qlir - 개인정보 처리방침 / Privacy Policy

1. Introduction

qlir ("the App") is an AI photo super resolution (upscaling) app for iOS, developed by independent developer qela.ai ("Developer"). The App uses the Real-ESRGAN CoreML model to enhance photo resolution.

2. Personal Information Controller

The personal information controller (and privacy officer) responsible for privacy matters related to this App is as follows:

• Controller: qela.ai (Independent Developer)
• Contact: support@qlir.app
• Phone: +82 10 8157 3574

3. Legal Basis for Processing

The legal bases applicable to personal information processing in this App are as follows:

• Consent (ATT Consent): Where a user grants permission through Apple's App Tracking Transparency (ATT) framework, AdMob SDK may collect information such as IDFA (Identifier for Advertisers) for ad personalization. Even if the user declines ATT consent, all core features of the App remain fully functional.
• Legitimate Interest (Essential Functions): Minimal data processed solely on-device for basic app functionality (e.g., processing history management, usage settings) is processed without separate consent, as it constitutes essential functionality for the user experience.
• Performance of Contract: Transaction processing related to premium purchases (in-app purchases) is handled through Apple's StoreKit 2 within the scope necessary for the performance of the service agreement.

4. Information Collected and Not Collected

4-1. Information Not Directly Collected by the Developer

The qlir Developer does not directly collect any of the following information from users:

• Personal identifiable information (name, email, phone number, etc.)
• Photos or image data (all processing is performed on-device)
• Location data
• Usage analytics or tracking data
• Payment information (processed directly by Apple)

4-2. Information That May Be Collected by Third Parties (Google AdMob)

Google AdMob SDK is used to serve ads to free users. In accordance with its own privacy policy, AdMob may automatically collect the following information:

Important: The above information is not collected by the qlir Developer but is automatically collected by the Google AdMob SDK. The Developer does not have direct access to such data. For premium users (one-time purchase completed), AdMob ads are not displayed and therefore such data collection does not occur.

For details, please refer to Google's Privacy Policy and Google's Partner Sites Policy.

5. On-Device Processing

The core functionality of qlir, AI photo super resolution, is performed entirely on the user's device.

• The Real-ESRGAN CoreML model runs locally on the device.
• Photos are never transmitted to any external server for processing.
• Image processing works without an internet connection.

6. Photo Access

qlir accesses photos exclusively through Apple's PhotosPicker (PHPicker).

• Only photos explicitly selected by the user are accessed.
• The App does not request access to the full photo library.
• Selected photos are used solely for processing and released from app memory after completion.

7. Locally Stored Data and Retention

qlir stores the following data locally on the device to provide app functionality:

Note: Original photos and processed high-resolution images are not stored within the App. The above data is never transmitted outside the device and is deleted when the App is uninstalled. Users may also delete app data individually through iOS Settings.

8. Payments

In-app purchases in qlir (com.qlir.premium.lifetime, one-time premium purchase) are handled through Apple's StoreKit 2.

• All payments are processed directly by Apple.
• The qlir Developer does not access or store any payment information (credit card numbers, billing addresses, etc.).
• For payment-related inquiries, please contact Apple directly.

9. Third-Party SDKs and Entrustment of Personal Information Processing

9-1. Third-Party SDKs Used

The following types of third-party SDKs are not used:

• No analytics or tracking SDKs
• No social media SDKs
• No crash reporting SDKs (except AdMob SDK's own diagnostics)

9-2. Entrustment of Personal Information Processing

In accordance with Article 26 of the Personal Information Protection Act (PIPA), qlir entrusts personal information processing for advertising services as follows:

The Developer stipulates compliance with applicable data protection laws, technical and administrative safeguards for personal information, and prohibition of use beyond the entrusted purpose in its entrustment arrangements.

10. International Data Transfer

Information collected through the AdMob SDK is transmitted to Google's servers, which may be located outside of South Korea (e.g., the United States). In accordance with Article 28-8 of the Personal Information Protection Act (PIPA), details regarding international transfers are as follows:

Google complies with international data transfer frameworks such as the EU-U.S. Data Privacy Framework and implements appropriate safeguards.

Note: For premium users, ads are not displayed and therefore no data transfer to Google via AdMob occurs.

11. App Tracking Transparency (ATT)

qlir complies with Apple's App Tracking Transparency (ATT) framework.

• An ATT consent prompt is presented to free users upon the first launch of the App.
• If "Allow Tracking" is selected: AdMob SDK may use the IDFA to serve personalized ads.
• If "Ask App Not to Track" is selected: IDFA is not collected, and contextual (non-personalized) ads are served. The core functionality of the App (photo upscaling) is not affected in any way.

Users can change their tracking preferences at any time via iOS Settings > Privacy & Security > Tracking.

Premium users: For users who have completed the premium purchase, AdMob ads are not displayed, and therefore no tracking via AdMob occurs regardless of ATT settings.

12. Advertising

qlir displays interstitial ads powered by Google AdMob for free users.

• Free users: Interstitial ads may be shown during app usage.
• Premium users (one-time purchase): Ads are completely removed. No data collection by AdMob SDK occurs.

AdMob may use data for ad personalization in accordance with Google's policies. Users can manage ad personalization through the following methods:

• ATT settings: Go to iOS Settings > Privacy & Security > Tracking to manage per-app tracking.
• Google Ad settings: Manage personalized ads at Google Ad Settings.
• Premium purchase: Completely remove ads through a one-time premium purchase.

13. No Account Required

No account creation or login is required to use qlir. We do not ask for email addresses, passwords, or any other personal identifiable information.

14. User Rights

In accordance with Articles 35 through 37 of the Personal Information Protection Act (PIPA), users (or their legal representatives) may exercise the following rights:

• Right of Access (Article 35): You may request access to the status of processing of your personal information.
• Right to Correction and Deletion (Article 36): You may request correction or deletion of your personal information.
• Right to Suspend Processing (Article 37): You may request suspension of processing of your personal information.
• Right to Withdraw Consent: You may withdraw consent for the collection and use of personal information at any time.

How to Exercise Your Rights

Since qlir does not directly collect personal information from users, most data-related actions can be taken as follows:

• Delete locally stored data: Uninstalling the App will delete all local data stored on the device.
• AdMob-related data: For data collected by Google, please request access or deletion through Google Account Data Management or contact Google Privacy Inquiries.
• Withdraw ATT consent: You may revoke tracking permission at any time via iOS Settings > Privacy & Security > Tracking.
• Other requests: If the above methods do not resolve your concern, please contact support@qlir.app and we will take necessary action without delay.

Requests to exercise user rights will not be refused without legitimate grounds, and the Developer will take necessary action within 10 days of receiving the request.

15. Children's Privacy

qlir is not directed at children under the age of 14 and does not intentionally collect personal information from children.

• The qlir Developer does not directly collect personal information from children.
• Google AdMob applies separate policies for child-directed content. This App is not categorized as a Kids Category app on the App Store and does not enable AdMob's child-directed treatment (COPPA tag).
• If it is determined that personal information has been collected through AdMob from a child under 14 without parental consent, a legal guardian may contact support@qlir.app and the Developer will take necessary action within the scope available.

Guardians are encouraged to use the Screen Time and Content Restriction features on iOS devices when children under 14 use the App.

16. Measures to Ensure Security of Personal Information

qlir implements the following measures to protect user data:

• On-device processing: All image processing is performed exclusively on the user's device and is not transmitted to external servers.
• Data minimization: As the Developer does not directly collect any personal information, the risk of external data exposure is minimized.
• Network security: HTTPS (TLS) encrypted communication is used for AdMob ad requests.
• Apple platform security: The App operates within iOS's sandbox environment, preventing other apps from accessing qlir's local data.

17. Remedies for Infringement of Rights

Users may consult or file complaints with the following organizations for remedies related to personal information infringement:

• Personal Information Infringement Report Center (KISA): 118 / privacy.kisa.or.kr
• Personal Information Dispute Mediation Committee: 1833-6972 / www.kopico.go.kr
• Supreme Prosecutors' Office Cyber Investigation Division: 1301 / www.spo.go.kr
• National Police Agency Cyber Bureau: 182 / ecrm.cyber.go.kr

18. Changes to This Policy

This Privacy Policy may be updated from time to time. If changes are made, we will notify users through app updates or this page in advance.

• General changes: at least 7 days prior notice before the effective date.
• Material changes adverse to users (addition of data collected, changes in purpose of use, expansion of third-party sharing, etc.): at least 30 days prior notice before the effective date, and separate consent will be obtained if necessary.

The revised policy becomes effective on the effective date posted on this page.

19. Contact Us

If you have any questions or concerns about this Privacy Policy, or wish to exercise your personal information rights, please contact us at:

• Developer (Privacy Officer): qela.ai (Independent Developer)
• Email: support@qlir.app
• Phone: +82 10 8157 3574