# PDF Grader Pro Privacy Policy
## Article 1 (Purpose)
HC Soft Korea (“에이치씨소프트코리아,” hereinafter referred to as the “Company”) establishes this Privacy Policy (the “Policy”) to protect the information (the “Personal Information”) of individuals who use the services provided by the Company (the “Company Services”), to comply with applicable laws and regulations, including the Personal Information Protection Act and the Act on Promotion of Information and Communications Network Utilization and Information Protection (the “Information and Communications Network Act”), and to promptly and effectively address privacy-related concerns raised by users of the Company Services (the “Users” or “Individuals”).
## Article 2 (Principles for Processing Personal Information)
In accordance with applicable privacy laws and this Policy, the Company may collect Users’ Personal Information. The collected Personal Information may be provided to a third party only with the Individual’s consent. However, where disclosure is lawfully required by applicable laws or regulations, the Company may provide collected Personal Information to a third party without obtaining the Individual’s prior consent.
## Article 3 (Publication of This Policy)
1. The Company makes this Policy available on the main page of its website or through a page linked from the main page so that Users can easily review it at any time.
2. When publishing this Policy under Paragraph 1, the Company uses appropriate font sizes, colors, and other presentation methods so that Users can easily identify and review it.
## Article 4 (Changes to This Policy)
1. This Policy may be amended in response to changes in applicable privacy laws, guidelines, notices, government policies, or the policies or content of the Company Services.
2. If the Company amends this Policy under Paragraph 1, it will provide notice using at least one of the following methods:
a. Posting a notice on the main page or in a separate window on the Company’s website
b. Providing notice within the application or through App Store release notes
3. Notice under Paragraph 2 will be provided at least seven days before the effective date of the amendment. However, if an amendment materially affects Users’ rights, notice will be provided at least 30 days in advance.
## Article 5 (Information Processed to Provide the Company Services)
The Company processes the following information to provide its services to Users:
1. Required information: None (no account registration is required)
2. Optional information: Student names, exam names, subject names, and score information entered directly by the User within the app
(This information is stored locally on the User’s device by default and is not transmitted to servers operated by the Company.)
3. Information processed for AI features: When the User runs AI grading or AI template features, selected answer images, question paper PDF pages or selected-area images, rubrics, checklists, point values, model answers, teacher feedback, exam information, answer-guide PDF summaries, and question-mapping information may be transmitted to the Google Gemini API.
4. AI features use a Google AI API key entered directly by the User. When AI features are turned off, the User can use manual grading, annotation, result export, and library storage without making external AI requests.
## Article 6 (Information Processed for Advertising Services)
The Company collects the following information to provide personalized advertising services to Users:
1. Automatically collected information: Advertising Identifier (IDFA), device information, and app usage data
2. Collecting party: Google AdMob (third party)
3. Purposes of collection: Providing personalized advertisements and measuring advertising performance
## Article 7 (Information Processed to Analyze Service Use and Detect Misuse)
The Company collects the following information for statistics and analysis relating to Users’ use of the Services:
1. Automatically collected information: Service usage records and device information
## Article 8 (Methods of Collecting Personal Information)
The Company collects Users’ Personal Information through the following methods:
1. Information entered directly by the User within the app, such as student names and exam information
2. Information collected automatically through the Google AdMob SDK to provide advertising services
3. Information collected with the User’s consent when requesting permission through Apple’s iOS App Tracking Transparency (ATT) framework
4. Information transmitted when the User runs an AI feature and requests analysis through the Google Gemini API
## Article 9 (Use of Personal Information)
The Company uses Personal Information for the following purposes:
1. Providing the Company Services, including grading PDF exam papers
2. Providing personalized advertisements
3. Producing statistics and analyses relating to use of the Services
4. Developing new services
5. Providing AI grading, question analysis, rubric generation, or model-answer generation requested by the User
## Article 10 (Retention and Use Period of Personal Information)
1. The Company retains and uses Users’ Personal Information for the period necessary to fulfill the purposes for which it was collected and used.
2. Information entered directly by the User within the app, such as student names and scores, is stored on the User’s device by default and is deleted from the device when the app is deleted. However, if the User runs an AI feature using materials that contain such information, Paragraph 4 applies.
3. Advertising-related information is processed in accordance with Google’s privacy policy.
4. The processing and retention period for inputs transmitted to and responses generated by the Google Gemini API may vary depending on the User’s Google AI service plan, settings, terms, and privacy policy. Under free services, inputs and responses may be used to improve Google products or may be processed by human reviewers. Users must therefore not transmit personal, sensitive, or confidential information through free services.
## Article 11 (Provision of Personal Information to Third Parties with Prior Consent)
1. Notwithstanding the general prohibition against providing Personal Information to third parties, the Company may provide Personal Information to a third party if the User has previously made the information public or has consented to any of the following. Even in such cases, the Company provides only the minimum Personal Information permitted under applicable laws:
a. Advertising identifiers and device information provided to Google AdMob to deliver interest-based advertisements
b. Anonymized conversion data provided to SKAdNetwork to measure advertising performance
c. Information described in Article 5, Paragraph 3, provided to the Google Gemini API to deliver AI features requested by the User
2. If a third-party disclosure relationship under the preceding Paragraph changes or ends, the Company will notify Users and obtain consent through the same procedure.
## Article 12 (Principles for Destruction of Personal Information)
As a general rule, the Company destroys Personal Information without undue delay when it is no longer needed, including when the purpose of processing has been fulfilled or the applicable retention and use period has expired.
## Article 13 (Procedures for Destruction of Personal Information)
1. Information entered by the User within the app is deleted from the device when the app is deleted.
2. Using the in-app “Initialize” or “Reset” feature immediately deletes stored project data.
## Article 14 (Methods of Destroying Personal Information)
The Company deletes Personal Information stored in electronic files using technical methods that prevent the records from being recovered. Data stored on the User’s device is automatically deleted by the iOS system when the app is deleted.
## Article 15 (App Tracking Transparency)
1. The Company complies with Apple’s App Tracking Transparency (ATT) framework on iOS 14.5 and later.
2. When the app is first launched, it requests permission for advertising-related tracking, and the User may deny this request.
3. The User may continue to use all app features normally even if tracking permission is denied.
4. Tracking permission can be changed at any time in iOS Settings > Privacy & Security > Tracking.
## Article 16 (Users’ Rights)
1. Users may access, correct, or delete their Personal Information at any time.
a. Access: Users can review all data stored within the app.
b. Correction: Users can directly edit student names, scores, and other information within the app.
c. Deletion: Users can delete all data through the in-app “Initialize” feature or by deleting the app.
2. Users may withdraw consent to advertising tracking at any time by following these steps:
a. Open the iOS Settings app.
b. Select Privacy & Security > Tracking.
c. Turn off the toggle for “PDF Grader Pro.”
## Article 17 (Users’ Responsibilities)
1. Users must keep their Personal Information accurate and up to date. Users are responsible for issues caused by entering inaccurate information.
2. Unauthorized collection or use of another person’s Personal Information may be punishable under applicable privacy laws.
## Article 18 (Measures to Protect Personal Information)
The Company takes the following measures to protect Personal Information:
1. Local storage: Projects and grading results are stored on the User’s device by default. However, when the User runs an AI feature, the information described in Article 5, Paragraph 3, may be transmitted to the Google Gemini API.
2. Encryption: Stored data is protected using iOS’s built-in data protection features.
3. Data minimization: The Company processes only the minimum information necessary to provide the Services.
## Article 19 (Protection of Children’s Personal Information)
1. The Company does not directly collect Personal Information from children under 14 years of age through account registration or similar processes.
2. Users must have lawful authority to process student materials and must remove unnecessary student identifiers and personal, sensitive, or confidential information when using AI features.
3. If Personal Information of a child under 14 years of age may be transmitted to an external AI service, the User must verify the consent or authority required under applicable laws and the policies of the User’s institution before using a service with appropriate processing conditions, such as a paid Google AI service.
## Article 20 (Installation, Operation, and Rejection of Automated Data-Collection Technologies)
1. The Company collects advertising identifiers and usage information through the Google AdMob SDK to provide personalized advertising services to Users.
2. Users may reject the collection of advertising identifiers through iOS Settings:
a. Configure tracking permission for each app in iOS Settings > Privacy & Security > Tracking.
b. Configure Personalized Ads in iOS Settings > Privacy & Security > Apple Advertising.
3. Users may continue to use all app features normally even if they reject the collection of advertising identifiers.
## Article 21 (Designation of the Company’s Chief Privacy Officer)
The Company has designated the following department and Chief Privacy Officer to protect Users’ Personal Information and address privacy-related complaints:
Chief Privacy Officer
1. Name: Hyunchan Yoo (유현찬)
2. Title: CEO
3. Telephone: 010-9376-6361
4. Email: yhc4512@naver.com
## Article 22 (Remedies for Infringement of Rights)
1. A data subject may apply for dispute resolution or consultation with the Personal Information Dispute Mediation Committee, the Korea Internet & Security Agency’s Personal Information Infringement Report Center, or another relevant organization to seek remedies for a privacy infringement. For other reports or consultations concerning privacy infringements, please contact the following organizations:
a. Personal Information Dispute Mediation Committee (개인정보분쟁조정위원회): 1833-6972 (without area code), www.kopico.go.kr
b. Personal Information Infringement Report Center (개인정보침해신고센터): 118 (without area code), privacy.kisa.or.kr
c. Supreme Prosecutors’ Office (대검찰청): 1301 (without area code), www.spo.go.kr
d. Korean National Police Agency (경찰청): 182 (without area code), ecrm.cyber.go.kr
2. The Company endeavors to protect data subjects’ right to determine how their Personal Information is used and to provide consultation and remedies for privacy infringements. To report an issue or request a consultation, please contact the officer listed in Article 21.
3. A person whose rights or interests have been infringed by an action or omission of the head of a public institution in response to a request made under Articles 35 (Access to Personal Information), 36 (Correction or Deletion of Personal Information), or 37 (Suspension of Processing, etc.) of the Personal Information Protection Act may file an administrative appeal in accordance with the Administrative Appeals Act.
a. Central Administrative Appeals Commission (중앙행정심판위원회): 110 (without area code), www.simpan.go.kr
## Addendum
### Article 1
This Policy takes effect on August 2, 2026.
### Article 2
This Policy was announced on August 1, 2026.