App Name: Cleio Bundle ID: io.cleio.app Operator: Kidae Lee (이기대) Contact: kdwara@icloud.com Address: 7, Yangdal-ro, Gwangmyeong-si, Gyeonggi-do, Republic of Korea Business Registration No.: 611-48-01233 Version: 1.5 Effective Date: 2026-09-09 ※ The “Version” above refers to the version of this Privacy Policy document, which is separate from the app version. Last Updated: 2026-09-11

This document is a translation provided for convenience only. The Korean-language version is the authoritative original. In case of any conflict between this translation and the Korean original, the Korean original shall prevail.

Table of Contents

  1. Overview
  2. Data We Collect
  3. Purposes of Processing
  4. Retention Periods
  5. Third-Party Disclosure
  6. Outsourced Processing 6-2. Prior Consent for Cloud AI Features 6-3. Private Cloud Compute Summarization 6-4. MCP Local Integration 6-5. System Audio Capture 6-6. Separate Consent for the Processing of Sensitive Information
  7. International Data Transfers
  8. Your Rights and How to Exercise Them
  9. Data Deletion and Destruction
  10. Automatic Data Collection
  11. App Permissions
  12. Children’s Privacy
  13. Data Security
  14. Privacy Officer
  15. Changes to This Policy
  16. Contact and Remediation Bodies
  17. Special Provisions for Users in the European Economic Area (EEA), the United Kingdom, and Switzerland

Article 1. Overview

Cleio (the “App”) is an iOS and macOS application operated by Kidae Lee (the “Operator”) that provides voice recording, real-time speech-to-text transcription, speaker diarization, and AI summarization. This Privacy Policy explains how the Operator collects, uses, stores, and protects your personal information when you use the App.

By using the App, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with its terms, please do not use the App.

Article 2. Data We Collect

2.1 Data You Create Directly

Data Purpose Storage External Transfer Retention
Audio recordings (M4A) Core service — voice recording Local device + iCloud (Pro) None Until deleted by user
System audio capture (macOS, Pro) Captures another app’s audio, chosen directly by the user on the “New Recording” screen (Article 6-5) Local device + iCloud Drive (Pro, if iCloud sync is on) None Until deleted by user
Transcription text Speech-to-text conversion results Local (SwiftData) + iCloud (Pro) OpenAI API (Pro text correction / summarization / translation; text only); a program the user has connected, if MCP Local Integration is on (Article 6-4) Until deleted by user
AI summary text Meeting/conversation summaries Local (SwiftData) + iCloud (Pro) OpenAI API or Private Cloud Compute (Pro summarization, depending on the engine the user selects in Settings; text only); a program the user has connected, if MCP Local Integration is on (Article 6-4) Until deleted by user
Action items (to-dos) To-do items extracted from summaries Local (SwiftData) + iCloud (Pro) + Reminders app (EventKit, when the user syncs) None (except a program the user has connected, if MCP Local Integration is on — Pro, default OFF, Article 6-4) Until deleted by user
Speaker diarization results Per-utterance speaker identification Local (SwiftData) + iCloud (Pro) None (except a program the user has connected, if MCP Local Integration is on — Pro, default OFF, Article 6-4) Until deleted by user
Calendar event matching data (event title, identifier, date/time) Automatic matching of recordings with Calendar events Local (SwiftData) + iCloud (Pro) None (except that, where an automatically matched event title is used as a recording’s displayed title, that title may be exposed to a connected program for users who have turned MCP Local Integration on — Article 6-4) Until deleted by user
Translation text (Pro) Display original/translated text for multilingual meetings Local (SwiftData) + iCloud (Pro) OpenAI API (when user requests translation; text only) Until deleted by user
App settings User preferences UserDefaults + iCloud KVS (Pro) None Until app deletion

Audio files are never transmitted to the Operator’s servers, to OpenAI, or to Apple. If a Pro subscriber enables iCloud sync, audio files are stored and synced to the user’s own Apple iCloud. Only text is sent to OpenAI or Private Cloud Compute, and it is transmitted only after the separate consent under Article 6-6 has been given and the user directly enables, selects, or invokes the relevant feature in Settings (see Article 6-2 for text correction/translation/GPT summarization, and Article 6-3 for Private Cloud Compute summarization).

Transcription text and AI summaries may contain sensitive information. What is recorded is decided by the user, and the Operator does not screen its contents in advance. When such text is sent to a cloud AI service, the Operator obtains separate consent under Article 23 of the Personal Information Protection Act — see Article 6-6 for the scope of sensitive information that may be included and for how to give or withdraw that consent. If cloud AI features are not used, this text never leaves the device (and, for Pro subscribers, the user’s own iCloud).

Audio recorded via System Audio Capture (Pro, macOS only) may include the voices of third parties, such as call or meeting participants. For details on where this audio is processed and the user’s responsibilities, see Article 6-5.

Calendar event data is read only on-device and is never transmitted to the Operator’s servers. When Calendar permission is granted, the App reads event information solely to match recordings with Calendar events, and caches only the matching event’s title, identifier, and date/time on the device; for Pro subscribers this cached metadata syncs only to the user’s own Apple iCloud. Denying Calendar permission does not affect core features such as recording, transcription, and summarization.

2.2 Automatically Collected Data

Data SDK Purpose Destination
App usage events Firebase Analytics Service improvement Google LLC (United States)
Crash logs Firebase Crashlytics Stability improvement Google LLC (United States)
App performance metrics Firebase Performance Performance monitoring Google LLC (United States)
Subscription status StoreKit 2 Payment management Apple Inc. (United States)

Automatically collected data does not include recording content or transcription text.

2.2-A Storage Optimization (Pro, opt-in)

When the user explicitly enables “Storage Optimization,” the Operator processes data as follows.

Article 3. Purposes of Processing

The Operator processes personal information for the following purposes.

  1. Core Service Delivery — Audio recording, speech-to-text transcription, real-time speaker diarization, and AI summarization.
  2. Pro Subscription Features — OpenAI-powered text correction, GPT summarization, and multilingual meeting translation; Private Cloud Compute AI summarization (when selected by the user in Settings); iCloud synchronization (real-time data and storage optimization); export capabilities (Markdown/PDF).
  3. Two-Way Reminders Synchronization (opt-in) — Two-way sync of action items with the Reminders app (EventKit).
  4. Calendar Event Automatic Matching (opt-in) — Automatically linking recordings with Calendar (EventKit) events for easier management.
  5. Service Improvement — Analysis of anonymized usage patterns to enhance features and user experience.
  6. Stability and Performance — Collection of crash reports and performance metrics to maintain and improve app reliability.
  7. Payment Processing — Managing subscription status through Apple’s StoreKit.
  8. User Preferences — Storing and synchronizing app settings across devices (Pro).
  9. Providing MCP Local Integration (Pro, User’s Choice) — Allowing a program the user has connected directly on this Mac to query the recording library and edit titles, folders, domains, and action item completion.
  10. Providing System Audio Capture (Pro, macOS only, User’s Choice) — Capturing the audio of another app the user selects directly on the “New Recording” screen, to support recording meetings and calls.

Article 4. Retention Periods

Personal information is retained until the purpose of collection is fulfilled.

Data Category Retention Period Destruction Method
Audio recordings Until deleted by user within the App Removed from local storage and iCloud
Transcription text, AI summaries, speaker diarization results, action items, translation text, calendar matching data Until deleted by user within the App Removed from SwiftData and iCloud
App settings Until app is deleted from device Cleared on app uninstallation
Firebase Analytics data Per Google’s data retention policy (default: 14 months) Automatic expiration
Firebase Crashlytics data Per Google’s data retention policy (default: 90 days) Automatic expiration
Firebase Cloud Functions logs (OpenAI proxy, payment verification) Per Google Cloud Logging default retention (30 days); no personally identifying content Automatic expiration
OpenAI API transmitted data (text correction, summarization, translation) Deleted within 30 days per OpenAI’s API data policy; not used for model training Automatic deletion by OpenAI
Private Cloud Compute transmitted data (AI summarization, when selected by the user in Settings) Per Apple’s published policy — not independently verified by the Operator (see Article 6-3) Not retained after processing, per Apple’s published policy
Reminders (EventKit) data Per the Reminders app’s retention policy Deleted when the user removes the item in the Reminders app, or when the user excludes it during a sync or deletes the action item in Cleio

If retention is required by law, the relevant data is stored separately and destroyed after the statutory retention period expires.

Article 5. Third-Party Disclosure

As a general rule, the Operator does not provide personal information to third parties. Exceptions include:

Where the user has turned on MCP Local Integration (Article 6-4) themselves, allowing a program they have connected to read and edit their data falls under “the user has given prior consent” above.

The Operator does not sell, rent, or trade personal information to any third party.

Article 6. Outsourced Processing

The Operator entrusts certain data processing to the following service providers for the purpose of delivering the Service. These providers process data solely on the Operator’s behalf and under the Operator’s instructions.

Processor Entrusted Task Retention Contact
OpenAI, Inc. (United States) Pro: transcription text correction, AI summarization, multilingual translation (text only; no audio) Deleted within 30 days; not used for model training privacy@openai.com
Google LLC (United States) Firebase analytics, crash reporting, performance monitoring, and Cloud Functions infrastructure operation (OpenAI proxy, subscription verification, usage management) Per Google’s retention policy https://firebase.google.com/support/privacy
Apple Inc. (United States) StoreKit payment processing, iCloud storage (Pro), Reminders (EventKit) data storage, Private Cloud Compute AI summarization (Pro, when directly selected by the user in Settings) Per Apple’s retention policy https://www.apple.com/privacy

The Operator maintains agreements (or applicable standard terms, the Apple App Store agreement, and the OpenAI Data Processing Addendum) with processors governing data protection obligations and oversees their compliance.

Private Cloud Compute AI summarization is transmitted directly from the user’s device to Apple’s servers, without passing through the Operator’s servers. See Article 6-3 for details.

MCP Local Integration is not an entrustment to a processor selected by the Operator; it is the user’s own act of granting access to a program the user has chosen and connected. See Article 6-4 for details.

Audio captured through System Audio Capture (Pro, macOS only) does not involve any new processor; it is processed through the same path as microphone recordings. See Article 6-5 for details.

Article 6-2. Prior Consent for Cloud AI Features

The Operator provides the following Pro features that utilize OpenAI, Inc.’s (United States) GPT services.

Feature Transmitted Data Recipient Default State
Text correction (Pro) Transcription text (STT), language settings, user term dictionary OpenAI, Inc. (United States) Inactive (default OFF)
AI summary (Pro) Transcription text (STT), recording title, domain tag, summary length setting OpenAI, Inc. (United States) Only when explicitly invoked by the user
Multilingual meeting translation (Pro) Transcript segment (source text), source language, target language OpenAI, Inc. (United States) Automatically runs if the auto-translate toggle is on (default OFF), or runs manually when the user directly requests a translation

Automatic domain detection: When AI summary is run, the full transcription text is also sent to OpenAI in order to automatically determine the summary domain. This processing is part of running “AI summary” above and does not create a new, separate point of transmission. When Private Cloud Compute summarization is selected, this automatic detection is not performed (see Article 6-3, “Relationship to Domain Detection”).

Not transmitted: audio files, account identifiers (email, IDFA, etc.), device identifiers.

Data is transmitted to OpenAI only when both of the following steps have taken place.

  1. Separate consent for the processing of sensitive information — given by the user on a dedicated consent screen (Article 6-6). This consent is optional, and no data is transmitted before it is given. Without this consent the toggles below cannot be turned on, and any that were previously on are turned off when the app launches.
  2. Enabling or invoking the specific feature — the user’s own act of turning on a toggle or tapping a button, as described below.

“Prior consent” in this Article means both of these steps together. If either is missing, no data is transmitted.

Before purchasing a Pro subscription, the subscription screen displays a notice describing the cloud AI features, the scope of data transmitted, and a link to this Privacy Policy. Users can review this notice and this Article before deciding whether to turn on the toggles or use the buttons described above.

Transmitted text is deleted within 30 days of transmission under OpenAI’s API policy and is not used for model training (see Articles 4 and 6).

No data is transmitted to OpenAI until the user takes one of the actions above. Whether each feature (text correction, AI summary, multilingual translation) is enabled is managed independently per feature, and that state is stored only on the device (not synchronized to iCloud).

The user may withdraw consent in the following ways.

Cloud-Free Alternatives

The App provides the following on-device processing as the default, allowing core functionality to be used without consenting to the cloud AI features above.

Article 6-3. Private Cloud Compute Summarization

The Operator provides the following Pro feature built on Apple Inc.’s (United States) Private Cloud Compute technology. In the App, this feature is displayed as “Private Cloud Compute.” Under this Policy, and consistent with Article 6, Apple is treated as a processor for this activity.

Feature Transmitted Data Recipient Default State
AI summary (Pro) Transcription text (STT, including speaker labels), the recording title the user has directly given it (auto-generated titles are excluded), domain tag, summary length/tone settings, language setting, recording date/time Apple Inc. (United States) — Private Cloud Compute Inactive — the default remains GPT; this option is used only when the user directly selects it in Settings

The data the Operator transmits does not include the following: audio files, account identifiers (email, IDFA, etc.), device identifiers. The Operator has not independently verified whether the actual transport layer of the request to Apple carries any other information.

Availability: This feature is available only to Pro subscribers on iOS 27 / macOS 27 or later whose device meets Apple’s eligibility requirements. On devices that do not meet these requirements, this option is not displayed at all.

In Settings > AI Models > “Summary AI,” the user directly chooses one of the following three options.

“Prior consent” in this Article means, together, both the separate consent for the processing of sensitive information under Article 6-6 and the user’s direct act of selecting “Private Cloud Compute” (or “Automatic,” which may fall back to it) on the screen described above. Without the separate consent, no data is transmitted even if this selection is made, and no data is transmitted to Apple before the user makes this selection either.

Relationship to Domain Detection

The feature that automatically detects a summary’s domain (see Article 6-2) works by transmitting the full transcript to OpenAI. This automatic domain detection does not run for summaries processed via Private Cloud Compute — if a domain has already been saved, that value is used; otherwise, Private Cloud Compute’s own model follows its built-in instructions to infer the domain. Accordingly, the transcript of a summary processed via Private Cloud Compute is never transmitted to OpenAI.

Whether the Backend Is Involved

Summarization via Private Cloud Compute is transmitted directly from the user’s device to Apple’s servers, without passing through the Operator’s Google Firebase Cloud Functions backend (see Article 13). As a result, the Operator retains no call logs for this processing, and it does not deduct from Pro usage (credits).

Usage Limits

Apple imposes its own usage limit on this feature. The information Apple provides does not include an exact remaining count or reset cycle — only a three-tier status (“plenty remaining,” “approaching the limit,” “limit reached”) and, where available, the next reset time. Accordingly, this Policy and the App do not characterize the usage cycle as “daily” or “monthly.” This limit is separate from the Pro usage (credits) managed by the Operator (see Articles 6-2 and 13).

Retention — Based on Apple’s Published Statements

Apple has publicly stated that it does not retain the content of requests processed by Private Cloud Compute. This statement reflects Apple’s own published policy and has not been independently verified by the Operator. Please refer to Apple’s publicly available materials for the most current information on retention and processing.

Cloud-Free Alternative

Core functionality remains available via on-device summarization (Apple Foundation Models; see Article 6-2) without consenting to this feature.

Article 6-4. MCP Local Integration

The Operator provides the following Pro feature (“MCP Local Integration”) that lets another program the user runs directly on this Mac (the “Connected Program”) query the user’s own Cleio library and modify a limited set of items in it. This feature is available only in the macOS version of Cleio, and its default state is inactive (OFF).

   
Data made available Recording list metadata (title, recording date/time, duration, status, folder, speaker count, domain), full transcript (per-segment speaker labels and start/end times), summary text (the version currently shown to the user), action item (to-do) list, folder list, linked calendar event details (event title, date/time, calendar name, and attendee names)
Not made available Audio files and their storage paths, account identifiers (e.g., email), device identifiers, calendar attendees’ email addresses and RSVP status
Recipient Not the Operator or a processor selected by the Operator, but a separate program running on this Mac that the user has chosen to connect themselves
Default state Inactive (default OFF) — the user must turn it on directly in Settings

Note on calendar attendees: When a recording is linked to a calendar event, retrieving that recording’s detail also provides the event’s attendee names. Attendee information is not cached on the device (the calendar cache scope in Article 2 remains title, identifier, and date/time) and is read directly from the device’s calendar at the time of the request. It is not provided if calendar permission is absent or the event has been deleted. Attendees’ email addresses and RSVP status are not provided — a name is what is needed to answer “who attended,” whereas an email address is a persistent identifier for a specific person. Attendees are not included in list results.

Note on titles: The “title” above includes not only a title the user has directly given a recording, but, when none has been given, a calendar event’s title shown via automatic matching, or the system’s date-based default title — whatever title is currently displayed on screen is what goes out.

How this differs from Articles 6-2 and 6-3: Those Articles describe processing relationships the Operator has established with named vendors (OpenAI, Apple). This feature is different — the Operator does not know, and does not choose, which program connects. Selecting a Connected Program and authorizing it by entering the access token is entirely the user’s own act.

How It Works

Turning on “MCP Local Integration” in Settings opens a server that responds only to this Mac itself (the loopback address, 127.0.0.1). No other device on the same network can reach it. Connecting requires an access token this app generates and stores in the device’s Keychain; the user must enter this token into the Connected Program themselves to complete the connection. The server runs only while the app is running and stops when the app quits.

The Connected Program may request only four kinds of edits: renaming a recording, moving it to a folder, setting its domain, and toggling an action item’s completion state. It cannot request any action that consumes Pro usage (credits), such as generating an AI summary, translating, or correcting text.

Reach into the Reminders app: If the Connected Program toggles the completion state of an action item the user has already exported to the Reminders app, that change is also applied to the corresponding item in the Reminders app (the same path as Reminders synchronization described in Article 2). This is the only case in which an edit made through this channel reaches outside the Cleio app, and it does not apply to items that have not been exported to Reminders.

“Prior consent” in this Article means the user’s own act of turning on “MCP Local Integration” in Settings. No data is made available through this channel until the toggle is turned on.

Limits on the Operator’s Responsibility for Downstream Handling

The recipient on this channel is not the Operator, but a separate program the user has chosen and connected themselves. The Operator does not know, and has no control over, what that program is or how it subsequently stores, uses, or retransmits the data it receives — including if that program itself forwards the data to another AI service. Any processing by that program is governed by its own terms and privacy policy, not this Policy. Choosing a Connected Program and reviewing how it handles data is the user’s own responsibility.

Alternative Without This Feature

This feature is off by default. Leaving it off does not affect any core functionality — recording, transcription, speaker diarization, AI summarization — or any other Pro feature.

Security Measures

Article 6-5. System Audio Capture

On the macOS version of Cleio, the Operator provides the following Pro feature (“System Audio Capture”), which captures the audio output of another app the user directly selects on the “New Recording” screen — as that app’s own output signal, not as a re-recording through the microphone. This feature is provided only on the macOS version of Cleio; the free plan and the iOS version offer microphone recording only.

Item Description
What is captured The audio output of a single app the user directly selects on the “New Recording” screen before starting a recording, captured at the process level using macOS’s Core Audio process tap technology
Simultaneous microphone capture The microphone is additionally recorded only if the user turns on “Include My Voice”
Processing/storage path Captured audio is stored and processed through the same path as microphone recordings — everything downstream (transcription, speaker diarization, summarization, cloud AI processing) follows Articles 2, 4, 6-2, and 6-3 exactly as for any other recording
Default state Not a persistent background capture — the user must directly select the app to capture each time a recording is started

Third-party voices (e.g., call or meeting participants) may be included

The app the user chooses to capture may be a call or video conferencing app whose output includes the voices of other participants. In that case, the captured audio may include the voices of third parties who took part in the call or meeting, in addition to the user’s own voice. Complying with applicable law when recording such third parties — including disclosing that a recording is being made and obtaining any consent that law requires — is the user’s responsibility; see Article 7 of the Terms of Service for details. The Operator has no knowledge of what the user chooses to capture and does not separately obtain consent from any third party whose voice is captured.

Where data is stored and processed

Captured audio files, and the transcripts, speaker diarization results, and summaries generated from them, are by default stored and processed only on this Mac. They are never transmitted to the Operator’s servers, to OpenAI, or to Apple, and audio files are stored and synced to the user’s own Apple iCloud Drive only if a Pro subscriber has enabled iCloud sync (see Article 2). If the user directly enables, selects, or invokes text correction, GPT summarization, translation, or Private Cloud Compute summarization in Settings, the resulting text — and only that text — may be transmitted to OpenAI or Apple under Articles 6-2 and 6-3.

Indicator while recording

While System Audio Capture is in progress, a persistent visual indicator is shown in the menu bar icon and in the recording screen (window) to show that capture is under way. Because capture can continue even when sound cannot be heard (e.g., while muted), this indicator exists so the user can always confirm, visually, whether capture is active.

Permission required

This feature requires macOS’s “Screen & System Audio Recording” permission, separate from microphone permission (see Article 11). If this permission is not granted, System Audio Capture does not operate; core functionality, including microphone recording, continues to work normally in that case.

“Prior consent” in this Article means the user’s acts of (1) granting the “Screen & System Audio Recording” permission macOS requests the first time it is needed, and (2) directly selecting the app to capture on the “New Recording” screen, every time. This feature does not operate unless the user selects an app to capture.

Alternative Without This Feature

Without using this feature, you can still use the App’s core functionality — microphone recording, transcription, speaker diarization, and on-device AI summarization — on the free plan in the same way.

Article 6-6. Separate Consent for the Processing of Sensitive Information

Article 23 of the Korean Personal Information Protection Act (PIPA) requires that, when sensitive information is to be processed, consent be obtained separately from consent to the processing of other personal information. The Operator obtains this separate consent for the cloud AI features (Articles 6-2 and 6-3).

Transcription text (STT) is a direct transcript of the conversation the user has recorded, so its content may include sensitive information as defined in Article 18 of the Enforcement Decree of the same Act. The Operator does not pre-screen recording content in any way; what to record is entirely up to the user.

The categories of sensitive information that may be included are: information concerning ideology or belief; joining or leaving a labor union or political party; political views; health; sex life; genetic information; criminal history; biometric information; and race or ethnicity.

In particular, AI summary determines a conversation’s domain and extracts items suited to that domain. Depending on what is discussed, the resulting summary may include sensitive content such as health, ideology, or political views. In addition, cloud AI features — including text correction and translation — transmit the full text of the transcription as is and do not separately filter out sensitive content.

The consent screen is shown through either of the following paths.

Turning on the toggle in Settings does not by itself constitute consent — the consent screen must always be shown. Likewise, features that run automatically without any user action, such as “Auto Text Correction” and “Automatic Translation,” cannot be turned on without this consent. Attempting to turn one on beforehand shows a notice, and it is turned on only if consent is given on this screen. Any such feature that was already on is turned off when the app launches, and withdrawing consent turns it off as well.

The consent screen discloses the following.

Disclosed Item Content
Purpose of processing Summarization, text correction, multilingual translation (including domain detection for summarization)
Data processed The full text of the transcription, language settings, your term dictionary, recording titles, domain tags, and summary length and tone settings — audio files are not transmitted
Retention and use period OpenAI: deleted within 30 days of transmission / Apple: per Apple’s published statements, not retained after the request is processed (see Article 6-3, “Retention”)
International transfer Recipients: OpenAI, Inc. and Apple Inc. / Country: United States / Timing and method: transferred over an encrypted connection when a cloud AI feature is invoked (Article 7)
Right to refuse consent You may refuse consent; refusing results only in the feature limitations described below

On the consent screen, the consent item is not pre-selected; the user must actively select it before the “Agree” button becomes enabled. To decline, the user may select “Decline and Continue” on the same screen; the rest of the app remains fully available in that case.

This consent is optional. Declining it does not affect the following features, which remain fully available — recording, transcription (STT), speaker diarization, and on-device AI summarization. Other Pro subscription benefits (iCloud sync, export, etc.) are not restricted either.

Declining this consent restricts only the cloud AI features (text correction, AI summary, multilingual translation, and domain detection, including Private Cloud Compute summarization).

The Operator records the time consent was given and the version of this Policy in effect at that time, on the user’s own device. This record is stored only on the user’s own device (not synchronized via iCloud); the consent timestamp can be checked in Settings > AI Models > “Cloud AI Consent.”

Turning off the “Cloud AI Consent” toggle in Settings > AI Models immediately withdraws consent. Once withdrawn, cloud AI features stop and only on-device processing remains; no further data is transmitted to OpenAI or Apple.

Withdrawal is effective only prospectively. The retention or deletion of data already transmitted before withdrawal is governed by Articles 6-2 and 6-3 and by each processor’s own policies.

Article 7. International Data Transfers

Your personal information may be transferred to and processed in countries outside your country of residence as follows.

Recipient Country Data Transferred Purpose Timing and Method of Transfer Recipient’s Retention and Use Period Legal Basis
OpenAI, Inc. United States Transcription text, summary input text, translation input text (only when the user enables or directly invokes the relevant Pro feature in Settings) Text correction, GPT summarization, multilingual translation Transmitted over an encrypted connection (HTTPS) at the time the relevant feature is invoked Deleted within 30 days of transmission Separate consent for sensitive information (Article 6-6) + the user directly enabling or invoking the feature (Article 6-2)
Google LLC United States (a) Anonymized app usage events, crash logs, performance metrics; (b) Cloud Functions invocation logs (no personally identifying content) Analytics, stability, and performance monitoring; backend infrastructure operation (OpenAI proxy, subscription verification, usage management) Transmitted over an encrypted connection (HTTPS) at the time of app usage or feature invocation Per the retention periods in Article 4 Performance of service contract
Apple Inc. United States Payment information, iCloud-synced data (Pro), Reminders (EventKit) data Payment processing, cloud storage, two-way Reminders synchronization Transmitted over Apple’s own encrypted channel at the time of payment or sync Per Apple’s policy (until the user deletes it from iCloud) Performance of service contract
Apple Inc. United States Transcription text, summary input text (including any recording title the user has directly given it), domain tag, and summary length/tone/language settings (only when the user directly selects Private Cloud Compute summarization in Settings) Private Cloud Compute AI summarization Transmitted directly from the device to Apple’s servers over an encrypted connection at the time of summarization (not passing through the Operator’s backend) Per Apple’s published statements, not retained after the request is processed (see Article 6-3, “Retention”) Separate consent for sensitive information (Article 6-6) + the user directly selecting the feature (Article 6-3)

These transfers are conducted in compliance with Article 28-8 of the Korean Personal Information Protection Act (PIPA) regarding cross-border data transfers.

Method and Procedure for Refusing the Transfer: You may refuse international transfers of your data. Transfer of transcription text to OpenAI and Apple can be refused by declining the separate consent under Article 6-6 (selecting “Decline and Continue” on the consent screen) or, if you have already consented, by turning off “Cloud AI Consent” in Settings > AI Models, which stops the transfer immediately. Refusing does not affect your continued use of recording, transcription, speaker diarization, or on-device summarization. Transfer to Apple in connection with payment, iCloud sync, and Reminders can be refused by not using the corresponding feature (subscription, iCloud sync, or Reminders integration), and transfer to Google (analytics, crash logs, and performance metrics) can be stopped by sending a request to kdwara@icloud.com — the App does not currently provide an in-app toggle to disable these individually (Article 13). In those cases, the refused feature (subscription payment, iCloud sync, or Reminders integration) is not available.

Recipient Contact Information: OpenAI, Inc. — privacy@openai.com / Apple Inc. — https://www.apple.com/legal/privacy/contact/ / Google LLC — https://support.google.com/policies/contact/general_privacy_form

Article 8. Your Rights and How to Exercise Them

You (or your legal representative) may exercise the following rights.

  1. Request access to your personal information
  2. Request correction or deletion of your personal information
  3. Request suspension of processing of your personal information
  4. Withdraw consent

How to exercise your rights

During the period in which a correction or deletion request is being processed, the Operator will not use or disclose the relevant personal information.

Article 9. Data Deletion and Destruction

Personal information for which the purpose of collection has been fulfilled is destroyed without delay.

Destruction methods

Article 10. Automatic Data Collection

Cleio does not use cookies or web-based tracking technologies. However, the following SDKs automatically collect data for service improvement purposes.

These SDKs are provided by Google LLC and operate under Google’s Privacy Policy (https://policies.google.com/privacy).

Article 11. App Permissions

Cleio requests the following device permissions.

Permission Purpose Required
Microphone Audio recording Required
Calendar (EventKit) Automatic matching of recordings with Calendar events Optional — if declined, recording/transcription/summarization features continue to work normally; only the Calendar automatic matching feature is disabled
Reminders (EventKit) Two-way action item synchronization between the App and the Reminders app Optional — if declined, transcription/summarization features continue to work; only the Reminders sync feature is disabled
Screen & System Audio Recording (macOS, TCC) Capturing the audio of another app the user selects (Pro, System Audio Capture) Optional — if declined, core functionality including microphone recording continues to work normally; only System Audio Capture is disabled

Article 12. Children’s Privacy

Cleio is not directed at children under the age of 14. The Operator does not knowingly collect personal information from children under 14.

The Operator takes the following measures to protect children’s privacy.

Article 13. Data Security

The Operator implements the following technical and administrative safeguards to protect personal information (in accordance with Article 29 of the Enforcement Decree of the Korean Personal Information Protection Act).

Technical Safeguards

Administrative Safeguards

Article 14. Privacy Officer

The following person is responsible for overseeing all personal information processing matters and handling complaints and inquiries from data subjects.

Role Details
Privacy Officer Kidae Lee (이기대)
Email kdwara@icloud.com
Responsibilities Overseeing all personal information processing, handling data subject complaints and inquiries, and remedying any violations of data subject rights

Article 15. Changes to This Policy

The Operator may update this Privacy Policy. When changes are made:

  1. The updated policy will be posted within the App.
  2. The “Version” and “Effective Date” at the top of this document will be updated.
  3. For changes that are unfavorable to users, prior notice of at least 30 days will be provided via in-app notification or email before the changes take effect.

Your continued use of the App after the updated policy takes effect constitutes your acknowledgment of the changes.

Article 16. Contact and Remediation Bodies

For questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact:

You may also contact the following organizations for personal information dispute resolution.

Organization Contact
Personal Information Dispute Mediation Committee (개인정보분쟁조정위원회) 1833-6972 / https://www.kopico.go.kr
Personal Information Infringement Report Center (개인정보침해신고센터) 118 / https://privacy.kisa.or.kr
Supreme Prosecutors’ Office Cyber Investigation Division (대검찰청 사이버수사과) 1301 / https://www.spo.go.kr
National Police Agency Cyber Bureau (경찰청 사이버수사국) 182 / https://ecrm.cyber.go.kr

Article 17. Special Provisions for Users in the European Economic Area (EEA), the United Kingdom, and Switzerland

This Article applies where the user resides in the European Economic Area (EEA), the United Kingdom, or Switzerland, and applies in addition to the other Articles of this Policy under the EU General Data Protection Regulation (GDPR) and each jurisdiction’s applicable data protection law. Where this Article conflicts with another Article, this Article prevails.

Controller

Item Details
Controller Kidae Lee (sole developer)
Address 7, Yangdal-ro, Gwangmyeong-si, Gyeonggi-do, Republic of Korea
Contact kdwara@icloud.com
Processing Activity Legal Basis
Recording, transcription (STT), speaker diarization, and on-device summarization — processed only on this device Performance of a contract (GDPR Article 6(1)(b))
iCloud sync, Reminders/Calendar integration, subscription payment Performance of a contract (GDPR Article 6(1)(b))
Cloud AI features (text correction, AI summary, multilingual translation, and domain detection, including Private Cloud Compute summarization) — transcription text may include sensitive information (a special category under the GDPR) Explicit consent (GDPR Article 9(2)(a)) — separate consent under Article 6-6
App usage events, crash logs, and performance metrics (anonymized) Legitimate interests (GDPR Article 6(1)(f)) — service stability and quality improvement

This consent is a single consent covering both OpenAI and Apple; you cannot selectively decline one of the two recipients. However, whether each feature actually runs is managed separately through per-feature settings (Auto Text Correction and Auto-Translate default to OFF; summarization always runs only when you directly invoke it).

Cloud AI features do not run without explicit consent. This consent is optional; declining it does not affect recording, transcription, speaker diarization, or on-device summarization (Article 6-6).

Rights of Data Subjects

Users may exercise the following rights. For users to whom this Article applies, the one-month processing period below applies instead of the 10-day period in Article 8.

Right Legal Basis How to Exercise It
Right of access GDPR Article 15 You can view your stored data directly within the App. For anything else, please submit a request by email
Right to rectification GDPR Article 16 You can correct it directly within the App
Right to erasure (“right to be forgotten”) GDPR Article 17 You can delete recordings, summaries, and related data directly within the App. Deleting the App also deletes the data stored on your device
Right to restriction of processing GDPR Article 18 Please submit a request by email
Right to data portability GDPR Article 20 Summaries can be downloaded directly using the App’s Export (Markdown) feature — PDF is an additional format provided for convenient viewing; Markdown is the reference format for fulfilling this right. For any other data, please submit a request by email
Right to object GDPR Article 21 To object to analytics collection (Firebase Analytics), crash logs, or performance metrics, please submit a request by email — the App does not currently provide an in-app toggle to disable these individually (Article 10)
Right to withdraw consent GDPR Article 7(3) Turning off Settings > AI Models > “Cloud AI Consent” in the App withdraws consent immediately. Withdrawal is effective only prospectively

The Operator will process your request within one month of receipt. Where a request is complex or numerous, this period may be extended by up to two months, and the Operator will inform you of the reason. Exercising these rights is free of charge (except for manifestly unfounded or excessive, repetitive requests).

The Operator does not hold most of this data. Recordings, transcriptions, and summaries are stored on your device (and, if you have turned on iCloud sync, in your own Apple iCloud) — not on the Operator’s servers (Article 13). Accordingly, a substantial portion of access and erasure requests can be handled directly and immediately by you within the App.

Automated Decision-Making (GDPR Article 22)

The Operator does not carry out automated decision-making or profiling that produces legal effects concerning the user or similarly significantly affects the user. AI summarization and domain detection are content-processing operations the user has requested; they do not evaluate or make decisions about the user.

Complaints to a Supervisory Authority

You have the right to lodge a complaint with the data protection supervisory authority of your country of residence or place of work.

Before filing a complaint, please contact us using the details above, and we will make every effort to resolve the matter promptly.

Basis for International Transfers

Transfer Destination Basis
Republic of Korea (the Operator’s country) The European Commission’s adequacy decision (December 17, 2021, Republic of Korea) — transfers can be made without a separate transfer mechanism such as standard contractual clauses. This decision is accompanied by supplementary rules (a notification of Korea’s Personal Information Protection Commission) that recipients in Korea must comply with, and the Operator complies with them
United States — OpenAI, Inc. · Apple Inc. · Google LLC Appropriate safeguards published by each company (such as standard contractual clauses)

The adequacy decision above is a decision of the European Commission. The United Kingdom and Switzerland each make their own adequacy determinations under their own law; for transfers concerning those jurisdictions, the Operator follows each jurisdiction’s own recognition, and applies appropriate safeguards such as standard contractual clauses to the extent recognition has not been given.

The transfer basis for the U.S. processors is as published by each company and has not been independently verified by the Operator. As of the verification date of September 9, 2026, Apple has published that international transfers of personal information it collects from the EEA, the United Kingdom, and Switzerland rely on standard contractual clauses (SCCs). Each company’s most current basis can be checked below.

Data Protection Officer (DPO)

The Operator has not designated a Data Protection Officer (DPO), having determined that the current scale of EEA, UK, and Swiss users and the frequency of cloud AI processing do not reach the “large scale” threshold under GDPR Article 37(1)(c). This determination is reviewed periodically as user numbers change. Inquiries regarding the processing of personal information may be directed to the Controller contact information above.