Privacy Policy
Float Co., Ltd. ("we") handles the personal data of users of the web service "Walking into Van Gogh" (the "Service") as described here, under Korea's Personal Information Protection Act. This policy covers the web service at walkingintovangogh.com. Processing in the Steam game follows Steam's and that game's own notices.
In short
- You can walk without signing in. We do not collect your name or email for that.
- To talk with Vincent you sign in with Google, Apple or a sign-in code sent to your email. We keep the sign-in provider and its user number (for email sign-in, a hash of your email address), your email, your Steam ID (if you link it) and your last position.
- Conversation text is handled only in memory while an answer is made, and is not stored.
- Voice input (asking by speaking) is not offered at the moment. When it is offered, recordings go to a speech-to-text provider (OpenAI, United States); we do not store them, but OpenAI may keep them for up to 30 days for abuse monitoring. Others see only a text bubble, never your voice.
- When you delete your account, your email and links go immediately; purchase records are made anonymous and kept only for the legal period.
1. What we process and why
| When | Data | Purpose | Legal basis |
|---|---|---|---|
| Walking (no sign-in) | A random device number made by your browser, your IP address and time of access (usage limits, access records), country of access (to pick the currency) | Running the Service, stopping excessive access, showing prices in your currency | Performance of contract, legitimate interest (PIPA Art. 15(1)4 and 6) |
| Sign-in | Sign-in provider (Google or Apple) and its unique user number ("sub"), email | Identifying members, managing passes and free asks, contacting you about refunds and notices | Performance of contract (Art. 15(1)4) |
| Email sign-in | Email (to send sign-in codes), a hash of the email address (to identify the account), an encrypted value of the sign-in code and a hash of its request number, the number of wrong entries, request times and a hash of the IP address | Sending and checking sign-in codes, identifying members, stopping code guessing and bulk requests, contacting you about refunds and notices | Performance of contract (Art. 15(1)4), legitimate interest (Art. 15(1)6, preventing abuse) |
| Sign-up free asks | Hashes of the sign-in identity, of the email address counted as one mailbox (dots and anything after "+" removed from the name part), of the device number and of the IP address (the original values are not stored) | Not giving the sign-up free asks to the same person or device again | Legitimate interest (Art. 15(1)6, preventing abuse) |
| Steam link (optional) | Steam ID | Treating your web and Steam accounts as one person | Performance of contract |
| Talking with Vincent | Your answer to the age question (19 or older / under 19), question text, question language | Making answers, age-appropriate notices, safety checks | Performance of contract |
| Usage records | Daily and total usage counts, remaining passes, last room and position | Counting free asks and passes, starting where you left off | Performance of contract |
| Purchases and refunds | Order number, item, amount and currency, payment and refund times and status, payment gateway transaction number, country of payment, refund or cancellation requests, member email (receipt) | Payment, withdrawal and refunds, keeping transaction records | Performance of contract, legal obligation (E-Commerce Act Art. 6) |
| Voice input (optional; not offered at the moment) | Microphone recording (when offered; we delete it as soon as it becomes text) | Turning speech into text | Performance of contract |
| Minor's cancellation request | Minimum proof that the person is a minor and the guardian is the guardian | Handling the cancellation and refund | Legal obligation (Civil Act Art. 5), performance of contract |
| Enquiries | Email address, content of the enquiry | Answering you | Performance of contract |
We never receive card numbers or other payment instrument details; Toss Payments handles them for payments in Korea and Paddle for payments outside Korea. For purchases outside Korea, Paddle is the seller of record (Merchant of Record) and processes what it needs for payment and tax (such as your email, billing country and postcode, and payment details) independently under its own privacy policy; we receive from Paddle only what we need to confirm orders and refunds (transaction number, item, amount and currency, country, status). We do not collect resident registration numbers or sensitive data, and we do not identify people by their voice (no speaker recognition or voiceprints).
Question text and Vincent's answers exist only in server memory while an answer is made and delivered; they are not written to disk or logs. They disappear when the conversation ends or after 20 minutes of inactivity. Server logs contain no question or answer text. Access records (time of access, IP address) are kept only for the period in section 2.
2. Retention and destruction
| Data | How long |
|---|---|
| Email (for email sign-in accounts, the email used to send sign-in codes), sign-in links (provider and user number), Steam ID, last position, age answer | Until you delete your account; destroyed immediately on deletion |
| Encrypted sign-in code values and request-number hashes | Destroyed as soon as you sign in, or after 10 minutes |
| Wrong-entry counts (per email address hash) | Until the end of that day (Korea time); destroyed at the next code request after that |
| Code request times (per email address hash and IP address hash) | 1 hour |
| Sign-up free ask records (hashes of sign-in identity, device and IP address) | 1 year from the grant, kept for that period even after account deletion (so the free asks are not claimed again by signing up again), then destroyed |
| Question text, Vincent's answers, voice recordings | Not stored (in memory only while processing; recordings deleted as soon as they become text). For what OpenAI keeps when voice input is offered, see section 7 |
| Records of contracts and withdrawals, payments and supply of passes | 5 years (E-Commerce Act Enforcement Decree, Art. 6(1)2 and 3) |
| Records of consumer complaints and disputes | 3 years (same article, (1)4) |
| Proof for minors' cancellations | Destroyed as soon as the case is closed |
| Access records (time of access, IP address, requested address, browser information) | 3 months (Protection of Communications Secrets Act Art. 15-2; Enforcement Decree Art. 41(2)2). Kept as the access log of the front web server (nginx); sign-in tokens and other credentials in the requested address are masked. IPs used to count usage limits are separately held in memory only, for at most 1 hour |
| Server operation logs (error records; no conversation text or account data) | 3 months |
Account deletion: "Delete account" in the account menu removes your email (including the email used for sign-in codes), sign-in links, Steam link and saved position at once. Usage, purchase and refund records are moved to a random number that no longer points to your account (anonymised), kept apart from other data for the legal periods above, and then destroyed.
How we destroy data: electronic files are erased so they cannot be recovered; paper is shredded or burned.
3. Voice input
- The microphone is used only when you turn it on. We show an explanation first, and every feature works with text only.
- Voice input is not offered at the moment (there is no microphone button). The points below describe how it works when it is offered.
- Your voice is used only to turn speech into text. The recording is sent encrypted to the speech-to-text provider (OpenAI, United States; a transfer abroad), and we delete it from our server as soon as the text comes back. We never write recordings to disk or logs. OpenAI, however, may keep the recordings it receives for up to 30 days for abuse monitoring (not kept where Zero Data Retention applies; longer only where the law requires).
- Your voice is never sent to other users. Questions for everyone appear only as text bubbles.
- Vincent's voice is a synthetic AI voice. We send the text of Vincent's answer to a speech synthesis provider to turn it into sound.
4. What others see when walking together
Others in your room see your figure and position, questions you ask for everyone (as text bubbles) and Vincent's answers to them. They never see your email or Google, Apple or Steam IDs; inside a room you are shown by a temporary label used only there. Please do not write contact details or other personal data in bubbles. We may automatically hide personal data or abusive language in bubbles.
5. Letter and translation records
When you ask for a letter in a language with no stored translation, an AI translates the original and we store that translation for later requests. We store only the letter number, language, a check value of the original, the model used and the translated text, never who asked. We count which languages are requested, to prepare translations, without any information that identifies users.
6. Processors
| Processor | Task |
|---|---|
| Anthropic, PBC | Making Vincent's answers, AI translation of letters |
| OpenAI, L.L.C. | Turning voice input into text (not offered at the moment; we do not store recordings, and OpenAI may keep them for up to 30 days for abuse monitoring) |
| Hanabi AI Inc. (operator of Fish Audio, a Delaware, USA corporation, [email protected]) | Turning Vincent's answer text into an AI voice |
| Toss Payments Co., Ltd. (토스페이먼츠 주식회사) | Payments in Korea, cancellations and refunds, sending the payment receipt by email (data entrusted: order number, product name, amount paid, member email (for the receipt)). Payment method details are collected and processed directly by Toss Payments |
| Paddle.com Market Limited | Seller of record for purchases outside Korea: payment, tax and refunds. Paddle processes payment data as an independent controller, and acts for us when handling our refund requests |
| Amazon Web Services, Inc. (Seoul region) | Sending sign-in code emails (Amazon SES, processed in the Seoul region; no transfer abroad) |
| Cloudflare, Inc. | Website delivery and security (connection data passes through it) |
| 「확인 필요」 (to be confirmed) (server operator) | Service servers and data storage |
Our contracts with processors forbid use for other purposes and require security measures, limits on sub-processing and liability for damage, and we check that they comply. If a processor changes, we update this policy and tell you.
7. Transfers abroad
To perform our contract with you, we have personal data processed abroad as below, and disclose it in this policy under PIPA Article 28-8(1)3(a).
| Recipient (contact) | Country | Data | When and how | Purpose | Retention |
|---|---|---|---|---|---|
| Anthropic, PBC (「확인 필요」) | United States | Question text, conversation context, question language, original text of letters to translate | At each question or translation request, over encrypted connections (HTTPS) | Making answers, translation | As set by the provider's policy 「확인 필요」 |
| OpenAI, L.L.C. (contact 「확인 필요」) | United States | Voice recording | Each time you speak, when voice input is offered (not at the moment), over encrypted connections (HTTPS) | Turning speech into text | Up to 30 days for abuse monitoring (not kept where Zero Data Retention applies; longer only where the law requires). We do not store it |
| Hanabi AI Inc. (operator of Fish Audio, a Delaware, USA corporation, [email protected]) | United States | Text of Vincent's answer only (no audio or account data; the answer may include words from your question) | For each answer, encrypted | Making the AI voice | Per the provider's policy, "as long as we need it to ensure that our systems are working" (no fixed period, 「확인 필요」) |
| Paddle.com Market Limited (contact 「확인 필요」) | United Kingdom (processing countries 「확인 필요」) | Member email (if pre-filled in checkout), order number, item, amount and currency | Each purchase outside Korea, over encrypted connections (HTTPS) | Payment, tax and refunds outside Korea | As set by Paddle's policy and UK law 「확인 필요」 |
| Cloudflare, Inc. (「확인 필요」) | United States and data centres worldwide | IP address, request data | Each connection, encrypted | Delivery and security | As set by the provider's policy 「확인 필요」 |
How to refuse, and what happens: to avoid transfers abroad you can walk without signing in (connections still pass through Cloudflare), use text instead of the microphone (no speech-to-text transfer), or turn off Vincent's voice. If you do not buy passes from outside Korea, nothing goes to Paddle. Conversation with Vincent cannot be provided without the AI provider, so refusing that transfer means you cannot talk with Vincent.
8. Sharing with third parties
We do not give your personal data to third parties, except where the law provides for it or investigators request it through legal procedures.
9. Children and minors
- The first time you speak to Vincent we ask whether you are 19 or older. If you do not answer, we treat you as under 19 and adjust notices.
- Children under 14 must have a legal guardian's consent before signing in. If we learn that a child under 14 signed up without it, we stop processing and either confirm the guardian's consent or destroy that account's personal data.
- Guardians may ask to see, correct, delete or stop processing a child's personal data.
- We use plain language when we tell children under 14 about their data.
10. Automatic collection
We use no advertising or tracking cookies and no outside analytics. Your browser's local storage keeps a random device number, a signed-in marker and display settings. These are needed for the Service to work; you can clear them in your browser settings, and you will then need to sign in again.
11. Automated processing
For safety, we automatically classify questions and bubbles to find signs of crisis (such as self-harm or suicide) and prohibited content. Signs of crisis bring up helpline information; prohibited content is hidden or the answer is declined. This classification does not by itself decide account restrictions; we review those. You may ask for an explanation and object to the result.
12. Your rights
You (or the legal guardian of a child under 14) may at any time ask to see, correct, delete or stop processing your personal data, and withdraw consent. You can delete your account directly from the account menu; send other requests to [email protected]. We reply within 10 days. Records the law requires us to keep are kept apart for the legal period even if you ask for deletion.
13. Security measures
- All connections encrypted (HTTPS)
- Social sign-in with no passwords; sign-in tokens verified by signature
- Minimal server access; API keys kept only in environment variables and never logged
- No storage of conversation text or recordings; no personal data in logs
- Usage limits per account, device and network address; automatic detection of unusual activity
14. Privacy officer
장청일 (Chief Executive Officer) · [email protected] · +82 10-8113-6606
15. Remedies
- Personal Information Dispute Mediation Committee: +82 1833-6972, www.kopico.go.kr
- Personal Information Infringement Report Center: 118, privacy.kisa.or.kr
- Supreme Prosecutors' Office: 1301, www.spo.go.kr
- Korean National Police Agency: 182, ecrm.police.go.kr
16. Changes to this policy
When we change this policy we post what changes and from when, at least 7 days before it applies. Important changes, such as new data, purposes, transfers abroad or processors, are posted at least 30 days before and also emailed to members. Where the law requires consent, we ask for it.