Privacy Policy

Newbl (“Company”) complies with applicable privacy laws. This Policy explains what we collect, why we use it, how long we keep it, third-party sharing, processors, cross-border transfers, your rights, security measures, updates, and contact.

Article 1 (Scope)

This Policy applies to personal data processed in connection with the non-custodial wallet/payment UI (Newblet). The Company does not store or recover private keys/mnemonics in plaintext.

Article 2 (Data We Collect & How)

- (Required) Via Google OAuth: account identifier (sub), email, name, profile image, preferred language/locale - (Required) Service-generated data: access logs (timestamps/usage), IP, device/browser info (User-Agent), cookies (for security and operations) - (Optional) If you use backup: **encrypted backup file** stored in Google Drive (AppData) (no plaintext keys/mnemonics)

Article 3 (Purposes)

- Authentication and account maintenance - Service delivery/operations, troubleshooting, and security (detecting/blocking abuse) - Customer support and notices, legal compliance and dispute handling

Article 4 (Retention & Deletion)

- Retained for the period necessary for service provision and dispute handling. - Where laws require retention, we keep data for the statutory period. - Deleted without undue delay once the purpose is achieved or the period expires using secure methods.

Article 5 (Sharing with Third Parties)

We do not provide personal data to third parties without consent, except as required by law or lawful requests from authorities.

Article 6 (Processors)

We may engage processors (e.g., cloud infrastructure, CDN, logging/monitoring, customer support). We select and supervise them to ensure compliance with privacy requirements.

Article 7 (Cross-Border Transfers)

Using Google OAuth/Drive (AppData) may involve transfers to servers outside your country (e.g., the U.S.). Destination, retention, and safeguards follow each provider’s policies; we apply safeguards where feasible. You may stop using backup at any time.

Article 8 (Your Rights)

You may request access, correction, deletion, restriction, and withdrawal of consent. We will respond without undue delay as required by law.

Article 9 (Security Measures)

We implement encryption in transit/at rest, access controls, audit logs, anomaly detection and periodic reviews, data minimization, and an internal management plan.

Article 10 (Updates to this Policy)

This Policy may be updated. Material changes will be announced in-app at least 7 days prior (30 days if unfavorable).

Article 11 (Contact)

Email: support@newbl.co.kr (Data Protection Officer) See in-app notices for the Company address and other details.

Effective:Oct 1, 2025