Piboo Privacy Policy

Liouville Labs Inc. (the "Company", "we", "us") has prepared and publishes this Privacy Policy under Article 30 of the Korean Personal Information Protection Act ("PIPA") to protect the personal information of data subjects and to handle related complaints promptly.

The Company is incorporated under the laws of the State of Delaware, United States, and operates Piboo (https://piboo.ai, the "Service"), an AI consultation service about skincare and cosmetics.

1. Purposes of Processing

We process personal information for the purposes below and do not use it for any other purpose. If a purpose changes, we will take the necessary steps, such as obtaining separate consent under Article 18 of PIPA.

• Sign-in and user identification: sign-in with a linked Google account, keeping you signed in, and telling signed-out users apart
• Providing consultations: generating answers to your questions, providing product information that reflects your skin details, and observing skin condition when you have given separate consent and attached a photo
• Keeping and reusing consultation results: consultation history, consultation memory, routine, and shelf (favorites) features
• Issuing and managing share links for consultation results
• Usage management and misuse prevention: daily usage counts, request rate limits, and temporary limits on repeated use unrelated to the Service's purpose
• Operating the Service and checking quality: incident response, checking answer quality, and reviewing cases of misuse
• Handling inquiries and complaints

We do not process personal information to send advertising, and we do not send advertising emails or text messages.

2. Personal Information We Process

We process the following categories of personal information.

Account information (when you sign in with Google)

• Email address, name, Google account identifier, and time of last sign-in
• The URL of your Google profile photo is kept in the sign-in cookie in your browser. We do not store it in our database.

Identifier for signed-out users

• One random user identifier created by your browser. It is sent with Service requests.
• The identifier of the consultation you last opened, a draft of skin details you have not sent yet (it may include whether you are pregnant or nursing), and text you typed on the home page that has not yet been passed to a consultation. The skin details draft and the typed text are sent to our server when you send a consultation message.
• These four items are values kept in the local storage of the browser on your device, and that storage itself is not synchronized with our server (Section 13). The user identifier is sent with requests and stored on our server as the owner marker of your consultations, and the content of the skin details draft and the typed text is stored on our server once you send it as a consultation message.
• If you sign in on the same browser, consultations from your signed-out use may be moved to your account.

Information you enter

• Seven skin details: skin type, skin concerns, ingredients to avoid, current routine, budget, region, and whether you are pregnant or nursing. You can use consultations without entering any of them.
• What you type in consultations, as written
• Photos you attach for a skin observation. We do not store photo files (Section 9).

Information created while you use the Service

• Consultation history: your questions, the AI's answers, screen records of the consultation, and a consultation title (created from your first question; it may contain part of that question as written)
• Photo observation findings (fixed categories and short descriptive sentences)
• Consultation memory items (one-sentence notes drawn from your consultations), routine records, and shelf records
• Consent records: age self-declaration (time, wording version, age threshold, and display language), consent to photo observation (time, wording version, adult age threshold, and display language), consent to pregnancy or nursing information (time and wording version), and consent to saving your routine (time and wording version). When you withdraw a consent, its record is deleted.
• Daily usage (number of messages, tokens, and photos), request rate records, and usage limit records
• Share link tokens and a copy of the consultation as of when the link was issued

Our Service code has no path that stores IP addresses, advertising identifiers, or MAC addresses. Records created by our hosting provider are described in Section 13.

3. Sensitive Information

The two kinds of information below concern health and may be sensitive information under Article 23 of PIPA. We process them only with your separate consent, given apart from consent to other processing.

• If you do not give this consent, you can still use consultations, without photo observation and without the pregnancy or nursing item being taken into account.
• You can withdraw consent at any time. You can withdraw photo observation consent on the screen where you attach a photo and pregnancy or nursing consent on the screen where you enter your skin details, or you can write to contact@piboo.ai. On withdrawal we delete the consent record on our server, and if you withdraw pregnancy or nursing consent, we also delete that item where it is stored in your account and your consultations.
• Without a consent record, our server does not accept a message with a photo attached and does not store a pregnancy or nursing value sent with a message. Without a valid consent, a previously stored pregnancy or nursing value is not used to generate answers or to write consultation memory and is not sent to our AI model provider. This applies to both new and ongoing consultations. The stored value itself remains until you clear it or delete your account.
• Health-related content that you type yourself in a consultation (for example, that you are pregnant, a skin condition, or medication you take) is not covered by the separate consent steps above. It is handled as consultation content under Sections 2 and 5.
• Share links do not include your skin details or photo observation cards. However, anything you wrote in your questions, or that an answer mentions, can appear in the shared content (Section 10).
• We instruct the AI that writes consultation memory not to record medical diagnoses, health conditions, or medications. This instruction alone cannot guarantee complete exclusion, so please delete any memory item you do not want kept.

4. How and From Where We Collect Information

• When you enter it yourself on the Service
• From Google (Google LLC) through Google sign-in. We receive your email address, name, profile photo URL, whether your email is verified, and your Google account identifier. We refuse sign-in with a Google account whose email is not verified.
• Automatically, as you use the Service

We do not receive your personal information from any third party other than Google.

5. Retention Periods

When you delete your account, we immediately destroy all of the information above linked to that account, regardless of the periods above. There is no grace period.

Consultations from signed-out use are not linked to an account, so they are kept until you delete them on the Service from that device.

To improve our product information, we record some product search terms run during consultations, without any user identifier. These records are not linked to accounts and are not removed by account deletion.

If a law requires us to keep personal information, we keep it for the period the law sets.

6. Provision to Third Parties

We process personal information only within the scope in Section 1 and provide it to third parties only where Articles 17 and 18 of PIPA allow, such as with your consent or under a specific legal provision. We currently do not provide personal information to third parties.

Processing we entrust to service providers is described in Section 7, and share links that you issue yourself in Section 10.

7. Service Providers (Entrusted Processing)

We entrust the following processing to service providers in order to provide the Service.

Entrustment lasts until the contract ends or the Service ends. Under Article 26 of PIPA, we manage and supervise our service providers to make sure they handle personal information safely. If a provider or task changes, we will update this Policy.

We do not use analytics or advertising tracking tools, so there are no service providers for those purposes.

During a consultation the AI may open a public web page directly. In that case our server requests only the page address and does not send any information identifying you.

8. International Transfers

The Company and all of its service providers are US companies, so your personal information is transferred abroad as follows. Transfers happen over the network whenever you use the Service.

Fireworks states that it does not use prompts or API inputs to train its models without the user's explicit opt in.

These transfers are necessary to perform our contract with you to provide the Service. You may refuse international transfer by writing to contact@piboo.ai. Because we cannot provide the Service without these transfers, refusing means you would need to stop using the Service, for example by deleting your account.

9. Photos

• Photo observation happens only with the separate consent in Section 3.
• We do not store photo files. A photo is used for a single AI request for the observation and is discarded from server memory when that request ends. What remains is a marker that a photo was attached and the findings.
• For the observation, photo data is sent to Fireworks AI (Section 7). That request does not include the text you typed.
• Your browser re-encodes the photo before sending it, which removes EXIF data such as location, device, and time taken.
• The daily photo limit is 10 for signed-in users and 2 for signed-out users.
• Photo observation is for adults. When you consent to photo observation, we ask you to confirm for yourself that you are 19 or older (when using the Service in Korean) or 18 or older (in any other language), and we keep that age threshold and display language in the consent record. If the person in a photo appears to be a minor, we do not perform the observation.

10. Share Links

• A share link is created only when you ask for one.
• The link contains a random token, and anyone who knows the address can view the content. Please send the link only to people you want to see it.
• Shared content consists of your questions and the answers as of when the link was issued, questions asked during the consultation with the answers you chose, recommended product information, and the results of web searches run during the consultation (title, address, and snippet). What you wrote in your questions is shown as written. Your skin details, photo observation cards, and account information are not included.
• If a viewer asks to read it in another language, the content is translated by AI and the translation is kept with the shared copy.
• You can delete share links one at a time or all at once. A deleted link can no longer be viewed. Deleting a consultation also deletes the shared copies made from it.

11. Destruction of Personal Information

• Information with a set retention period is deleted automatically from our database when the period ends.
• Information you delete using the Service's delete functions is deleted immediately in a way that cannot be recovered. Deleting a consultation also deletes its shared copies and its memory links.
• When you delete your account, we immediately delete, in a way that cannot be recovered, that account's account information, skin details, consent records, consultation history, share links and copies, consultation memory, routine, shelf, and usage and limit records from our database. There is no grace period, and deletion cannot be undone. If a consultation is in progress, we first request that it stop; until it has stopped we do not proceed with deletion and ask you to try again shortly.
• If you sign in again with the same Google account after deletion, a new empty account is created and earlier information is not restored. We do not restrict re-registration and keep no information for that purpose.
• Account deletion applies to information in our database. Sign-in records held by Google, access records created by our hosting provider, and backup copies kept by our database provider on its own schedule are handled under each provider's policies.
• We do not keep personal information on paper.

12. Your Rights and How to Exercise Them

You may at any time ask us to give you access to, correct, delete, or stop processing your personal information, and you may withdraw consent.

What you can do yourself on the Service

• View, edit, and clear your skin details
• Delete consultations
• Delete share links (one at a time or all)
• Delete consultation memory items (one at a time or all)
• Delete your routine and shelf
• Delete your account: "Delete account" in Settings

What you can request by email or post

For requests the Service has no function for (such as access to the information we hold, correction, stopping processing, withdrawing consent, or refusing international transfer), and for account deletion requests, please contact us below. We receive requests and act on them without delay, as provided in Article 41 of the PIPA Enforcement Decree.

• Email: contact@piboo.ai
• Post: 455 Market St Ste 1940 PMB 213430, San Francisco, CA 94105, United States

To confirm that a request comes from the data subject or an authorized representative, we may ask for a reply from the email address of the account concerned or take similar steps.

A legal guardian of a child under 14 may exercise these rights for the child's personal information.

We do not currently provide a transfer function under the right to request transmission of personal information in Article 35-2 of PIPA. If we become subject to that obligation, we will add the transfer method to this Policy.

13. Cookies and Similar Technologies

Cookies

• One sign-in cookie (valid for 30 days), used only to keep you signed in.
• One language cookie (valid for 1 year), which remembers the display language you chose.
• Security cookies used for sign-in. The request forgery protection cookie and the cookie holding the address to return to after sign-in are session cookies that are removed when you close the browser, and the Google sign-in verification cookies expire within 15 minutes.

Local storage

We keep the following items in the local storage of the browser on your device. These values are stored in your browser, not on our server. How the identifier and the content you send are stored on our server is described in Sections 2 and 5.

• kb.user_id: a random identifier that tells signed-out users apart
• kb.last_thread: the identifier of the consultation you last opened, used to show it again when you return
• kb.profile_draft: a draft of skin details you have not sent yet. It may include whether you are pregnant or nursing. When you send a consultation message, its content is sent to our server and the draft is emptied.
• kb.pending_message: text you typed on the home page. The consultation screen deletes it as soon as it reads it, and a value older than 10 minutes is not used.
• kb.consents: markers that the age confirmation, photo observation consent, and pregnancy or nursing consent have already been given in this browser (wording version, time, and for the age confirmation and photo observation consent the age threshold and display language). The authoritative consent records are on our server. These markers are kept separately for each signed-in account and each signed-out identifier, so a confirmation made while signed out is asked again for your account after you sign in. If you answer that you are under the age threshold, that marker stays only here and is not sent to our server.

Markers used for screen behavior are kept in the same storage as well: kb.offtopic_until (the time a temporary usage limit ends), and kb.memory_notice and kb.shelf_reaction_notice (markers that a notice has already been shown). A device that used an earlier version of the Service may still hold kb.adopted_for (the identifier of the Google account that signed in); we no longer write this value or use it for any decision.

Clearing site data in your browser settings removes all of these values. When you delete your account, we also remove kb.profile_draft and kb.pending_message on that device. The other values remain in the browser and can be removed by clearing site data.

What we do not use

We do not use analytics tools, advertising tracking pixels, or tools that collect behavioral data for targeted advertising.

Blog view counts

We count blog article views only per article and language, and store no user identifier. A marker that prevents counting the same tab twice is kept in the browser's session storage and disappears when you close the tab.

How to refuse

You can delete or block cookies and site data in your browser settings.

• Chrome: Settings > Privacy and security > Third-party cookies or Site data
• Safari: Settings > Privacy > Manage Website Data
• Edge: Settings > Cookies and site permissions
• Firefox: Settings > Privacy & Security > Cookies and Site Data

If you block the sign-in cookie, you cannot sign in. If you clear site data, you will not be able to find consultations from your signed-out use again.

Records kept by our hosting provider

Our Service code does not store your IP address. Our hosting provider (Vercel) creates runtime records of the Service, which include the request path, browser information (User-Agent), and time, together with consultation processing metrics we log (identifiers, processing time, token counts, and similar). We keep the text of your questions and answers out of these metrics. However, if a search of our product data fails with an error, the search term written by the AI may remain in the error record, and that term may include words you typed.

14. Security Measures

We take the following measures.

• Encryption in transit: the Service is provided over HTTPS only.
• Access control: only operators signed in within the last 24 hours with an account on a domain we designate can open the operator console. For running the Service, checking quality, and handling misuse, operators can see users' email addresses, usage, consultation lists, and consultation content there.
• Minimal logging: we keep the text of questions and answers out of runtime records. The exception is the search error record described in Section 13.
• Photo protection: photos are not stored, and EXIF data is removed before sending.
• Limited sharing: shared copies exclude skin details, photo observation cards, and account information.

15. How AI Consultations and Recommendations Are Produced

• Answers and product recommendations are generated by AI language models, without a person reviewing each one.
• Inputs used to generate answers: what you type, your skin details, photo findings if you consented, consultation memory items, the product and ingredient data we maintain, and web search results where needed.
• Recommendations are information for your reference. They do not oblige you to buy anything and are not decisions that set your rights or obligations. They are not medical diagnoses; if you suspect a skin condition, please see a dermatologist.
• For an explanation of an answer or recommendation, or to object to one, write to contact@piboo.ai and we will reply.

16. Age Requirement and Children

• The Service is for people aged 14 or older when used in Korean, and 16 or older when used in any other language. Before a consultation starts, we ask you to confirm for yourself that you meet this age, and if you answer that you do not, you cannot use consultations. Our server does not accept consultation messages without an age confirmation record.
• We do not knowingly collect personal information from children under 14. If we learn that we have collected personal information from a child under 14, we destroy it without delay. A legal guardian may ask us to check and delete it at contact@piboo.ai.
• Photo observation is for adults. When you consent to photo observation, we ask you to confirm for yourself that you are 19 or older (when using the Service in Korean) or 18 or older (in any other language), and we keep that age threshold and display language in the consent record. If the person in a photo appears to be a minor, we do not perform the observation.

17. Privacy Contact and Complaints

We have a privacy contact who oversees personal information processing and handles data subjects' complaints and remedies.

• Privacy contact: contact@piboo.ai
• Registered address: 1209 N. Orange St, Wilmington, DE 19801, United States
• Mailing address: 455 Market St Ste 1940 PMB 213430, San Francisco, CA 94105, United States

We accept inquiries and complaints by email or post and reply without delay.

18. Domestic Representative in Korea

The Company has no address or place of business in Korea. If we become obliged to designate a domestic representative under PIPA, we will do so and publish the representative's name, address, telephone number, and email address in this Policy.

19. Remedies for Infringement (Korea)

To seek a remedy for infringement of personal information, you may apply for dispute resolution or counseling to the following bodies in Korea.

• Personal Information Dispute Mediation Committee: 1833-6972 (www.kopico.go.kr)
• Personal Information Infringement Report Center: 118 (privacy.kisa.or.kr)
• Supreme Prosecutors' Office: 1301 (www.spo.go.kr)
• Korean National Police Agency: 182 (ecrm.police.go.kr)

20. Users in the EEA, the UK, and Switzerland

This section applies if the EU General Data Protection Regulation (GDPR), the UK GDPR, or the Swiss data protection law applies to our processing of your personal information. The controller is Liouville Labs Inc. (contact details in Section 17).

Legal bases (GDPR Article 6)

You do not have to give us your skin details or photos. Without account information we cannot provide a signed-in account, but you can still use the Service signed out.

Special category data (Article 9)

Photo observation findings and the pregnancy or nursing item are health data. We process them only with your explicit consent, which you can withdraw at any time without affecting the lawfulness of processing before withdrawal.

Your rights

You have the right to access your personal data, to rectification, to erasure, to restriction of processing, to data portability, to object to processing based on legitimate interests, and to withdraw consent at any time. You can exercise these rights through the Service functions in Section 12 or by writing to contact@piboo.ai. We respond within one month, which may be extended by two further months for complex requests, in which case we will tell you.

Automated decision-making

We do not make decisions based solely on automated processing that produce legal effects concerning you or similarly significantly affect you (Article 22). AI answers and recommendations are information for your reference (Section 15).

International transfers

We are a company located in the United States, and our service providers are located in the United States (Section 8). Your personal data is therefore processed in the United States.

Complaints

You have the right to lodge a complaint with a data protection supervisory authority, in particular in the country where you live or work or where an alleged infringement took place. We would appreciate the chance to address your concern first at contact@piboo.ai.

Children

Users in these regions must be at least 16 (Section 16).

21. United States Residents

This section supplements this Policy for residents of US states with consumer privacy laws, including the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA).

Categories of personal information we collect

Sources, purposes, and the service providers we disclose information to are described in Sections 1, 4, and 7.

No sale or sharing

We do not sell personal information and do not share it for cross-context behavioral advertising. We have not done so in the past 12 months.

Sensitive personal information

We use sensitive personal information only to provide the Service you request, as permitted by the CCPA, and not to infer characteristics about you.

Your rights

Subject to the law of your state, you may request to know what personal information we collect, use, and disclose; to access and receive a copy of it; to delete it; to correct it; and to opt out of sale or sharing (which we do not do). We will not discriminate against you for exercising these rights. Send requests to contact@piboo.ai or by post to the mailing address in Section 17. We verify requests by asking for a reply from the email address of the account concerned. An authorized agent may submit a request on your behalf with your signed permission, and we may ask you to confirm the request directly. We respond within 45 days, extendable once by 45 days where the law allows, with notice to you. If we deny your request, you may appeal by replying to our decision, and we will respond to the appeal within the period required by your state's law.

Children (COPPA)

The Service is not directed to children under 13, and we do not knowingly collect personal information from children under 13. If you believe a child under 13 has given us personal information, contact us at contact@piboo.ai and we will delete it.

22. Changes to This Policy

This Policy applies from its effective date. When we add, remove, or change content, we will announce the changes on the Service at least 7 days before they take effect, and at least 30 days before for significant changes that are unfavorable to users.

• Version 1.0: first published