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Privacy Policy

This is a courtesy translation. If the versions differ, the Korean original prevails. View the Korean original

Huston English Academy (the “Academy”) maintains the following policy in order to protect users’ personal information and to handle related grievances, in accordance with the Personal Information Protection Act of Korea.

1. Personal information we collect

  • Required: name, email address, password
  • Optional: phone number, school year, date of birth, parent’s name
  • Collected automatically: learning records (course history, quiz scores, attendance)
  • Reading homework (submitted at the user’s choice): the audio file the student records. Automatic analysis of length, pace, pronunciation, intonation and diligence runs only inside the user’s own browser (locally); the audio is not sent to any third party such as an external speech-recognition server. The recording is stored in the cloud (Vercel) solely so that the teacher in charge can review it and give feedback.

2. Why we collect personal information

  • member management and identity verification
  • providing the course service and managing study
  • AI-based personalised learning analysis and recommendations
  • creating a learning portfolio
  • providing learning reports to parents
  • automatic learning analysis of reading recordings and teacher feedback (the star rating and comments are checked and finalised by the teacher)
  • tuition payment and refund processing

3. Retention period

We delete personal information immediately when a member withdraws. Where retention is required by applicable law, however, we keep it for the period prescribed.

  • Act on Consumer Protection in Electronic Commerce: records of contracts or withdrawal of subscription — 5 years
  • records of payment and of the supply of goods or services — 5 years

4. Provision to third parties

The Academy does not provide users’ personal information to third parties. However, we use Anthropic’s Claude AI service for AI learning analysis, and learning data (excluding names) may be processed in the course of it.

4-1. Outsourcing of personal information processing

To provide the service smoothly, the Academy outsources personal information processing as follows.

Sub-processorTaskRetention Period
Korea PortOne Inc. (PortOne)Payment processing, payment agency, settlement management, PG integration, fraud preventionUntil the outsourcing contract ends, or the period prescribed by law
KG Inicis / NHN KCP / KakaoPay / PayPalAuthorisation and capture of credit card, easy-pay and overseas paymentsThe period prescribed by law (5 years under the E-Commerce Act)
Vercel Inc. (USA)Website hosting, CDN, analyticsFor as long as the service is used
Anthropic PBC / OpenAI Inc. (USA)AI teacher conversations, learning analysis, personalised recommendationsDiscarded as soon as the conversation is processed (not retained)
Google LLC (USA)Google Analytics 4 visit analysis and ad conversion measurement (Consent Mode v2 — only with consent)Up to 14 months (GA4 retention cycle)
Google LLC (USA) — Google AdsSearch-ad conversion measurement and ad optimisation (conversion linker cookies _gcl_* — only with advertising consent; enhanced conversions are not used)Up to 90 days of conversion tracking (destroyed when the cookie expires)
Meta Platforms Inc. (USA)Facebook and Instagram ad pixel and conversion measurement (only with consent)Until consent is withdrawn
TikTok / ByteDance (Singapore, USA, China)TikTok ad pixel and conversion measurement (only with consent)Until consent is withdrawn (no EU adequacy decision — not fired for EEA users)
NAVER Corp. / Kakao Corp. (Korea)Search and Kakao ad log analysis and conversion measurement (only with consent)Until consent is withdrawn

Analytics and advertising tracking based on cookies or similar technologies operate only where the user has given consent. For users in the EEA, the United Kingdom and Switzerland, all non-essential cookies and tracking are blocked until explicit consent is given, in line with Google Consent Mode v2. Behavioural advertising tracking is automatically disabled for children under 14 (or below the digital consent age of their country of residence) and in the children’s learning areas. Consent can be changed or withdrawn at any time from “Cookie settings” in the footer at the bottom of the page (Personal Information Protection Act and GDPR Art. 7(3)).

Notice of cross-border transfer of personal information (Article 28-8 of the Personal Information Protection Act): Among the sub-processors above, Google, Meta, TikTok, Vercel, Anthropic and OpenAI transfer personal information (cookie identifiers, device information and the like) overseas, including to the United States. (Items transferred: cookies, advertising identifiers, ad click identifier (gclid), access device, usage records, conversion events (time and type) / Destination countries: the United States, Singapore and others / Time and method: transmitted over the network at the moment consent is given / Purpose: ad measurement and personalisation / Retention: as stated in the table above / How to refuse: decline advertising and analytics in “Cookie settings”)

In accordance with Article 26 of the Personal Information Protection Act, the Academy sets out in the contract and other documents the prohibition on processing personal information beyond the purpose of the outsourced work, technical and administrative safeguards, restrictions on re-outsourcing, supervision of the sub-processor, and liability including damages; and it supervises whether the sub-processor handles personal information safely.

5. Protection of children’s personal information

When we collect personal information from a child under the age of 14, we obtain the consent of their legal guardian. The legal guardian may request access to, correction of, or deletion of the child’s personal information.

6. Safeguards for personal information

  • Some information is stored in the browser’s local storage (localStorage) for study convenience, while enrolment, enquiry and payment information is stored on a cloud database server (Vercel/Upstash KV). It is retained for the period prescribed by law or until the member withdraws.
  • This service uses global cloud infrastructure (Vercel, USA) and AI processing services, so some personal information may be processed and stored outside Korea. (Destination countries: the United States and others · Purpose: service provision and AI learning support · Method: transmission over the network)
  • Member passwords are protected by SSL/TLS encrypted communication, and administrator passwords are managed only as server environment variables and are never exposed to the client.
  • We use SSL/TLS encrypted communication.
  • Advice and reporting on personal information infringement: Personal Information Dispute Mediation Committee (1833-6972), Personal Information Protection Commission (182, no area code), KISA Personal Information Infringement Report Centre (118, no area code).

7. Your rights

  • You may request access to, correction of, or deletion of your personal information.
  • You may request that the processing of your personal information be suspended.
  • You can remove all locally stored data yourself by clearing your browser’s localStorage.

4-2. Collection, use, provision of behavioural information and how to refuse it

We collect behavioural information for online personalised advertising as set out below. Declining does not restrict your use of the service in any way.

  • Items collected: Site visit history, buttons and pages clicked, referral path including search terms, ad click identifier (gclid), cookies and advertising identifiers, and device or browser information. We do not send personally identifying data such as name, phone number or e-mail to advertising platforms, and we do not use the enhanced conversions feature that would combine them.
  • How it is collected: Automatically, through scripts installed on the site (Google Ads, Google Analytics 4, Meta, TikTok, Kakao, Naver) once you have consented to advertising and analytics cookies and while you browse the site.
  • Purpose: Measuring advertising performance (conversions), avoiding repeated impressions, providing interest-based personalised advertising, and spending the advertising budget efficiently.
  • Retention and subsequent handling: Google Ads conversion cookies last up to 90 days, Google Analytics 4 up to 14 months, and other advertising platforms follow their own policies (see the outsourcing table above). Data is destroyed automatically when the cookie expires, and withdrawing consent stops any further collection immediately.
  • How to refuse (web browser): The simplest way is to decline advertising and analytics under Cookie settings in the footer at the bottom of the page (changeable at any time). To block them in your browser — Chrome: Settings > Privacy and security > Third-party cookies / Edge: Settings > Cookies and site permissions / Safari: Preferences > Privacy > Prevent cross-site tracking / Firefox: Settings > Privacy and Security > Enhanced Tracking Protection. You can also turn off Google ad personalisation at adssettings.google.com.
  • How to refuse (mobile device): Android: Settings > Privacy > Ads > Delete advertising ID / iPhone and iPad: Settings > Privacy and Security > Tracking > turn off Allow Apps to Request to Track.
  • Protection of children: Behavioural advertising tracking is automatically disabled for users under 14 (or below the digital consent age of their country), in the children learning areas, and on the consultation and enrolment pages where a child name, school year or age is entered. This applies at all times, regardless of user settings.

8. Personal information protection officer

Name: Cho Yunhyo (Representative) / Kim Donghan (Operations Manager)
Organisation: Huston English Academy
Business registration number: 603-90-70612
Academy registration number: No. 2384 (Busan Seobu Office of Education)
Address: Floors 2–3, 534 Dadae-ro, Saha-gu, Busan, Republic of Korea
Email: donghan941@gmail.com
Phone: +82-51-266-0582

Effective date: August 8, 2026 (revised to add Google Ads conversion measurement and behavioural-data disclosures)