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Supplementary Privacy Notice for Users in the EU/EEA, the United Kingdom and Switzerland (GDPR)

Version 1.1 · Updated October 10, 2026

This notice is for people who use I'm Miri while living in the European Union, the European Economic Area, the United Kingdom or Switzerland. It gives, in one place, the information required by the General Data Protection Regulation (GDPR) and the equivalent UK and Swiss rules: who is responsible for your data, why and on what legal basis we use it, who receives it, how long we keep it, and your rights. It does not start any new processing. It supplements our full Privacy Policy (miri.im/privacy-en), which describes each processing in detail; where this notice gives you more information or more protection, it applies.

1. Who is responsible for your data

2. What we process

Your birth date is needed to calculate readings, and an account is needed to use the app; without them we cannot provide those features. Everything marked optional is up to you. More detail: section 2 of the Privacy Policy.

3. Why we use your data and our legal basis

Purpose Legal basis (GDPR)
Your account, readings and the oracles' replies, invitations and connections, purchases, the pre-sign-in conversation trial, and support Performance of a contract with you, or steps you ask for before entering into one (Art. 6(1)(b))
Compatibility readings using information about people you add Our and your legitimate interests (Art. 6(1)(f))
Proactive messages from the oracles and other optional notifications Consent (Art. 6(1)(a))
Usage statistics (Google Analytics for Firebase) Consent (Art. 6(1)(a)) — asked in recent iOS and Android versions on devices set to a European region or time zone. The web version and older app versions do not ask yet, and a few invitation, referral and sign-up events are sent from our servers under a pseudonymous identifier, on the basis of our legitimate interest in measuring how the service is used (Art. 6(1)(f)).
Mood records in check-ins and the 21-day journey Explicit consent (Art. 6(1)(a) and Art. 9(2)(a)), because mood may be health-related
Conversation safety (detecting risks of suicide, self-harm or violence and showing crisis contacts) Our legitimate interest in keeping users safe (Art. 6(1)(f)) and, where a risk is detected, the protection of vital interests (Art. 6(1)(d))
Security, preventing fraud and abuse (including invitation rewards and the trial), fixing errors, install attribution, and checking the quality of AI replies and support replies with AI analysis tools Legitimate interests in running a safe and reliable service (Art. 6(1)(f))
Keeping purchase, contract and complaint records for the periods required by Korean law, and handling App Store refund reviews Legitimate interests in complying with the laws that apply to us and defending our rights (Art. 6(1)(f))

You can withdraw a consent at any time; this does not affect the lawfulness of processing based on that consent before its withdrawal (section 7). If you refuse or withdraw a consent, only the feature that depends on it stops: without notification consent you do not receive proactive messages; without usage-statistics consent the app does not send usage statistics; without mood-record consent you cannot use check-in mood records. The rest of the service is unchanged.

Ads. We do not send ad measurement data (Google Ads) for installs that came from the EEA, the United Kingdom or Switzerland, and we never use your data to personalize ads.

Sensitive information in conversations. The app only asks for one kind of sensitive data, in an optional feature: mood records, collected with your explicit consent. Conversations are free text. If you choose to write about your health, beliefs or other sensitive matters, that text is handled like the rest of the conversation — used to reply to you, to summarize and remember context, and for the conversation safety analysis below — and is never used for advertising. If you do not want such information processed, please do not write it. You can delete a conversation, clear what the oracles remember, or delete your account at any time (section 7). Please avoid writing sensitive information about other people.

Conversation safety. If a message you send contains expressions related to suicide, self-harm or violence, an AI automatically analyzes that message and part of the preceding conversation. If there is a risk to the life or physical safety of you or someone you mention, we may make the reply safer, show verified crisis and emergency contacts, and pause fortune notifications for 72 hours. The analysis does not receive your account identifier, name, date of birth or Saju information, and its result is not stored with your account — we keep only daily statistics that identify no one. Crisis contact cards shown to you are kept with that conversation. No person reads your conversations in real time.

4. Who receives your data

More detail on what each provider receives: sections 4 and 5 of the Privacy Policy.

5. International transfers

We are established in the Republic of Korea. The European Commission has recognized Korea as providing an adequate level of protection for personal data (Commission Implementing Decision (EU) 2022/254), and the United Kingdom has made a similar decision (The Data Protection (Adequacy) (Republic of Korea) Regulations 2022). Our providers listed in section 4 process data mainly in the United States (and, for Google Cloud, in other Google processing regions). These transfers are needed to provide the service, for example to store your account and generate AI replies, and data is sent encrypted. Google's data processing terms with us provide for the European Commission's standard contractual clauses where EU data protection law applies. For our other providers: where a provider's terms with us include safeguards such as the European Commission's standard contractual clauses, or the provider is certified under the EU–U.S. Data Privacy Framework, those safeguards apply. To get more information about the safeguards for a given provider, write to cristina@miri.im.

6. How long we keep your data

7. Your rights

You have the right to access your data, to have it corrected, to have it erased, to restrict its processing, and to receive the data you provided to us in a structured, commonly used and machine-readable format (portability). Where we rely on your consent, you can withdraw it at any time. These rights are free of charge.

Right to object. You may object at any time, on grounds relating to your particular situation, to processing based on our legitimate interests. We will then stop, unless we have compelling legitimate grounds that override your interests, rights and freedoms, or the processing is needed for legal claims.

How to exercise them (Settings: open the menu, tap your name at the bottom of the menu — “You” if you have not set one — and choose “Settings”):

Some requests may be limited by law, for example where we must keep purchase records. If you live in France, you can also give us instructions on what should happen to your data after your death. You also have the right to lodge a complaint with a data protection supervisory authority, in particular in the country where you live or work or where the alleged infringement took place — in France, the CNIL (www.cnil.fr); in the United Kingdom, the ICO (ico.org.uk); in Switzerland, the FDPIC (www.edoeb.admin.ch).

8. Automated decisions

We do not make decisions based solely on automated processing that produce legal effects concerning you or similarly significantly affect you. Two features act automatically: conversation safety (section 3) and checks against invitation-reward abuse, which may withhold a reward. If you disagree with an outcome, write to us at cristina@miri.im.

9. Security

We use technical and organizational measures such as encryption, access control and access logging (section 8 of the Privacy Policy).

10. Relationship with the full Privacy Policy

This notice is a supplementary summary of the Privacy Policy. Where it gives you more information or protection, it applies; otherwise the details are in the full Privacy Policy, in English (miri.im/privacy-en) and Korean (miri.im/privacy). Nothing in this notice limits the rights the law gives you. When this notice changes, we update the date at the top. Changes to the Privacy Policy that add new processing are announced on its page at least 7 days before they take effect (its section 13); corrections that add no new processing take effect when posted.

Contact: cristina@miri.im