Privacy Policy

1. Introduction

Protecting your personal data is a priority for Chingu. This Privacy Policy explains how we collect, use, store, and protect your personal data in accordance with the General Data Protection Regulation (GDPR).

Data Controller:
HANFLOW, LLC
Address: 131 Continental Dr, Suite 305, Newark, DE 19713, USA
Email: mikey@chingu.app

2. Data Collected

We collect the following personal data:

• Identification data: Email address
• Location data: Approximate location (neighborhood-level), used to recommend nearby places — only collected with your explicit permission, only while using the relevant feature
• Photos: Images you choose to share for the camera translation feature (menus, signs, posters) — processed to provide the translation and not retained longer than necessary for that purpose
• Payment data: Purchases are processed directly by Apple or Google — we do not receive or store your banking or card details; we only receive purchase/entitlement confirmation via RevenueCat
• Usage data: App interactions, questions asked, features used
• Communication data: Messages sent through the Chingu chat interface, support requests

3. Processing Purposes

Your data is collected and processed to:

• Manage your Chingu Pass or Chingu Weekly access
• Provide the travel companion service, including location-based recommendations and photo translation
• Synchronize purchase and entitlement status
• Improve the service and develop new features
• Communicate with you (support, updates, launch notifications)
• Comply with legal and regulatory obligations

4. Legal Basis for Processing

• Contract execution: For providing the service you purchased
• Consent: For location and photo data, and for marketing communications (withdrawable at any time)
• Legitimate interest: For improving our services and security
• Legal obligation: For accounting and tax compliance

5. Data Recipients

Your data may be shared with:

• Apple Inc. / Google LLC — payment processing for in-app purchases (App Store / Google Play)
• RevenueCat, Inc. — subscription and purchase management, entitlement synchronization
• Supabase, Inc. — database, authentication, and backend infrastructure
• Naver Corp. — place search and location data (South Korea)
• Kakao Corp. — reverse geocoding for neighborhood-level location (South Korea)
• PostHog Inc. — product analytics
• Resend Inc. — transactional and marketing email delivery
• Vercel Inc. — hosting infrastructure
• Anthropic PBC — AI processing powering the Chingu chat (Claude API)
• Competent authorities — in case of legal obligation or judicial request

All service providers are required to comply with GDPR and offer sufficient data protection guarantees. Transfers outside the EU are governed by standard contractual clauses.

6. Data Retention

• Account and usage data: Duration of active access + 3 years after last activity
• Payment data: We do not directly store payment/banking details — Apple and Google retain transaction records under their own policies; RevenueCat retains purchase/entitlement metadata for the duration of your access
• Photos: Not retained beyond processing the translation request
• Email data: Until unsubscription or deletion request
• Account deletion: Upon a verified deletion request, your account and associated personal data are deleted within 30 days, except where retention is required by law (e.g. accounting records)

7. Your Rights

Under GDPR, you have the right to:

• Access: Obtain a copy of your personal data
• Rectification: Correct inaccurate or incomplete data
• Erasure: Request deletion of your account and data — see "Account Deletion" in our Terms and Conditions
• Restriction: Restrict how your data is processed
• Portability: Receive your data in a portable format
• Object: Object to data processing
• Withdraw consent: At any time, including for location access, photo access, or marketing communications

To exercise your rights, contact us at mikey@chingu.app. We will respond within one month. You also have the right to lodge a complaint with your local data protection authority.

8. Data Security

We implement appropriate technical and organizational measures to protect your data, including:

• Encryption of data in transit (HTTPS/TLS)
• Secure authentication and access management
• Regular security monitoring

9. Changes

We reserve the right to modify this Privacy Policy at any time. Changes take effect upon publication. We encourage you to check this page regularly.

10. Contact

For any questions regarding this Privacy Policy:
Email: mikey@chingu.app
HANFLOW, LLC — 131 Continental Dr, Suite 305, Newark, DE 19713, USA