Location-Based Service Terms

Operator: Foo AI Corp. · Effective: 2026-09-20 · Document version: loc-2026-09-20 · Contact: support@fadetalk.app

1. Purpose and Scope

These Terms govern the location-based service (“Near”) that Foo AI Corp. provides within FadeTalk. They do not apply to users who do not use Near; the rest of the Service is governed by the Terms of Service and the Privacy Policy. How location data is handled in detail is set out in the Location Privacy Policy; where the two differ, whichever is more favourable to the user applies.

2. Company Details and Contact

Location Information Act art. 19(1)(i)

• Company: Foo AI Corp.
• Representative: JEEHO SONG
• Business registration number: 284-81-02702
• Address: 359 Gangnam-daero, Seocho-gu, Seoul, Republic of Korea
• Phone: We do not operate a customer service phone line. Enquiries and rights requests reach us by email (support@fadetalk.app) or at the address above.
• Location Information Manager: JEEHO SONG, Chief Executive Officer · support@fadetalk.app

3. What the Service Does

art. 19(1)(iii)

• When and how location is read — your device reads your position once, when you open Near and ask for a list. It immediately converts that position into the identifier of a fixed grid cell of at least about 3 km² (a pair of integers). Coordinates never leave your device. What we receive is the cell identifier.
• No background collection — no background location, no movement history, no continuous tracking. If you do not open the screen, nothing is read.
• What you see — up to 30 people who used Near from the same or an adjacent cell within the last 30 minutes. For each of them: one of three distance bands (same area / adjacent area / this area) and their display name, if they set one. The ID code and the profile photo are shown only to mutual friends. A card for someone who is not your friend carries no ID code; it carries a single-use reference instead, which is never displayed, works only for the person the card was shown to, and expires with the card. Once the card has expired, nothing it carried can be used to reach that person or open a chat with them.
• What a chat request passes on — if you send a chat request to someone who is not your friend, they see your display name and your ID code. Sending the request is your choice; if you do not send one, your ID code is not passed on.
• Who can use Near — Near is available only to an account with a verified email address we can deliver to, because that is how each disclosure is notified to you (clause 8). Allowing app notifications alone is not enough, and an address our mail cannot reach cannot carry a notice either: Apple’s private relay address, issued when you hide your email while signing in with Apple, is such an address, so an account that has only that address cannot use Near.
• What the Service does not provide — no map, no coordinates, no distance in metres or kilometres, no bearing, no movement history, no past locations. Our database has no column that could hold any of them.
• Audience — you choose who your distance band is shared with: Friends or Everyone nearby. Which values you can choose depends on your account region; accounts in the Republic of Korea share with friends. “Friend” means a mutual connection only, and either side removing it ends visibility immediately.
• Reciprocity — the pool you are visible to is always the pool you can see. While you are paused or have withdrawn consent, you see nobody.
• Starting a chat — with someone who is not a friend, a chat opens only after a request is accepted. A declined request hides both sides from each other for 30 days.
• Price — Near is free. Data charges are between you and your carrier.

The service is not yet in operation. While the feature is disabled there is no permission prompt, no location read, and no cell identifier sent.

4. Sharing Location With Other Users

art. 19(2), 19(3)

Showing your distance band to other users is what Near is for, and it is a disclosure of personal location data to third parties. We state the following in these Terms and obtain your separate consent to that disclosure before any of it happens.

We do not disclose location data for advertising or marketing, and we do not sell it. Processors unrelated to Near (such as the AI reply-suggestion provider) receive no location data. Cross-border processing for server and database operation is described in the Location Privacy Policy.

While the feature is disabled no disclosure occurs and no disclosure record is created.

5. Your Rights and How to Exercise Them

art. 19(1)(ii), 19(5), 24, 25, 27

• Partial consent — consent is split into separate items and you may agree to some only. Consent to collection/use and to disclosure is needed to use Near; whether an app notification accompanies the email, the notification frequency and the audience are optional. A deliverable email address is not optional — it is a condition of use (clause 3). Declining location consent entirely leaves the rest of FadeTalk fully usable.
• Withdrawal — in the app, Settings → Near → Withdraw consent, or by email to support@fadetalk.app. On withdrawal we delete the stored cell identifier in the same operation, destroy your entries in the statutory activity records, and record the fact of that destruction (how many entries, and when). Records the law requires us to keep are retained for the period in clause 6 and then destroyed.
• Pause — one tap from the list screen, two from Settings, effective immediately. We do not refuse a pause request and impose no confirmation step, rate limit or precondition.
• Access — Settings → Near → Provision records shows your collection, use and disclosure records at any time. The screen shows only your own records; it cannot be used to enumerate the people you saw. You may also request access, correction or deletion by email.
• If we have suspended your account — pausing, withdrawing consent and access are not affected. Signing in again with the same method gives you a credential limited to those three plus a read of your Near settings; it cannot query Near, give consent or change settings. The same requests are accepted by email to support@fadetalk.app.
• Under 14 — FadeTalk does not accept registrations from anyone under 14, and the Near consent step requires that confirmation as well. We therefore process no location data of children under 14 and operate no legal-guardian consent flow. An account found to belong to someone under 14 is deleted.
• Guardians — we do not offer the art. 26 service by which a guardian may consent on behalf of a child aged 8 or under or another protected person, so no such flow exists.
• Damages and dispute resolution — if we breach arts. 15 to 26 of the Location Information Act and you suffer loss, you may claim damages. If we cannot resolve it between us, you may apply to the Korea Communications Commission for adjudication or to the Personal Information Dispute Mediation Committee (1833-6972, kopico.go.kr).

6. Statutory Activity Records: Basis and Retention

art. 19(1)(iv), art. 16(2)

• Basis — art. 16(2) requires a location service provider to record and retain, automatically, the fact that location data was collected, used or disclosed. We keep these records to comply with that duty.
• What is recorded — whether the act was a collection, a use or a disclosure; who requested it; how it was obtained; the method; the recipient; and a timestamp shown at 10-minute granularity. The location itself is not recorded — the table has no column that could hold a coordinate or a cell identifier.
• Retention — 6 months. An automatic job deletes entries older than that.
• Immutability — once written, these records cannot be modified or deleted; the database itself refuses. Only marking a notification as delivered, and destruction required by law, run through their own controlled procedure.
• Other logs — access by our staff is logged for 1 year, and grants and changes of location-handling authority for at least 5 years.

7. Purpose and Retention of Personal Location Data

art. 19(1)(v), Enforcement Decree art. 23(i)

• Purpose — showing people nearby and connecting chat requests. Nothing else.
• Retention — one cell identifier per user, overwritten in place, held for at most 30 minutes. Once it expires it is excluded from every query, so it can no longer be read or disclosed, and an automatic job running at least every 6 hours deletes the row physically. We describe this as it is rather than claiming instant physical deletion.
• No history — past positions and movement are stored in no table. Cell-related fields are also stripped from error and usage-analytics events before they are sent.
• Backups — anything left in point-in-time database backups is purged within 7 days.

8. Notifying You of Each Disclosure

art. 19(1)(v), Decree art. 23(ii); art. 19(3)–(5), Decree art. 24

• Contents — the recipient, the date and time (10-minute granularity), and the purpose. All three are shown in Provision records in the app, on the device the location was collected from.
• Method — all three are emailed to your account’s verified email address. Email is the channel, and having one is also what makes you eligible for Near (clause 3). If you happen to read the entry in Provision records before the mail goes out, that reading discharges the notice and no mail is sent.
• App notification — if you chose app notifications, a content-free alert (“You have a new provision record”) goes out alongside the email. It names neither the other person nor any location: an alert body travels through an external notification provider, so naming the other person would carry the fact of proximity to that provider and hand any nearby account a doorbell to ring. The alert never replaces or delays the email, and an alert on its own does not discharge the notice.
• If we cannot notify you — with no verified email address we can deliver to, Near does not run. Any cell identifier still held is deleted in the same request, so there is no period in which disclosure continues while notification cannot.
• Batched notification — with per-disclosure notices you receive one every time a disclosure happens. To receive fewer, choose every 10/20/30 disclosures or every 10/20/30 days (30 days maximum); you can switch back in one tap at any time.

9. Limiting or Suspending the Service

We may limit or suspend Near where you have paused it or withdrawn consent; where no verified email address we can deliver a notice to is available; where a report or block has made two accounts mutually invisible; where we identify a breach of these Terms such as forged location or automated bulk querying; where compliance requires it; or in unavoidable circumstances such as force majeure or equipment failure. Limiting Near never limits the rest of the Service.

10. Publication and Changes

art. 12(1), Decree art. 13(ii)

These Terms are published at fadetalk.app/location-terms and linked from the first Near screen (the consent screen) in the apps and on the web. If we change them, we publish the change and its effective date the same way, and announce any change unfavourable to users in-Service before it takes effect. If you do not agree to a change you may withdraw consent and stop using Near.

11. Governing Law and Jurisdiction

These Terms are interpreted under the laws of the Republic of Korea, and disputes are handled by the courts with jurisdiction under applicable law.

This English text is provided for a global audience; the Korean version is the authoritative text and prevails in case of any conflict.

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