Corporate & Biz
Pre-Launch Legal Review for a Mobile App: Privacy, AI, and In-App Payment Compliance
사건 개요
- Client Information
- Corporate / Business Entity
- Case Details
-
The client was preparing to launch a mobile application featuring image analysis and AI-based functionality.
The app processed user account information as well as user-specific images and analytical data. Certain data was also intended to be used for AI model improvement and service enhancement.
The service further included paid subscriptions and a separate credit-based payment system, requiring legal review not only of personal data processing but also of payment, subscription, cancellation, and refund structures.
Before launching the app, the client engaged Decent Law Firm to review whether its actual user interface, service structure, Terms of Use, and Privacy Policy were aligned with applicable legal requirements in Korea and to identify any necessary revisions.
디센트 전략
Decent Law Firm did not limit its review to the wording of the Terms of Use and Privacy Policy. We also examined the app’s actual user interface, consent flows, data processing structure, and payment process.
1. Review of Service Results and User-Facing Language
We reviewed whether the app’s image analysis results could be perceived as constituting a medical diagnosis or otherwise create regulatory concerns relating to medical or medical-device services.
Based on the review, we recommended revisions to the wording displayed on the results screen so that users could more clearly understand the nature and limitations of the service.
2. Review of Privacy and Consent Structure for Children’s Data
We reviewed the collection, retention, and deletion structure for personal information processed through the app, including user account information and images.
We also examined whether information requiring separate consent was appropriately distinguished from general personal information.
Where children’s information was involved, we reviewed the consent process for legal representatives and the structure for obtaining consent separately for each child.
3. Review of AI Training Data and Optional Consent
We reviewed whether the use of personal data for AI model improvement and service enhancement was properly separated from data processing necessary to provide the core service.
We also compared the app’s optional consent mechanism with the relevant disclosures in the Privacy Policy to ensure that the documented data practices reflected the app’s actual use of information.
4. Review of In-App Payments, Subscriptions, and Refunds
We reviewed the app’s paid subscription, automatic renewal, and credit purchase structure, including the disclosure of refund and cancellation terms at the point of payment.
We also reviewed whether users could easily access the applicable Terms of Use and recommended revisions to the refund provisions to address situations involving unused credits.
5. Privacy Policy and User Rights
We reviewed whether the analytics and error-reporting tools actually used in the app were properly reflected in the Privacy Policy.
Where necessary, we recommended additional disclosures regarding outsourced data processing and automatically collected information.
We also advised the client to reflect the app’s internal data deletion and export functions in the section of the Privacy Policy explaining how users may exercise their privacy rights.
For areas requiring revision, Decent Law Firm provided not only legal comments but also specific wording that could be implemented directly in the app interface, Terms of Use, and Privacy Policy.
1. Review of Service Results and User-Facing Language
We reviewed whether the app’s image analysis results could be perceived as constituting a medical diagnosis or otherwise create regulatory concerns relating to medical or medical-device services.
Based on the review, we recommended revisions to the wording displayed on the results screen so that users could more clearly understand the nature and limitations of the service.
2. Review of Privacy and Consent Structure for Children’s Data
We reviewed the collection, retention, and deletion structure for personal information processed through the app, including user account information and images.
We also examined whether information requiring separate consent was appropriately distinguished from general personal information.
Where children’s information was involved, we reviewed the consent process for legal representatives and the structure for obtaining consent separately for each child.
3. Review of AI Training Data and Optional Consent
We reviewed whether the use of personal data for AI model improvement and service enhancement was properly separated from data processing necessary to provide the core service.
We also compared the app’s optional consent mechanism with the relevant disclosures in the Privacy Policy to ensure that the documented data practices reflected the app’s actual use of information.
4. Review of In-App Payments, Subscriptions, and Refunds
We reviewed the app’s paid subscription, automatic renewal, and credit purchase structure, including the disclosure of refund and cancellation terms at the point of payment.
We also reviewed whether users could easily access the applicable Terms of Use and recommended revisions to the refund provisions to address situations involving unused credits.
5. Privacy Policy and User Rights
We reviewed whether the analytics and error-reporting tools actually used in the app were properly reflected in the Privacy Policy.
Where necessary, we recommended additional disclosures regarding outsourced data processing and automatically collected information.
We also advised the client to reflect the app’s internal data deletion and export functions in the section of the Privacy Policy explaining how users may exercise their privacy rights.
For areas requiring revision, Decent Law Firm provided not only legal comments but also specific wording that could be implemented directly in the app interface, Terms of Use, and Privacy Policy.
결과 및 의의
"Legal Review Memorandum Provided"
Based on the legal review, the client was able to refine its app interface, privacy consent process, AI data-use structure, and payment and refund policies before launch.
1. Review Extended to the Actual User Interface
The legal review was not limited to policy documents.
We also examined the results screen, account registration flow, child-profile registration process, and payment interface that users would actually encounter.
This allowed the client to identify and address inconsistencies between its written policies and the way the service operated in practice, while also refining user-facing notices before launch.
2. Privacy and AI Data-Use Structure Refined
We separately reviewed personal data collection and use, image-based information processing, consent relating to children’s data, and the use of data for AI model improvement.
In particular, we helped distinguish data processing necessary to provide the service from additional data use for service improvement, and aligned the consent structure with the Privacy Policy.
3. Payment and Refund Policies Strengthened
We reviewed the app’s actual subscription, automatic renewal, and credit purchase mechanisms against the disclosures provided to users at the payment stage.
The Terms of Use and refund notices were refined so that users could review the relevant conditions before making a payment and so that the written policies were consistent with the app’s actual payment structure.
4. Pre-Launch Policies Finalized
Following the review, revised versions of the Terms of Use and Privacy Policy were provided to the client.
The client was therefore able to finalize its key legal documents and user-facing policies in line with the planned launch of the service.
Based on the legal review, the client was able to refine its app interface, privacy consent process, AI data-use structure, and payment and refund policies before launch.
1. Review Extended to the Actual User Interface
The legal review was not limited to policy documents.
We also examined the results screen, account registration flow, child-profile registration process, and payment interface that users would actually encounter.
This allowed the client to identify and address inconsistencies between its written policies and the way the service operated in practice, while also refining user-facing notices before launch.
2. Privacy and AI Data-Use Structure Refined
We separately reviewed personal data collection and use, image-based information processing, consent relating to children’s data, and the use of data for AI model improvement.
In particular, we helped distinguish data processing necessary to provide the service from additional data use for service improvement, and aligned the consent structure with the Privacy Policy.
3. Payment and Refund Policies Strengthened
We reviewed the app’s actual subscription, automatic renewal, and credit purchase mechanisms against the disclosures provided to users at the payment stage.
The Terms of Use and refund notices were refined so that users could review the relevant conditions before making a payment and so that the written policies were consistent with the app’s actual payment structure.
4. Pre-Launch Policies Finalized
Following the review, revised versions of the Terms of Use and Privacy Policy were provided to the client.
The client was therefore able to finalize its key legal documents and user-facing policies in line with the planned launch of the service.
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