process your contact details when you submit inquiries, ensuring efficient customer support.

  • To ensure security and integrity:
    We process personal information to detect, prevent, and investigate fraud or unauthorized activities, thereby safeguarding our systems and the Service.

  • For legal compliance:
    We process personal information as necessary to comply with applicable legal obligations and regulations.

  • For business purposes:
    We process personal information for data analysis, identifying usage trends, and improving our product offerings, based on our legitimate interests.

4. Service Providers and Data Processing

We process your personal data primarily in the Republic of Korea and, if necessary, may transfer it to other countries (including the United States) for operational purposes. When transferring data outside Europe, we ensure appropriate safeguards are in place—relying on the European Commission’s adequacy decision regarding South Korea or on standard contractual clauses where applicable. We engage service providers for functions such as customer support, analytics, and payment processing; these providers are bound by contractual obligations to protect your data.

5. Your Rights

As a user in Europe, you have the following rights regarding your personal information:

  • The right to access, correct, update, or request deletion of your personal information.

  • The right to restrict or object to the processing of your personal information based on our legitimate interests.

  • The right to data portability.

  • The right to withdraw your consent at any time (this will not affect the lawfulness of processing prior to withdrawal).

  • The right to file a complaint with your local supervisory authority if you believe your rights have been violated.

To exercise these rights, please contact us at contact@peekaboolabs.ai. In some cases, additional information may be required to verify your identity before we act on your request.

6. Data Transfers

Your personal information may be processed and stored in the Republic of Korea or other countries. When transferring data outside of Europe, we rely on the European Commission’s adequacy decision regarding South Korea or standard contractual clauses to ensure an adequate level of protection.

7. Changes to This Addendum

We may update this Europe Privacy Policy Addendum from time to time. The updated version, along with the effective date, will be posted on our website. By continuing to use our Service after changes are posted, you agree to the updated terms.

8. Contact Information

If you have any questions or concerns regarding this Europe Privacy Policy Addendum or our processing of your personal information, please contact us at:

  • Company: PeekabooLabs Co., Ltd.

  • Address: 13, Jongam-ro, Seongbuk-gu, Seoul, Republic of Korea, Seoul, 02841

  • Email: contact@peekaboolabs.ai