개인정보 처리방침

(AI)글로벌에듀 ("Company") operates X10LAB (x10lab.ai) and related services — Guppy (cloud GPU cost diagnosis and optimization) and Marlin (multi-cloud GPU matching and instance execution, beta) (collectively, the "Services") — and protects users' personal data in compliance with the Personal Information Protection Act of Korea ("PIPA") and other applicable laws. This policy is prepared under Article 30 of the amended PIPA effective 11 September 2026. In case of any discrepancy, the Korean version prevails.

1. Purposes of Processing

1. Responding to inquiries and pre-registrations; service communication
2. Providing the Services (Guppy/Marlin): user identification/authentication, running and managing GPU instances, settling usage fees/credits, and issuing tax invoices (contract performance)
3. Service improvement, usage analytics, and new-service development
4. Preventing fraudulent use, responding to security incidents, handling disputes, and complying with legal obligations
5. Marketing and event/benefit notifications (only for users who have separately opted in)

2. Personal Data Collected and Collection Methods

a. Landing page (inquiry / pre-registration) — entered by the user. Required: email address. Optional: name, company, message.

b. Service use (Guppy/Marlin) — collected during sign-up and use. Account data: email, authentication identifier (OIDC), API keys, SSH public keys. Usage data: workload/instance details, usage time, fee/credit records. Payment data: if a payment gateway is introduced, payment-approval data only (card issuer, approval number, etc.); full card numbers are collected and held by the payment processor, not the Company.

c. Automatically generated/collected — cookies, IP address, browser/device/OS information, visit timestamps, service usage logs.

The Services are not directed at children under 14, and the Company does not knowingly collect their data; any such data identified will be destroyed without delay.

3. Retention Periods

• Inquiry/pre-registration data: 1 year after the purpose is achieved, or until the user requests deletion (internal policy).
• Account/usage data: until account withdrawal.
• Statutory retention: records on contracts and withdrawal of offers — 5 years; records on payments and supply of goods/services — 5 years; records on consumer complaints and dispute resolution — 3 years; records on labeling/advertising — 6 months (E-Commerce Act, Art. 6); website access logs — 3 months (Protection of Communications Secrets Act, Art. 15-2).

4. Provision to Third Parties

The Company does not provide personal data to third parties, except (i) with the user's separate prior consent, or (ii) where required or permitted by law. Any new third-party provision will be reflected in this policy with the recipient, purpose, items, and retention period specified, and consent will be obtained where required.

5. Outsourcing (Processors)