01
Who this covers
This policy explains how LORA English Remote Academy (business registration 650-94-02234), which runs Tier One English, handles personal information on the website, the dashboard, the practice and exam tools, the study assistant, live classes and related services. We follow the Personal Information Protection Act of Korea (PIPA). Where the GDPR applies because you are in the European Economic Area, we note the matching basis.
It applies to visitors, people who take a free diagnostic or join a waitlist, students, and the teachers and advisors who work with us. It does not cover other companies' sites we link to.
"Personal information" means anything that identifies you on its own or together with other information, as PIPA Article 2 defines it. "Processor" means a company that handles data for us under contract. Cookies and similar technologies have their own page, the Cookie Policy. We do not operate CCTV or other fixed video surveillance, and we do not process pseudonymized information under PIPA Article 28-2.
02
What we collect
Grouped by what you are doing. The only items required to open an account are your name, email address and password (or your social sign-in details). Items marked optional are collected only if you choose to provide them; declining them never affects your sign-up or your use of the service, except that a feature which needs that item (for example checkout, which requires phone verification) is unavailable. Everything else is generated or collected automatically as you use the feature concerned.
Account and sign-in
- Name, email address, password (stored only as a hash), profile picture (optional), language and theme.
- If you sign in with Google or Kakao: the identifier, name, email and picture they send, and the sign-in tokens.
- Phone number (optional, verified by one-time code, or supplied by Toss Payments after a card payment) and, while advisor support is on, your KakaoTalk id.
- Each session's IP address, browser, and the city and country derived from the IP address.
Your learning work
- Target exam, target scores, exam date, why you are studying (free text), previous exam history, placement level.
- The full text of every essay and answer you submit, recordings of your speaking practice and their transcripts, and the scores, feedback and notes our evaluators and teachers produce, including the error patterns detected in your work and your rank within your group in weekly reports.
- How you worked: timestamps, time on task, when you switched tabs, and for writing tasks your typing rhythm, pauses and pastes, used to detect copied work.
- Vocabulary review state, streaks, weekly progress snapshots and reports, live class attendance, recordings of live classes you attend (including your camera and microphone), how long you watched each recording or opened each material, your time zone and country, in-app notifications, and invitations to advisor study sessions (joined on an external meeting link).
- Certificates you request (enrollment, attendance, completion, payment confirmation) keep a snapshot of your name, attendance and amount paid.
Payments
- Order id, payment key, amount, date, product, the raw payment notifications we receive, and refund requests including the reason you give and your exit survey answers.
- For Mock Pass renewals, a billing key and the card brand, type and last four digits. Full card numbers stay with Toss Payments.
- If you accepted ad cookies at checkout, a copy of the Meta cookie values, your IP address and browser type, kept with the order so the purchase can be reported to Meta.
Messages and chat
- Every message in the study assistant, including what it looked up for you. Messages flagged by automated moderation are copied for review.
- Messages and attachments you exchange with your teacher, advisor or group.
- A log of every email and KakaoTalk message we send you: recipient, template, variables, delivery status, and addresses that bounced.
- Notes staff write about you: advisor care notes, teacher notes, internal notes on a chat thread, lead status, and any restriction we place on your account with its reason.
How you found us
- Campaign parameters, referrer and campaign link clicks, captured on landing and attached at sign-up.
- For campaign links: a session id, a salted hash of your IP address (never the raw address), a truncated browser string and country.
- Your answers to the cookie banner and to each consent box at sign-up, with the version, time, IP address and browser.
- If you join a waitlist or download free material, your email, name and campaign parameters, with the IP address and browser at the time of consent.
- If you use or share a referral code, the code and who referred you.
Support and staff
- Anything you send through the contact form or by email, with your IP address for the form.
- For teachers and advisors: username, bio, specialty, phone and KakaoTalk id for scheduling.
- If you join a live class as a guest, the name you enter.
We do not collect your date of birth, home address, full card numbers, or any of the sensitive categories in PIPA Article 23 (health, religion, political views and similar). Please keep them out of your essays and recordings; if they appear, we treat them as ordinary submission content. Inside the company, your teacher sees your name, email, submissions, scores, attendance and missed work for the classes they teach. Your advisor sees those plus your phone number, KakaoTalk id, goals, motivation notes, enrollment and payment dates, consent history and progress while advisor support is on. Our operators see every record in this policy through an internal console, and each staff opening of a student's dashboard is recorded.
03
Why, and on what basis
PIPA Article 15 requires a lawful basis for each use. The GDPR article is shown alongside for readers in the European Economic Area.
| Purpose | PIPA | GDPR |
|---|---|---|
| Running your account, delivering lessons, evaluating your work, showing progress | Article 15(1)(4), the contract with you | 6(1)(b) |
| Taking payments, issuing receipts, handling refunds | Article 15(1)(4) and 15(1)(2), tax and e-commerce law | 6(1)(b), 6(1)(c) |
| Sending account, payment, class and progress messages | Article 15(1)(4) | 6(1)(b) |
| Security, fraud and abuse prevention, moderation of the assistant, checking writing for copied work | Article 15(1)(6), legitimate interest | 6(1)(f) |
| Measuring how visitors find us | Article 15(1)(6), limited to actions you started | 6(1)(f) |
| Ad measurement scripts (Meta, Naver, Vercel Analytics) | Articles 15(1)(1) and 17(1)(1), consent via the cookie banner | 6(1)(a) |
| Marketing messages about programs and features | Article 15(1)(1), separate consent at sign-up | 6(1)(a) |
| An advisor viewing your progress and contacting you | Article 15(1)(4), part of the program you enrolled in; you can switch it off in Profile | 6(1)(b) |
| Answering inquiries and complaints, handling disputes, keeping a record of messages we sent you | Article 15(1)(4) and 15(1)(6) | 6(1)(b), 6(1)(f) |
| Issuing enrollment, attendance, completion and payment certificates | Article 15(1)(4), at your request | 6(1)(b) |
| Legal obligations such as keeping transaction records and tax filings | Article 15(1)(2), e-commerce and tax law | 6(1)(c) |
Criteria for additional use or disclosure: when deciding whether personal information may be used or disclosed beyond the original purpose without new consent under PIPA Articles 15(3) and 17(4), we consider whether the new purpose is related to the original one, whether you could reasonably expect it given how the data was collected and how it is normally handled, whether it unfairly harms your interests, and whether safeguards such as pseudonymization or encryption are in place. We do not currently rely on these provisions; if we ever do, this policy will say so first.
04
How automated evaluation and the study assistant work
Your essays and speaking recordings are scored and commented on by third-party language models, and the study assistant is a language model too. The table under Who receives your data names each provider and what it receives. In short, Google evaluates speaking, Anthropic evaluates writing and speaking transcripts, OpenAI steps in if the first evaluator fails, and DeepSeek powers the assistant.
Most requests go through Vercel AI Gateway, which forwards them to the provider. One feature connects your browser straight to the provider: the live examiner streams your microphone to Google while you speak, and the examiner's questions come back as text on screen.
Automated feedback is study feedback, not a final judgment, and it can be wrong. In live-class programs, writing feedback is checked by a teacher before it counts; in self-paced programs the score stands unless you ask for a review. In every program you can ask for a human review of any automated result from your teacher or at support@tieroneenglish.com. No decision with legal effect is made about you by software alone.
We do not use your data to train or fine-tune models for ourselves, and we choose providers whose business terms exclude training on customer inputs. Each provider's own logging still applies under its terms. The assistant runs on a DeepSeek model served through the gateway from servers in the United States; even so, please do not type sensitive personal details into it.
We keep a record of each evaluation and chat request (model, tokens, cost) and the responses you receive, for billing, abuse prevention and quality. Seriously harmful chat content may be reported to Korean authorities.
05
Who receives your data
We do not sell personal information and we do not share it for anyone else's marketing. The companies in the table below receive data for the purpose shown, under contract with us. Toss Payments, Google or Kakao for social sign-in, and Resend are also named in the consent box at sign-up, and receive the items shown in the table. Meta is different: ad-measurement events are disclosed to it only with your cookie-banner consent, and it keeps them under its own policy, as described under Cookies and device storage. Beyond that, we disclose data only to authorities when the law requires it, to our lawyers and accountants under confidentiality, in a merger or sale after notice to you, or with your explicit consent.
Vercel, Inc.
Hosting, background jobs and file storage
Everything the site processes passes through its servers in Singapore. Its file storage in Seoul is the fallback for your recordings, attachments and profile picture if our primary store is unavailable, and holds our encrypted database backups. Vercel's own logs and control plane are in the United States.
Singapore, Korea, United StatesAlwaysPrivacy policyNeon, Inc.
Main database
All account, learning, payment and message records described under What we collect, stored in Singapore. A separate operations database in the United States holds the support inbox: emails you send to our addresses, website chat messages and KakaoTalk or Instagram channel messages, with your name, address or handle and the link to your account. It is kept until we close the matter and is not removed by account deletion; email privacy@tieroneenglish.com to have it erased.
Singapore, United StatesAlwaysPrivacy policyUpstash, Inc.
Cache, rate limiting and short-lived queues
A copy of your session, cached copies of your enrollment and progress data, IP addresses and phone numbers as rate-limit keys, and queued ad events for retry.
SingaporeAlwaysPrivacy policyBunnyWay d.o.o. (Bunny.net)
Private file storage and video delivery
Your speaking recordings, chat attachments and profile picture in a private zone in Singapore, plus class recordings. Teacher and advisor profile pictures are on the public zone. Its player sees your IP address and browser when a video plays.
SingaporeAlwaysPrivacy policyFunctional Software, Inc. (Sentry)
Error reporting
Stack traces and request context, which can include your account id or the email an operation concerned, received in the EU and kept for up to 90 days. Cookies and sign-in credentials are stripped first.
European UnionAlwaysPrivacy policyAxiom, Inc.
Operational logs
Log lines that can include account ids, email addresses and IP addresses, kept for 30 days.
United StatesAlwaysPrivacy policyGitHub, Inc.
Daily encrypted database backup job
Once a day a full encrypted copy of the database passes through a GitHub Actions runner, and an encrypted copy is kept there for 90 days. It can be opened only with a key we hold.
United StatesAlwaysPrivacy policyResend, Inc.
Sending email
Your email address and the full message: name, scores, one-time codes, order amounts, links. Processed in Tokyo, Japan, including mail you send to our addresses and the automatic acknowledgements we send back.
JapanAlwaysPrivacy policySolapi (솔라피)
KakaoTalk messages and text messages
Your phone number and the message text, including one-time codes. For the phone verification code, a text message is the fallback when KakaoTalk delivery fails.
KoreaAlwaysPrivacy policyToss Payments (토스페이먼츠)
Card payments and refunds
Order id, amount and product. For Mock Pass (sign-up, card changes and renewals) also your name and email. Toss Payments sends back your phone number with the payment result. Card numbers never reach us.
KoreaAlwaysPrivacy policyGoogle LLC (Sign-In)
Sign in with Google
Google gives us your name, email and profile picture. We store the sign-in tokens.
United StatesWhen you use itPrivacy policyKakao Corp. (카카오)
Sign in with Kakao
Kakao gives us your nickname, email and profile picture. We store the sign-in tokens.
KoreaWhen you use itPrivacy policyLiveKit, Inc.
Live class video and audio
Your camera, microphone and display name while you are in a class. Each participant connects to the nearest LiveKit data center; from Korea that is Japan. Class recordings are made in the teacher's browser and stored at Bunny.net, not by LiveKit.
Japan, Singapore, United States, European UnionWhen you use itPrivacy policyGoogle LLC (Gemini)
Speaking evaluation and the live examiner
Your speaking recordings, the reference text and your name for feedback. For the live examiner, your microphone audio streams directly from your browser. Messages you send to our support addresses or website chat are also classified by Gemini so we can route them.
United StatesAlwaysPrivacy policyAnthropic, PBC
Writing and speaking feedback, Korean notes, staff drafts
Your essays, speaking transcripts, name and target scores; while advisor support is on, a snapshot of your profile and progress for your advisor's assistant. Support replies may be drafted by Anthropic from your message thread; a person reviews them before they are sent.
United StatesAlwaysPrivacy policyOpenAI, L.L.C.
Fallback evaluator
Full essays or speaking transcripts, with your name and target scores, only when our first evaluator fails.
United StatesAlwaysPrivacy policyHangzhou DeepSeek Artificial Intelligence Co., Ltd.
The study assistant chat
Your chat messages plus the details the assistant looks up for you: name, email, progress, schedule, notifications, account settings, payment amounts and refund estimates, and your advisor's contact. Never your essays or audio. In adaptive speaking practice, if the examiner's reply fails, the transcript of your answer is sent to DeepSeek to write the follow-up question.
United StatesWhen you use itPrivacy policyMeta Platforms, Inc.
Facebook and Instagram ad measurement
Hashed email, hashed phone number, hashed account id, IP address, browser type and the two Meta cookie values, per event. Events: page views, content views, diagnostic start, contact, lead, sign-up, checkout start, payment info entered and purchase, with the amount and plan name for checkout events. Never your name, address or learning content.
United States, European UnionAfter cookie consentPrivacy policyNaver Corp. (네이버)
Naver search ad measurement (Naver Log Analysis)
Page views and conversions with amounts only. No name, email or account details.
KoreaAfter cookie consentPrivacy policyVercel, Inc. (Analytics, Speed Insights)
Site usage and speed metrics
Anonymous page views and performance timings; on free practice pages, whether a test was started or finished.
United StatesAfter cookie consentPrivacy policy
When a company changes or a new one is engaged, we announce it in advance as described under Changes to this policy and update this table when the new processing begins. Toss Payments, Kakao, Google and Naver also act as independent controllers for what happens on their own sites. Some processors subcontract part of their work: Solapi delivers KakaoTalk notifications through Kakao, Vercel AI Gateway forwards evaluation and chat requests to the language model providers in the table, and infrastructure processors such as Vercel, Neon and Upstash run on cloud platforms such as Amazon Web Services. Subcontractors process data only for the same purpose, under the original processor's contract and policy. A few services see only your IP address and browser: the content networks that deliver camera-effect models during live classes (jsDelivr, Google Cloud Storage), and YouTube or Vimeo when a lesson embeds their player. When a class is held on Zoom instead of our own classroom, Zoom receives your display name, camera and microphone under its own policy.
06
Transfers outside Korea
Most of our processors are outside Korea. These transfers are outsourcing and storage needed to perform our contract with you (PIPA Article 28-8(1)(3)). The law asks us to disclose the recipient, the country, the items, when and how, the purpose and retention, contact details, and how to refuse. There are two exceptions. First, if you sign in with Google, exchanging sign-in details with Google LLC in the United States is a disclosure to a third party, made only with the consent you give in the third-party box at sign-up (Article 28-8(1)(1)). Second, ad-measurement events go to Meta in the United States as a disclosure, only with your separate consent on the cookie banner (same provision). The table above gives the recipient, items and purpose; the rest follows.
Recipients by location
- Korea
- Vercel, Inc., Solapi (솔라피), Toss Payments (토스페이먼츠), Kakao Corp. (카카오), Naver Corp. (네이버)
- Singapore
- Vercel, Inc., Neon, Inc., Upstash, Inc., BunnyWay d.o.o. (Bunny.net), LiveKit, Inc.
- Japan
- Resend, Inc., LiveKit, Inc.
- United States
- Vercel, Inc., Neon, Inc., Axiom, Inc., GitHub, Inc., Google LLC (Sign-In), LiveKit, Inc., Google LLC (Gemini), Anthropic, PBC, OpenAI, L.L.C., Hangzhou DeepSeek Artificial Intelligence Co., Ltd., Meta Platforms, Inc., Vercel, Inc. (Analytics, Speed Insights)
- European Union
- Functional Software, Inc. (Sentry), LiveKit, Inc., Meta Platforms, Inc.
- Timing and method: in real time, over encrypted connections, at the moment a feature needs the processing.
- Retention by recipient: each keeps the data only as long as its function needs, under its own policy and our contract. Essays and recordings sent for evaluation are processed at that moment and not used for training under the settings we have chosen.
- Contact details: each recipient's privacy contact is listed in its privacy policy, linked in the table. If you cannot reach them, write to privacy@tieroneenglish.com and we will forward your request.
- Refusing: you may refuse cross-border transfer by emailing privacy@tieroneenglish.com or by deleting your account. Because hosting, storage and evaluation happen abroad, refusal means we cannot provide the service. Refusing the ad-measurement transfer to Meta costs you nothing: decline on the cookie banner.
08
How long we keep it
We keep personal information only as long as the purpose needs, then delete it without delay. The periods below are the ones enforced by scheduled jobs in our system.
| What | How long | Notes |
|---|---|---|
| Account, profile, learning work, recordings, chat and progress | While your account exists | Deleted when you delete your account. |
| Cancellation window after requesting deletion | 7 days | Only for accounts with a purchase. Deletion runs on the first day after the window. |
| Sign-in sessions | 7 days | Expire 7 days after last use (refreshed daily while you use the service); expired ones are swept daily. |
| One-time codes (email, phone, deletion) | Up to 10 minutes | 5 to 10 minutes, then unusable. |
| Payment and refund records | 5 yearsLegal requirement | Required by Article 6 of the Act on Consumer Protection in Electronic Commerce and Article 6 of its Enforcement Decree: records of contracts, cancellations, payments and delivery (5 years) and of complaints and disputes (3 years). The same ledger also satisfies the 5-year record-keeping duty under Article 85-3 of the Framework Act on National Taxes. Kept in a separate ledger with only order id, amount, product, date, your name and email. |
| Deletion receipt | 3 years | A hashed account id and your consent snapshot, proving what was deleted and when. |
| Encrypted database backups | 1 year | Daily copies for 7 days, weekly for 4 weeks and monthly for 12 months in a private store in Seoul, plus a 90-day copy on GitHub. Restorable only with a key we hold. |
| Email and KakaoTalk send log | 180 days | Recipient and content are redacted after 180 days or when you delete your account; the delivery record (channel, template, status) stays for accounting. |
| Campaign click log and cookie consent log | 365 days | Clicks that led to a sign-up are kept with the account. |
| Diagnostic taken before signing up | 30 days | Deleted if not attached to an account within 30 days. |
| Unsubmitted assignment drafts on our servers | 30 days | Swept 30 days after last edit. |
| Class recordings | No automatic deletion | Kept while the program's recordings remain available; removed by us, not on a timer. |
| Support inbox (email, website chat, social messages) | No automatic deletion | Kept until we remove it; not deleted with your account. Ask privacy@tieroneenglish.com to erase it. |
| Error and operational logs | 90 days | Error reports are kept by Sentry for up to 90 days and operational logs by Axiom for 30 days. They can contain your account id and IP address and expire on their own schedule rather than with your account. |
When your account is deleted we remove your profile, work, recordings, chat, progress, sessions and consents, revoke sign-in grants, delete billing keys, and blank your messages in group chats. Files are deleted from storage, and a daily sweep removes unreferenced files from our fallback storage. What survives is listed above: the payment ledger, the deletion receipt, and redacted delivery records.
Destruction method: we keep personal information in electronic form only, as a rule, delete it so that it cannot be recovered, without delay once the retention period ends or the purpose is achieved, and shred any printout that is exceptionally made. Records we are legally required to keep are stored separately from everything else (PIPA Article 21(1) proviso and 21(3); Enforcement Decree of the Act on Consumer Protection in Electronic Commerce, Article 6). Our database provider keeps a 7-day point-in-time history, and encrypted backups follow the schedule in the table above; deleted data disappears from backups as they age out.
09
How we protect it
- Encryption in transit everywhere (TLS, HSTS), and at rest at our database and storage providers.
- Passwords are stored only as salted hashes. Sessions use HttpOnly, Secure, SameSite cookies and expire after 7 days.
- Rate limits on sign-in, codes, uploads, evaluations and the assistant; signed one-time tokens for email links; webhooks verified by signature or a shared secret.
- Role-based access on every server endpoint. Staff see only what their role needs, and a student's dashboard can be opened by staff only through a logged "view as student" procedure that requires a reason and expires in 30 minutes.
- Student recordings, attachments and profile pictures live in a private storage zone and are served through links that expire, within 6 hours for content you review and 15 minutes for one-off downloads. Teacher and advisor profile pictures are public.
- Every staff opening of a student's dashboard is recorded permanently in our operations database with the operator, the student and the reason. Other security events (sign-ups, sign-ins, payment changes, role changes, deletions) are written to our hosting provider's logs, which are kept for one day.
- Error reports have cookies and credentials stripped before they leave your browser or our servers.
- We limit the staff who handle personal information to the minimum the work requires, and each account carries only the role it needs.
- Our servers and storage sit in the certified data centers of cloud providers, which apply physical controls such as access restriction. We do not keep personal information on paper.
10
Your rights and how to use them
PIPA Articles 35 to 37 give you the right to see, correct, delete and stop processing of your data. Most of it is self-service.
- See and download
- Settings has a one-click export of your account, profile, consents, enrollments, diagnostic results, exercise history and assistant chat as a file. It leaves out progress snapshots, weekly reports, vocabulary review state, payment keys, ad and campaign identifiers, staff notes, messages with staff, the send log and raw recordings; email us for those.
- Correct
- Name, phone, picture, goals and preferences are editable in Profile and Settings. Your email address is fixed to your sign-in; email us to change it.
- Delete
- Settings, confirmed with a one-time code sent to your email. Accounts with a purchase get a 7-day window to cancel, from Settings or the link we email you; others are deleted at once. You cannot start a deletion while a refund is being processed; try again once it is paid out.
- Withdraw consent
- Marketing messages: toggle in Settings or the unsubscribe link in any marketing email. Advisor support: switch off in Profile. Ad cookies: the Cookie Policy page or the footer link. Confirmations you asked for (waitlist, unfinished order) and progress messages are service messages and are sent regardless of the toggle. Withdrawal does not undo processing already done.
- Review sessions
- Settings lists every signed-in device with its location and lets you sign any of them out.
- Automated decisions
- Ask your teacher or support@tieroneenglish.com to explain or review any automatically generated score or feedback, or to have a person redo it (PIPA Article 37-2).
- Stop processing or object
- Email privacy@tieroneenglish.com. We answer within 10 days and may ask you to confirm your identity from your registered email.
Beyond the self-service options above, you can request access, correction, deletion, suspension of processing or withdrawal of consent by email at privacy@tieroneenglish.com or by phone at 070-8018-6673. We respond within 10 days of receiving a request. If we limit or refuse access, or cannot honor a deletion or suspension request, we tell you why and how to object. Personal information that another law requires us to keep (for example payment records kept for 5 years) cannot be deleted during that period. You can also exercise these rights through a legal representative or an agent you authorize in writing; we will ask for a power of attorney or similar proof of authority and verify that the person asking is you or your authorized agent. If you are the parent or guardian of a child under 14 who has registered, contact us and we will remove the account (see Children and sensitive information below).
11
Children and sensitive information
The service is for people aged 14 and over. Sign-up requires you to confirm you are at least 14, and we do not collect a date of birth. We do not register anyone under 14; if we learn that has happened, we delete the account and its data without delay.
Your speaking recordings can reveal identifying characteristics of your voice. We do not build voice profiles or perform speaker identification, and recordings are protected as described under How we protect it.
12
Changes to this policy
We update this page when a processor changes, when we collect something new, or when the law changes. Changes to what we collect, why, or who receives it are announced in the service or by email at least 30 days before they take effect; other material changes at least 7 days before. Corrections and clarifications take effect on posting. Earlier versions are available on request at privacy@tieroneenglish.com, and the main changes are summarized below.
Version 2.0 (September 2026) rewrote the policy around a processor registry checked against our code and our vendor accounts. It adds OpenAI, LiveKit, Naver and GitHub to the table and discloses the support inbox database. It also corrects where each company processes data and what Anthropic, Toss Payments, Solapi, Meta and Sentry receive, corrects retention periods, and documents the self-service export. The consents you gave at sign-up remain valid: the items you consented to have not changed.
13
Contact and complaints
Our Personal Information Protection Officer handles all privacy questions, requests and complaints, and the same contact point (privacy@tieroneenglish.com) receives and processes requests for access, correction, deletion and suspension of processing.
Personal Information Protection Officer
Chanhee So, Representative
LORA English Remote Academy (Tier One English)
Business registration 650-94-02234
- Privacy
- privacy@tieroneenglish.com
- Support
- support@tieroneenglish.com
- Phone
- 070-8018-6673
- 19, Hakdong-ro 2-gil, 2F Unit 2525, Gangnam-gu, Seoul (Nonhyeon-dong, Sail Building), Republic of Korea
If you are not satisfied with our answer
You can take a complaint to these Korean bodies free of charge.