Privacy Policy

Last Updated: April 18, 2026 | Effective Date: May 17, 2022


1. Introduction
iFactory Co., Ltd. ("Company," "we," "us," or "our") operates the Water-N mobile application and connected IoT device (collectively, the "Service").
This Privacy Policy explains how we collect, use, share, and protect your information, and describes your privacy rights under applicable U.S. law, including the California Consumer Privacy Act (CCPA/CPRA), the Children's Online Privacy Protection Act (COPPA), and the FTC Act.

2. Information We Collect
Personal Information means information that identifies or is reasonably linkable to a specific individual, including:
- Identifiers: Name, email address, IP address, and device identifiers (such as MAC address)
- Device and Usage Data: Water quality readings, temperature, firmware version, and app interaction logs
- Location Data:
  - Approximate location derived from IP address
  - Precise location (only if you grant permission through your device settings), used solely to enable Bluetooth or Wi-Fi connectivity between the App and the Device. This data is not used for tracking or advertising
- Sensitive Personal Information: Certain device or usage data may be treated as sensitive personal information where required by applicable law
We do not collect biometric identifiers (as defined under applicable state law, including Illinois BIPA) through the current Service. If this changes, we will update this Policy and provide appropriate notice and consent mechanisms.

3. How We Use Information
We use Personal Information to:
- Operate and maintain the Service
- Provide real-time water quality monitoring and alerts
- Improve device performance and develop new features
- Ensure security and prevent fraud
- Comply with legal obligations

4. How We Share Information
We do not sell or share personal information for cross-context behavioral advertising as defined under applicable law.
We do not share personal information with advertising networks or ad measurement platforms. Any third-party analytics tools we use are configured to receive only non-personal, aggregated usage data.
We may share information:
- Service Providers:
  - Amazon Web Services (AWS) - cloud infrastructure
  - Stripe, Inc. / PayPal, Inc. - payment processing
  - Identity verification providers
- Legal Requirements: Where required by law
- Business Transfers: Mergers or acquisitions
- With Consent: Where you explicitly agree
We maintain appropriate data processing agreements with all service providers who process personal information on our behalf.

5. Sensitive Personal Information
We use sensitive personal information only as necessary to:
- Provide the Service
- Maintain and improve functionality
- Comply with legal obligations
California residents may request to limit the use of sensitive personal information by contacting us at mac@i-factory.co.kr.

6. Cookies and Tracking
We use cookies and similar technologies to:
- Maintain sessions
- Analyze usage
- Improve performance
We do not use third-party advertising tracking technologies.
You may disable cookies through your device or browser settings, but some features may not function properly.
We honor Global Privacy Control (GPC) opt-out signals where required by applicable state law.

7. Data Retention
- Account Data: Retained until account deletion
- Device Data: Retained for up to 2 years, then de-identified
- Transaction and Legal Records: Retained up to 5 years as required by law
We will respond to verified privacy requests within 45 days, which may be extended where permitted by law.
We will delete or anonymize personal information within 45 days for California residents (with a possible 45-day extension where permitted by law), and within a commercially reasonable period for other users, subject to legal retention requirements.

8. Your Privacy Rights (CCPA/CPRA)
Depending on your state of residence, you may have the right to:
- Access your personal information
- Request deletion of your personal information
- Request correction of inaccurate data
- Limit use of sensitive personal information (California residents)
- Non-discrimination for exercising your rights

How to Exercise Your Rights
- Email: mac@i-factory.co.kr
- Web: https://www.i-factory.co.kr/qna
We will verify your identity before processing requests.
If we deny your request, you may appeal by contacting mac@i-factory.co.kr within 30 days of denial. We will respond to your appeal within 45 days.

9. Children's Privacy (COPPA)
The Service is not intended for children under 13.
We do not implement automated age-verification technology. If you believe your child under 13 has created an account, contact us at mac@i-factory.co.kr immediately.
If we discover that we have collected personal information from a child under 13 without verified parental consent, we will delete such information within 5 business days.

10. International Data Transfers
Personal information may be processed in the United States and accessed from the Republic of Korea for maintenance and support.
We implement appropriate safeguards, including contractual and technical measures, to protect personal information during such transfers.

11. Data Security
We implement security measures including AES-256 encryption at rest, TLS 1.2 or higher in transit, role-based access controls, security monitoring, and incident response procedures. Access to personal information is limited to personnel with a documented business need, and all access is logged and audited.
In the event of a data breach, we will notify affected users and relevant authorities as required by applicable law. For breaches involving health-related personal information, we will additionally notify the FTC and, where required, relevant media outlets in accordance with the FTC Health Breach Notification Rule, within the timeframes prescribed by law.

12. Email Communications
We may send:
- Service-related communications (account notifications, alerts)
- Marketing communications (only with your consent)
All marketing emails will include our valid physical postal address and a one-click unsubscribe link.
You may opt out of marketing emails at any time by using the unsubscribe link or contacting us at evan@i-factory.co.kr.
Opt-out requests are processed within 10 business days.

13. Do Not Sell or Share My Personal Information
We do not sell or share personal information for cross-context behavioral advertising.
We honor Global Privacy Control (GPC) signals for applicable state residents.
You may submit privacy-related requests at:
- Email: mac@i-factory.co.kr
- Web: https://www.i-factory.co.kr/qna

14. Changes to This Policy
We may update this Privacy Policy from time to time.
Material changes will be notified at least 30 days in advance.

15. Contact Us
For questions or requests regarding this Privacy Policy:
- Email: evan@i-factory.co.kr
- Web: https://www.i-factory.co.kr
- Address: #303, 64 Yeonsuwon-ro, Danwon-gu, Ansan-si, Gyeonggi-do, 15432, Republic of Korea
- Phone: +82.31.5182.9393

16. Complaints
If you believe we have not addressed your privacy concerns, you may contact:
- The Federal Trade Commission (FTC)
- Your state Attorney General