Privacy Policy

Some Other Place Inc. (hereinafter “the Company”) is committed to protecting the privacy of users and complying with global data protection regulations, including the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), Personal Information Protection and Electronic Documents Act (PIPEDA), and the South Korean Personal Information Protection Act (PIPA). This Privacy Policy outlines how we collect, use, retain, and protect your personal information.

This Privacy Policy is effective as of February 18, 2025.

The collects and uses personal information from individuals registering for the Company’s services, as follows:

Purpose of Collection and Use Personal Information Collected Retention Period
Account Registration and Management Phone number, access IP information, email, affiliated account app ID and name (Google, Apple, or Kakao), nickname, date of birth, profile picture, gender, region 3 years from the date of account termination
Handling Customer Complaints Email, mobile phone number, login ID (KakaoTalk ID, Apple email account included), gender, date of birth, name, service usage records, access logs, cookies, access IP information, payment information, inquiry details 3 years from the date of account termination
Service Provision, Performance Improvement, AI Learning, and New Service Development Nickname, gender, date of birth, social media account information, phone number, name, any information provided, transmitted, captured, streamed, and/or uploaded during service use, including text and voice communication data, photos, videos, voice information, service usage details, user reactions, status information visible to others, network connection and geographic information, log data, cookies, location information, access information, IP address, device performance, bandwidth, service usage statistics (URLs, redirect URLs, etc.), network type, device information (device type, model, device ID, OS), errors and technical issues, error time and app status, advertising identifiers, in-app purchases and refunds, interaction with other users, time spent on voice/text chats, app version, device locale (country and language), app store purchase history, payment details, service access status, language preferences, hobbies, interests, career and educational information, profile details entered by the user 5 years from the date of account termination
Monetary Payout and International Data Transfers Full name, national identification number, address, bank name, account number, email address, Payoneer account (email address, etc.), physical address, phone number, mobile phone number. Data may be shared with trusted third-party service providers like AWS, Microsft, Google, Twilio, and MaxMind for services including user verification, voice communication, and payout processing. 3 years from the date of account termination

You may choose not to consent to the collection and use of your personal information as described above. However, please be advised that if you do not agree, you may be restricted from accessing or using certain services provided by Some Other Place, such as the 1:1 conversation service on Hug.

1. Purpose of Collecting Personal Information

The Company collects personal information for the following purposes:

  1. Account Management and Verification
    • Verification of identity, prevention of fraudulent activities, providing member services, managing user accounts, and implementing and upholding platform policies.
  2. Service Provision
    • Delivering services, including app functionalities such as voice and text chat, content sharing, and managing communication tools.
  3. Marketing and Advertising
    • Sending promotions, personalized recommendations, and advertising through data analytics based on user behavior, as well as sharing aggregated, anonymized data with third-party partners.
  4. Service Development and AI Training
    • Using personal data, including communication data (messages, voice chat, and relevant metadata from interactions), for AI learning, machine learning, fraud detection, content moderation, compliance monitoring, and automated recommendations.
  5. Security and Fraud Prevention
    • Monitoring and analyzing user activity for security enhancement, fraud prevention, abuse detection, compliance with platform policies, and ensuring a safe user environment.
  6. Legal and Compliance Requirements
    • Fulfilling legal obligations, responding to regulatory inquiries, and protecting the company against legal claims.

2. Data Retention Period

The Company retains user data for as long as necessary to provide services, comply with legal obligations, enhance security, and improve platform functionality. Where legally required or permitted, the Company may retain certain data beyond the stated retention period for fraud prevention, security enhancement, legal compliance, or business continuity purposes. Data retention periods may vary based on operational, regulatory, and legal requirements.

Data Deletion Requests
User requests for data deletion will be reviewed in accordance with legal, operational, and security requirements. Some data may be retained if required for:

The Company may retain certain data beyond the retention period where necessary for fraud prevention, security enforcement, regulatory compliance, or other legitimate business interests. The Company reserves the right to reject deletion requests in cases where: (1) the data is required to fulfill legal, tax, or compliance obligations, (2) deletion is technically unfeasible without affecting system integrity, or (3) the data is necessary to protect the Company’s rights, enforce agreements, or resolve disputes.

Third-Party Data Processors

The Company may share personal data with third-party service providers to ensure seamless delivery of services. These include:

These third parties are bound by agreements to protect personal data in compliance with applicable privacy regulations. All data is processed and stored by the Company in compliance with applicable laws and its Privacy Policy.

4. User Rights and Requests

Users have the right to:

  1. Access and Rectification
    • Users may access their personal data and request corrections if any information is inaccurate.
    • The Company reserves the right to deny access requests if they infringe on the privacy of others, conflict with security or legal obligations, or are deemed unreasonable.
  2. Deletion
    • Users may request the deletion of their personal data, subject to applicable legal, security, and operational requirements.
    • Certain data cannot be deleted if required for:
      • Compliance with financial, tax, and regulatory laws
      • Fraud detection, security monitoring, and abuse prevention
      • Legal defense, dispute resolution, or investigations
      • Protecting the legitimate business interests of the Company, including service integrity and compliance monitoring
  3. Data Portability
    • Users may request the transfer of their data to another service provider where technically feasible.
    • The Company is not responsible for compatibility issues with third-party services.

Limitations and Retention of Requests

Users may exercise these rights by contacting our support team at support@hugapp.com. Requests will be processed in accordance with applicable laws and platform policies.

5. Data Transfers and International Processing

The Company may transfer personal data across international borders to provide services, including to countries that may not have the same data protection laws as the user’s country of residence. The Company ensures that all data transfers comply with applicable legal requirements, such as the GDPR’s Standard Contractual Clauses.

In regions with data localization laws, such as Russia, China, and other jurisdictions with similar regulations, the Company will comply with local requirements, including storing certain categories of personal data within the applicable jurisdiction. However, the Company reserves the right to transfer data across borders where permitted by law and necessary for business continuity, fraud prevention, regulatory compliance, and service optimization.

6. Liability Limitation and Service Disclaimer

To the extent permitted by applicable law, the Company shall not be liable for any indirect, incidental, consequential, special, punitive, or exemplary damages, including but not limited to lost revenue, lost profits, business interruptions, reputational harm, loss of data, or other intangible losses, even if such damages were foreseeable or the Company was advised of their possibility. If such limitations are not permitted by law, this provision shall not apply to the extent of such prohibition.

  1. The Company’s total liability for any claims, including but not limited to data breaches, privacy violations, service disruptions, or third-party failures, shall not exceed the amount permitted by applicable law, regardless of the legal theory under which the claim is brought.

  2. The Company provides its services on an “as is” and “as available” basis without warranties, express or implied, including but not limited to merchantability, fitness for a particular purpose, title, or non-infringement. The Company does not guarantee uninterrupted, error-free, or fully secure operation of the services.

  3. The Company is not liable for damages resulting from user-generated content, interactions with third parties, unauthorized account access, service interruptions, security breaches, software bugs, or changes in Company policies.

  4. The Company is not responsible for failures, interruptions, or damages caused by third-party service providers, including but not limited to cloud hosting, payment processors, telecommunications networks, and software vendors. The Company is not liable for damages resulting from cyberattacks, data breaches, hacking incidents, denial-of-service attacks, or other security threats beyond its reasonable control, as well as acts of government, regulatory restrictions, changes in law, natural disasters, pandemics, labor strikes, or other force majeure events.

  5. The Company does not guarantee continuous, uninterrupted, or error-free service and reserves the right to modify, suspend, or discontinue any part of the service at its sole discretion without prior notice. Users acknowledge that service interruptions, updates, feature removals, or policy changes do not entitle them to compensation, refunds, or damages.

  6. Users agree to bring any claims individually and waive the right to participate in any class action, consolidated, or representative proceeding. Where permitted by law, the Company’s total aggregate liability for multiple claims arising from a single event shall not exceed the amount allowed under applicable law.

  7. The Company shall not be liable for any damages arising from user-generated content, interactions between users, unauthorized account access, or misuse of the Services by users. Users are solely responsible for their own conduct and any consequences arising from their use of the Services. The Company disclaims all warranties, express or implied, including but not limited to merchantability, fitness for a particular purpose, and non-infringement.

By using the service, users acknowledge and accept these limitations.

7. Indemnification by Users

Users agree to indemnify and hold the Company harmless from any claims, damages, liabilities, or expenses, including legal fees, arising from their misuse of the services, violation of this Privacy Policy, or infringement of third-party rights.

8. Arbitration and Dispute Resolution

To the extent permitted by applicable law, all disputes arising from this Privacy Policy or the processing of personal data shall be resolved through binding individual arbitration.

  1. Disputes shall be resolved through arbitration administered by a recognized arbitration institution, including but not limited to:
    • The Korean Commercial Arbitration Board (KCAB) in Seoul, South Korea
    • The American Arbitration Association (AAA)
    • The London Court of International Arbitration (LCIA)
    • Any other arbitration institution mutually agreed upon by both parties or designated by applicable law.

    If arbitration is unenforceable, impractical, or otherwise inapplicable in a specific jurisdiction, disputes shall be resolved through individual legal proceedings before a court of competent jurisdiction.

  2. To the extent permitted by law, users agree that disputes shall be resolved individually and not as part of any class or representative action.

  3. To the extent permitted by law, both parties waive their right to a jury trial in any legal proceeding related to this Privacy Policy.

  4. Arbitration proceedings shall be governed by the laws of the Republic of Korea unless the user resides in a jurisdiction where arbitration clauses are restricted by law, in which case the applicable local law shall apply. If arbitration is not applicable or enforceable, disputes shall be resolved in the courts of the user’s place of residence or another jurisdiction as determined by applicable law.

  5. Notwithstanding the foregoing, the Company reserves the right to seek injunctive relief or damages in a court of competent jurisdiction where the user is located, or in the jurisdiction where the Company is registered, for claims related to intellectual property infringement, unauthorized use of the Services, fraudulent activities, or breaches of contractual obligations.

9. AI Learning and Service Development

10. Data Security and Protection

11. Data Monetization and Analytics

12. Data Transfer in Case of Mergers or Acquisitions

In the event of a merger, acquisition, or corporate restructuring, user data may be transferred to the new entity. The acquiring entity shall ensure that transferred data is protected at a level equivalent to this Privacy Policy or provide users with notice of any material changes.

13. Regulatory and Financial Disclosures

The Company may disclose personal data to tax professionals, auditors, banks, payment processors, financial service providers, tax authorities, regulatory agencies overseeing financial, tax, and compliance matters, law enforcement agencies, financial crime units, anti-money laundering (AML) enforcement bodies, relevant government agencies, and public institutions administering government funding, economic development programs, and business support initiatives.

These disclosures may include, but are not limited to, financial and transactional data, compliance-related records, and other information necessary to fulfill contractual obligations, regulatory compliance, fraud prevention, and risk management.

Such disclosures may be made as required or permitted by applicable laws, regulatory requirements, or industry best practices.

14. Cookies and Tracking Technologies

The Company uses cookies, tracking pixels, and other similar technologies to enhance user experience, improve service performance, and conduct targeted advertising. These technologies help analyze user behavior, optimize service functionality, and measure advertising effectiveness.

Users may manage their cookie preferences through browser settings. However, disabling cookies may impact the functionality of certain services. Some cookies are essential for security, fraud prevention, service performance optimization, advertising compliance, and account authentication purposes and cannot be disabled. In some jurisdictions, users may have the right to opt out of certain types of tracking, and the Company will comply with applicable regulations, including GDPR, CCPA, and similar laws.

15. Changes to the Privacy Policy

The Company reserves the right to update or modify this Privacy Policy at its sole discretion, without prior user approval, unless required by applicable laws. Updates may be communicated through appropriate channels, such as in-app notifications, emails, or website notices.

Continued use of the service following any updates constitutes acceptance of the revised policy. Users are responsible for reviewing this Privacy Policy periodically to stay informed about any changes.

This Privacy Policy was last updated on February 18, 2025.