Privacy Policy
LW PRIVACY 20261108 DRAFT 04
Prepared 8 November 2026 · Version LW PRIVACY 20261108 DRAFT 04 · Effective date not set
This Policy explains how 주식회사 스카이폴 handles personal data through Luxwarp websites and apps for iOS, Android, macOS, Windows and Linux. It distinguishes account and connection management, data used by enabled remote features, and enquiries.
Draft for review. The privacy officer is 이상화 (Sang-hwa Lee), Representative. Section 7 distinguishes locations observed through read-only operational checks on 8 November 2026 from unconfirmed routes. Section 8 distinguishes the account-retention principle adopted for this draft, existing operating rules and deletion procedures awaiting verification. Remaining transfer details and deletion conditions must be completed and aligned with operations before effectiveness. This draft and prototype do not collect real consent.
Section 1 Controller and contact
The controller is 주식회사 스카이폴, a Korean company, represented by 이상화 (Sang-hwa Lee), business registration number 480-86-02585. Its address is Suite 1422, 14F, DMC Star Palace, 34 Kkotmaeul-ro, Deogyang-gu, Goyang-si, Gyeonggi-do, Republic of Korea. Contact inquiry@luxwarp.com or +82-70-8095-1561 for privacy enquiries and rights requests.
The Company is responsible for processing for its own purposes, including registration, account security, service operation and enquiries addressed to it. An employer or other organisation that determines how remote sessions, members or work materials are used may also be a controller for that processing. Processing by the Company on an organisation’s instructions is addressed in a separate Data Processing Agreement, or DPA. The Personal or Team product label does not by itself determine the parties’ legal roles.
Section 2 Data and purposes
| Category | Data processed | Purpose |
|---|---|---|
| Registration and accounts | Email, internal user identifier, registration and verification times, applications or invitations, optionally stated intended use | Registration verification, accounts, invitations and notices |
| Authentication and security | Hashes of verification codes or tokens, expiry times, session information and necessary security or access records | Authentication, maintaining login and preventing abuse |
| Organisations and devices | Organisation, membership and role, invitation status, device name and identifier, host or viewer role, owner, registration, last activity and revocation times | Permissions, device management and connection targets |
| Connections and diagnostics | IP addresses, ports and other network addresses, device certificate fingerprints, connection times and results, errors, display size and frame rate, CPU, memory, traffic and status information | Connection negotiation, status, troubleshooting and security |
| Consent and contracts | Document and version, language, individual selections, acceptance, change or withdrawal times, related user and organisation identifiers | Evidence of agreement and choices, handling requests |
| Support | Contact details, subject, message, attachments supplied by the user, replies and handling status | Responding and resolving problems |
| Sales and consultation | Name, email, subject and message, optional company name, form language and version, receipt identifiers and handling times | Reviewing, responding to and following up on consultation |
| Support installation and connections | Installation identifier, public key, issuance and revocation, presence, temporary negotiation messages, host-reported summaries and paid relay audit records | Stable installation identity, authorised negotiation, status and security |
| Optional features | User-authorised screen, audio and input data, clipboard or transferred files and related information | Providing the enabled remote feature |
The final row does not mean that all such data is stored on Company servers. Section 5 explains transmission and organisational access. Diagnostic fields depend on features and platforms. Before expanding collection, the Company checks purpose and legal basis and provides any required notice or consent choice. Do not send passwords, verification codes, unnecessary sensitive data or third-party work materials in an enquiry.
Section 3 Legal grounds and separate choices
The Company distinguishes processing necessary to enter into or perform a contract, compliance with legal obligations, lawful purposes such as security where the applicable law permits them, and processing based on consent. Reliance on legitimate interests requires assessing necessity and the individual’s rights and interests. Where consent is the legal basis, the purpose, data, retention period and specific consequences of refusal are explained before a separate choice is offered.
Accepting the EULA or opening this Policy is not blanket consent to all processing. International transfers are separated from collection and marketing when separate transfer consent is required. Where another lawful transfer ground is used, the Company provides the required information and identifies that ground.
Marketing is optional and off by default. Refusing it does not prevent use of the basic service. If marketing is offered, its data, channels, purpose, retention and withdrawal method are explained separately, including channel-specific permission for promotional messages where required. Contractual and legally required notices are distinguished from marketing. The Company does not sell personal data or use users’ work materials for advertising or general-purpose AI training at its discretion.
Section 4 Email and Google authentication
Email authentication uses a verification link or code. Luxwarp does not collect or store an account password. Authentication secrets are managed through the required verification information and expiry, and the Company does not ask users to reply with passwords or login verification codes.
New registration through Google uses the openid and email scopes and may use the email verified by Google to confirm registration. Linking Google to an existing account uses openid. The Company processes the provider, its subject identifier sub, the linked internal user, link time and email confirmed for registration. Matching email addresses alone do not automatically merge accounts.
The Company does not retain raw Google ID tokens, access tokens or refresh tokens as account information. This login does not request access to Google profiles, Gmail, Drive or contacts. Google’s own authentication is governed by the Google Privacy Policy. Connections can be managed through Google account connections. Unlinking Google and deleting a Luxwarp account are different procedures.
Section 5 Remote sessions and device permissions
In direct connections, screen, audio, input and enabled clipboard data travel between the connected devices. Company connection servers process signalling and status needed to establish the connection; they do not relay or record the screen or audio of a direct connection. A separately offered and enabled relay feature may carry encrypted session packets through a server. Accordingly, the Company does not represent that every session bypasses servers.
The remote participant can see personal data displayed on the screen and, within the permissions granted, send input or receive files and clipboard contents. Authorised organisation administrators may see member emails, roles, devices, invitations and connection status for administration. Ask the organisation about its own purposes and retention rules.
Permissions on iOS and Android, Screen Recording, Accessibility and Local Network permissions on macOS, and relevant screen, input and network permissions on Windows and Linux are requested for supported features. Permission names and available features vary by operating system. This does not promise unattended hosting on every mobile device. Installation or acceptance of terms does not automatically enable unattended access. Users must have authority over the devices and materials they permit others to access.
Section 6 Providers and recipients
| Recipient or environment | Purpose and scope | Role |
|---|---|---|
| Cloudflare | Web and account infrastructure, storage, authentication email, connection signalling, security and errors | Processor within the actual contract and enabled service scope |
| Company email environment using ECOUNT | Enquiries sent to inquiry@luxwarp.com and forwarded to the Company mailbox, including replies | Processor for enquiry email |
| Google authentication selected by the user | Separate controller for its own authentication; selection does not make Google a subprocessor for every Company activity | |
| Company Relio environment | Sales consultation and support intake and handling | Internal Company system, not a separate third-party legal entity |
| Authorised organisation users and remote participants | Administration or remote functions described in Section 5 | Recipients within the authorised access scope |
Information is disclosed only on a lawful basis, such as a legal obligation or a disclosure requested or authorised by the user. Entrusted processing is distinguished from disclosure for a recipient’s own purposes. Before activating another support tool or SDK, the Company identifies its operator, data, countries and retention and arranges required contracts and notices. An optional module’s presence in source code alone does not establish that it is an active provider.
Section 7 International transfers
Read-only checks on 8 November 2026 observed primary-instance query processing in Seoul, Republic of Korea (ICN) for the account, browser-session and organisation databases, and Osaka, Japan (KIX) for the support database. These observations are not a fixed-country contract or verification of every stored copy, backup, email, security-processing or support-access location. The account and support databases reported APAC, no jurisdiction restriction and disabled read replication. Processing is therefore not represented as restricted exclusively to one country.
Observed processing locations and remaining transfer details
| Route | Confirmed country and processing | Remaining confirmation |
|---|---|---|
| Cloudflare account, browser-session and organisation databases | Primary query processing observed in Seoul, Republic of Korea (ICN); account, login and organisation data | Locations of all copies, recovery history and operational access, and any fixed-country commitment |
| Cloudflare support database | Primary query processing observed in Osaka, Japan (KIX); installation, signalling, status and summary data | Contracting recipient and contact, complete storage and access countries, transfer ground and disclosures |
| Cloudflare web, email routing, authentication email and security | Service routes in use; complete processing countries unconfirmed | Do not extend the Korean and Japanese database observations to these entire routes |
| ECOUNT Company email | inquiry@luxwarp.com forwards to Company email. The reviewed webmail-specific public policy does not identify countries for originals, replicas, backups or operational access | Obtain written provider confirmation. Privacy contact: security@ecounterp.com, 1566-5333 (Korea). Headquarters are not evidence of storage country |
| Company Relio and NAS | The S19B01 NAS holding consultation SQL backups and minimal erasure records is installed at the Republic of Korea office, confirmed by the operator on 8 November 2026. Intake originals have a 90-day rule and NAS backups a separate rolling 90-day rule | This confirms Company NAS storage only, not every Relio cloud, ECOUNT or Cloudflare backup location. Additional copies and overseas access require separate confirmation |
| Optional Google authentication | Google’s own authentication and receipt of needed identifiers; all countries for this route unconfirmed | Distinguish independent authentication from transfers to the Company and provide required information |
The Company must identify the ground for each transfer under Korean law. Where separate consent is needed, it must first provide the data, countries, timing and method, recipient and contact, purpose, retention, and refusal method and consequences. Where Japanese law applies, required information includes the foreign protection system and recipient safeguards. Where the GDPR applies, the relevant transfer conditions and safeguards must separately be satisfied. Document language alone does not determine applicable law.
Where refusal is available, the Company explains which transfer-dependent feature is affected and available alternatives. Refusing marketing transfers does not restrict the basic service. Agreement to a DPA or EULA alone neither authorises all international transfers nor executes standard contractual clauses.
Section 8 Retention and deletion
The Company deletes personal data without undue delay, or otherwise handles it as required by law, when its purpose or lawful retention period ends. Statutory retention is identified by legal ground, data and period, with use restricted to that ground. An incomplete deletion process is not a basis for indefinite retention.
| Data | Retention rule and operating status |
|---|---|
| Email verification, device approval and OAuth state | Valid for 15, 5 and 10 minutes respectively. Expiry is distinct from erasure; no confirmed general automatic erasure deadline across account storage |
| Browser login cookie | Valid up to 30 days, separate from residual server-record deletion |
| Accounts, organisations, devices, invitations and consent records | Principle adopted for this draft: retain data needed to provide the service while the account is maintained; on account closure or fulfilment of the processing purpose, erase without undue delay except data subject to statutory retention. Procedures and completion deadlines for complete account erasure must be established and verified before effectiveness |
| Ordinary ECOUNT support email | No uniform automatic deletion period was confirmed for inbox or archive folders. Assess deletion against the enquiry purpose and any separate statutory retention need |
| ECOUNT spam and trash | Provider notice sets automatic permanent deletion of spam 7 days after receipt and trash 30 days after deletion, effective 17 April 2026. This is not the retention period for other folders or separate backups |
| Support installation identity mapping | Installation identifier, public key and initial issuance mapping are preserved without automatic deletion or reuse. Revoked mappings remain; rights requests require separate handling |
| Support presence | Expires 90 seconds after the latest observation |
| Temporary support negotiation messages | Default 10-minute expiry. Material referenced by a valid active connection permission is retained while needed |
| Support connection summaries | 7-day expiry; not server proof of successful authentication |
| Paid relay audit records | 30-day expiry |
| De-identified daily support totals | 90 days; separate totals without device, account, IP or message content |
| Support temporary-data cleanup | Operates every 5 minutes. Read-only checks on 8 November 2026 confirmed a recent successful cleanup, zero recorded failures and zero pending expired candidates. This is not instant physical erasure or complete deletion across all storage |
| Unsuccessful consultation intake originals | 90 days after explicit staff-recorded unsuccessful closure. Covers name, email, company, subject, message and content hash; excludes reopened, active or successful cases and separate CRM work records |
| NAS backups for that intake | Separate rolling 90-day retention. Operating application and a successful zero-target automated run are recorded; this is distinct from observing erasure of actual due originals |
| Minimal consultation erasure ledger | Minimal identifiers and times are kept separately from ordinary backup rotation to prevent restored content from reappearing, longer than every restorable backup; final maximum period remains unset |
| D1 recovery history and Workers Logs | D1 provider recovery window up to 30 days. At the check date, provider Workers Logs retention was 3 days on Free and 7 on Paid. These periods do not govern exported logs, email or NAS backups |
The absence of automatic deletion for identity mappings or erasure evidence does not authorise indefinite personal-data retention. The privacy officer must establish category-specific lawful grounds, necessity and maximum periods and address deletion or withdrawal requests. The 90-day intake rule does not establish periods for separate CRM customer or work records, ordinary support mail or operational logs.
Electronic data is deleted using suitable methods that make recovery difficult; printed material is destroyed appropriately. Residual backup data must be restricted until deletion under a defined rotation, and deletions must be reapplied on restoration before data is exposed to the service again. Account deletion currently begins by contacting the Company. Logout, unlinking and blocking device access are not substitutes for complete personal-data deletion. Coverage across storage, mail and backups, maximum completion deadlines and execution procedures must be completed and verified before effectiveness.
Section 9 Individual rights
Subject to applicable law, individuals may request access, correction, deletion, restriction and withdrawal of consent. Objection, portability and rights relating to automated decisions are available where the applicable law provides them. Send the account concerned and the request to inquiry@luxwarp.com. The Company uses the minimum information needed to verify identity or representative authority and provides its outcome or grounds for restriction within applicable legal deadlines. Do not send passwords or login verification codes.
The Company explains limits involving another person’s data or statutory retention. Requests for data processed on an organisation’s behalf are forwarded to that organisation with appropriate assistance; the Company addresses its own controller processing directly. Deleting data essential to a feature or withdrawing consent relied upon for that feature may end it, and the effect is explained beforehand. Optional marketing withdrawal does not limit basic use.
Concerns may be raised with the Korean Personal Information Protection Commission, Privacy Infringement Report Center, Personal Information Dispute Mediation Committee, or the competent supervisory authority in the individual’s region.
Section 10 Safeguards and device storage
The Company operates and improves safeguards appropriate to risk, including necessary access controls, transport security, and hashing and expiry of authentication secrets. Additional measures, including storage encryption, administrator authentication, logs and backup rules, must be checked for the actual service scope. This Policy does not assert ISO or SOC certification or identical security settings across every system.
Session cookies or device storage may maintain login, and Cloudflare Turnstile may be used for security. Turnstile may process security signals including IP and browser information under its privacy notice. Turnstile tokens are not kept in original consultation intake records. Browser and operating-system controls can manage cookies and permissions, although some authentication or remote features may be affected. Advertising tracking is not a condition of basic service. The SDK and storage inventory for each platform must reflect the actual release configuration.
Section 11 Children and automated processing
Luxwarp is not designed for children. Where guardian consent is required by applicable law, the relevant procedure must be provided. Contact the Company if a child’s data appears to have been submitted improperly.
Automated authentication, abuse detection or rate limits may be used. Before introducing solely automated decisions that have legal or similarly significant effects on a person, the Company provides the purpose, criteria and available rights as required by applicable law.
Section 12 Changes and privacy responsibility
When processing changes, the Company makes the revised effective date, changes and required actions easy to find and retains earlier versions. Changes requiring new consent are subject to separate consent before they take effect. Korean, English and Japanese versions describe the same processing and rights; translation differences do not reduce rights under applicable law.
Privacy Officer: 이상화 (Sang-hwa Lee), Representative. Send privacy enquiries and access, correction, deletion or restriction requests to inquiry@luxwarp.com, telephone +82-70-8095-1561. This draft records the Company’s designation on 8 November 2026. Any regional representative requirement is assessed separately against the actual applicable law and activities.
Appendix First launch screen design
The design applies the same document versions and choice rules after installation and before first use on iOS, Android, macOS, Windows and Linux. Distribution without a separate installer uses first launch.
| Screen item | Choice rule |
|---|---|
| I agree to the End User License Agreement | Required contractual acceptance, unchecked by default |
| I have read the Privacy Policy | One privacy item on the first screen. View opens collection, use and international-transfer information together; acknowledgement is not blanket consent |
| I agree to receive marketing messages | Optional, off by default; distinguish required channel permissions |
| Data Processing Agreement | An authorised representative executes the completed agreement and annexes for actual entrusted processing; not required of every installer |
Where collection, use or transfer actually requires separate consent, present the required details and obtain each consent at the relevant feature or registration step. The single first-screen acknowledgement does not replace it.
Language initially follows system settings and can be changed between Korean, English and Japanese. Users can continue without marketing consent. An overall selection control must not force optional choices. Settings should show document versions and recorded choices and provide withdrawal of optional consent.
Appendix Review requirements
The privacy officer is confirmed as 이상화 (Sang-hwa Lee), Representative. Observed database query processing countries are the Republic of Korea and Japan, limited to the scope in Section 7. The account-retention principle in Section 8 is adopted for this draft. Complete transfer routes, contractual recipients and access countries, procedures and completion deadlines for complete account erasure, and maximum periods for ordinary email and erasure-ledger records still require confirmation or definition. Complete these items, the SDK and support inventory, and full deletion and restoration procedures before effectiveness. Operating evidence consists of SUPPORT-STORAGE-20261028.md and rollout records, SALES-INTAKE-VERIFICATION-20261007.md, Relio’s INTAKE-RETENTION.md, and read-only D1 checks on 8 November 2026. See the D1 API and Cloudflare locations for location metadata and Workers Logs for provider log periods.
Official references include the TeamViewer product privacy information, Korean privacy policy disclosure requirements and international transfer rules, Japanese PPC foreign transfer guidance, the GDPR, and D1 recovery documentation. TeamViewer’s data inventory and retention rules are not represented as Luxwarp facts.
Additional verification: the operator confirmed that S19B01 is installed in the Republic of Korea. ECOUNT’s webmail retention notice dated 16 April 2026 announces 7-day spam and 30-day trash deletion from 17 April. Its webmail-specific policy describes keeping customer data for 3 months after termination of the provider’s service contract; this is not a 3-month post-closure retention rule for Luxwarp members. The reviewed public policy does not specify actual storage or backup countries, requiring provider confirmation. Inspection of account scheduling and production database schema found no rule automatically erasing account originals after a fixed number of days. Adoption of the draft retention principle does not establish implementation or verification of complete erasure, and no invented erasure period is represented as current operation. At the operator’s direction, no provider enquiry about mail storage or backup countries was sent.