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Piuda Cookie Policy

Last Updated: September 29, 2026 · Effective Date: September 29, 2026 · Version: v1.3.0

⚠️ Important Notice

Piuda (the “Service”) is not officially offered in the United States, EU member states, EEA member states, the United Kingdom, or any other country or region that Passion Factory Corporation (the “Company”) expressly designates as an unsupported region. Accordingly, this Cookie Policy is not intended to represent that the Service satisfies all requirements of laws applicable in those excluded regions, including the GDPR, UK GDPR, ePrivacy Directive, and CCPA/CPRA. For more information about excluded regions, please see Sections 4 and 25C of the Piuda Terms of Service and the Piuda Privacy Policy.

This Cookie Policy (the “Policy”) explains the types of cookies and similar technologies used in Piuda, their purposes, retention periods, and how users can manage them.

This Policy supplements the Piuda Privacy Policy and has been prepared in accordance with applicable laws, including Korea’s Act on Promotion of Information and Communications Network Utilization and Information Protection, etc., the Personal Information Protection Act (PIPA), and Japan’s Act on the Protection of Personal Information (APPI).

Any term used but not defined in this Policy has the meaning given in the Piuda Terms of Service or the Piuda Privacy Policy.

1. Company Information

Item Details
Company name Passion Factory Corporation
Korean company name 주식회사 열정팩토리
Representative Jeonghoon Lee
Address 161 Hakdong-ro, Gangnam-gu, Seoul, Republic of Korea
Business Registration No. 114-87-18004
Mail-Order Business Registration No. 2022-Seoul Gangnam-00382
Email [email protected]
Phone +82-70-7756-1070

2. Key Information

This summary is provided for convenience. The detailed rights and obligations are set out in the sections below.

Item Summary
What is a cookie? A small text file stored on a user’s device when the user accesses the Service
Why we use cookies Service operation (including maintaining login sessions), security (bot management and DDoS protection), and remembering language preferences
Website cookies currently confirmed 4 categories: 3 essential cookies (Better Auth session cookies, i18n_redirected, and Cloudflare infrastructure cookies) + 1 Google Ads advertising/conversion-linking cookie category
No analytics or tracking cookies The Company does not use client-side analytics or tracking cookies. PostHog behavioral analytics uses the client SDK’s localStorage rather than cookies
Advertising cookies for conversion measurement The Company uses Google Ads conversion tracking (gtag.js) to set advertising/conversion-linking cookies such as _gcl_au. These are not used for personalized advertising, retargeting, or profiling. They are managed through notice + opt-out rather than a separate cookie consent banner (see Sections 4.6 and 6.4)
No third-party cross-site tracking cookies The Company does not use third-party tracking cookies for the purpose of tracking users across other websites
Email tracking technology (newsletter only) Open-tracking images and click tracking are used only in newsletters sent to users who have given both the consent to collection and use of personal information for marketing purposes and the consent to receive newsletter (marketing) emails. The information is used to measure newsletter performance, improve content and delivery methods, and manage recipient lists. Without additional consent, it is not used to serve personalized ads, retarget users, build individual advertising profiles, or support third-party ad targeting. The Amazon SES resources and email event stores used by the Company are configured only in the Seoul Region (ap-northeast-2), although information needed to deliver an email may be sent to a recipient’s mail service outside Korea depending on where that mail service operates. The Company has not configured newsletter tracking to set an additional cookie itself. As a precaution, the Company is still verifying whether Amazon SES, another external provider, or the runtime environment may set a separate cookie in connection with tracking requests or redirects (see Section 4.7)
User controls Users can manage cookies through browser settings. Newsletter email tracking can be managed separately using the methods described in Section 4.7.1
Effect of blocking Blocking essential cookies may prevent core functions such as login from working. Stopping newsletter tracking does not affect use of Piuda

3. What Are Cookies and Similar Technologies?

3.1 Definition

A cookie is a small text file stored on a user’s device (such as a computer, tablet, or smartphone) when the user visits a website or uses an application.

3.2 Technologies Covered by This Policy

This Policy also covers similar technologies used by Piuda.

Technology Description How Piuda uses it
HTTP cookies Small text files stored in the browser Used (see Section 5)
Local SQLite A local database stored within the desktop app Used to store Free plan research data, which is generally not sent to the server
localStorage Browser/Electron storage without a built-in expiration date Used for UI state (not sent to the server) and, after consent, for PostHog SDK analytics identifiers such as distinct_id, which are sent to PostHog Cloud in the United States (see Section 7)
OS Keychain Operating-system-level secure credential storage Used for session information in the desktop app through Electron safeStorage
Pixels / beacons Technologies that use image requests or similar signals to detect page views or email opens Website/app: no page-view tracking pixel is used (see Section 4.6 for Google Ads conversion tracking). Newsletter email: used only in newsletters sent to users who have given the relevant optional consents. This is separate from web advertising pixels such as Facebook Pixel (see Section 4.7)
Link click tracking (redirects) Routes an email link through a recipient-specific tracking URL before sending the user to the original destination Used only in newsletter emails. It operates as an email-based tracking technology separate from ordinary website/app cookies. The Company has not configured this feature to set an additional cookie itself, but is conservatively verifying whether an external provider or runtime environment may set a separate cookie in connection with the request or redirect (see Section 4.7)
Third-party advertising SDKs Technology for ad serving or conversion tracking Not used

3.3 Classification by Duration

Type Description
Session cookie A temporary cookie that is deleted when the browser closes or the session expires
Persistent cookie A cookie that remains on the device until its set expiration date or until the user deletes it

3.4 Classification by Setting Party

Type Description
First-party cookie A cookie set by Piuda/the Company or by a server or domain directly operated by the Company
Third-party cookie A cookie set by a service provider or external service, such as Cloudflare

4. Why the Company Uses Cookies and Similar Technologies

4.1 Essential Cookies — Authentication and Session Management

These cookies are required to support login and session continuity and may be set without separate optional consent.

Purpose Description
Authentication Maintains login sessions through Better Auth using HTTP-only Secure cookies
Token management Manages access tokens (15-minute expiration) and refresh tokens (7-day expiration); the previous token is invalidated when refreshed
Security Uses HTTP-only and Secure attributes to reduce the risk of session hijacking

4.2 Essential Cookies — Infrastructure Security

Cloudflare infrastructure cookies are used for bot management and DDoS protection and support the stable operation of the Service.

Purpose Description
Bot management Detects and blocks bots using Cloudflare cookies such as __cf_bm
DDoS protection Identifies and blocks abnormal traffic patterns
Traffic distribution Optimizes traffic handling across edge nodes

4.3 Essential Cookies — Language Preferences

These cookies remember a user’s language preference.

Purpose Description
Language preference Remembers the user’s selected language and displays the same language on the next visit (i18n_redirected, using @nuxtjs/i18n)

4.4 Cookies the Company Does Not Use

The Company does not use cookies for the following purposes.

Cookie / purpose not used Company policy
Analytics/tracking cookies (for example, _ga, _gid, _fbp) Not used. PostHog behavioral analytics uses the client SDK’s localStorage rather than cookies
Personalized advertising / retargeting cookies Not used. The Company does not use cookies to serve personalized ads or retarget users. Google Ads conversion-measurement cookies such as _gcl_au are addressed in Section 4.6
Behavioral advertising profiling cookies Not used
Cross-site tracking cookies Not used. The Company does not track users across other websites
Social-media tracking pixels Not used. The Company does not embed Facebook Pixel, LinkedIn Insight Tag, or similar social-media tracking pixels. Newsletter open-tracking images are a separate technology described in Section 4.7
Profiling cookies Not used. The Company does not build advertising profiles using cookies
Cookies used to collect data for AI model training Not used. Data obtained through cookies is not used to train the Company’s or its AI processing providers’ general-purpose AI models
Sentry tracking cookies Sentry is configured with sendDefaultPii: false so Cookie and Authorization headers are automatically scrubbed. The Company does not use Sentry as an independent user-tracking cookie system

4.5 PostHog Behavioral Analytics and Cookies

The Company uses PostHog to analyze usage patterns. Behavioral events are collected through the client-side posthog-js SDK, while LLM usage is aggregated server-side through posthog-node. In the Company’s current configuration, the PostHog client SDK uses localStorage persistence rather than analytics cookies. Only after consent does it store analytics identifiers such as distinct_id and send them with behavioral events to PostHog Cloud in the United States. Before consent, the opt-out persistence configuration prevents analytics identifiers from being stored.

Item Details
Collection method Client-side posthog-js SDK capture using localStorage instead of analytics cookies + server-side usage aggregation
Consent Handled through the cross-border transfer consent process under Article 28-8 of PIPA, as described in Section 13.4 of the Piuda Privacy Policy
If consent is declined or incomplete The client SDK’s identified path starts in opt-out mode, blocking transmissions (including automatic pageviews) and analytics-identifier storage before consent. It is switched to opt-in after consent. Device-storage-free, non-identifiable anonymous statistics described in Section 6.4 may be handled separately
More information See Section 13.4 and Appendix A.5 of the Piuda Privacy Policy

4.6 Advertising Conversion-Tracking Cookies (Google Ads)

The Company uses Google Ads conversion tracking (gtag.js) to measure advertising performance. When a user arrives through an advertisement and views a landing page, submits an early-access form, or downloads the desktop app, standard gtag may set first-party advertising/conversion-linking cookies to connect an ad click with a resulting conversion.

Item Details
Cookies _gcl_au and other first-party conversion-linking cookies (see Section 5.1)
Purpose Measure advertising conversions (landing-page views, form submissions, desktop-app downloads) and analyze advertising performance
Processing location Conversion-event metadata, IP address, User-Agent, and related information are sent to Google LLC in the United States (see Section 9)
Nature Non-essential advertising cookies used for conversion measurement, not for personalized advertising or profiling
Management No separate cookie consent banner. Managed through this Policy’s notice + user opt-out
Opt-out Block or delete cookies in the browser (Section 6.1) or change Google ad personalization settings
Effect on the Service Opting out does not affect use of Piuda; it only limits advertising conversion measurement

The Company does not currently use these advertising cookies for personalized advertising, retargeting, or individual advertising profiling. The Company also does not use Meta Pixel, LinkedIn Insight Tag, or similar advertising pixels.

4.7 Newsletter Email Open and Click Tracking

The Company does not place newsletter open-tracking pixels/beacons or newsletter click-tracking redirects on the Piuda website, web application, or desktop app. These technologies are used only in newsletter emails sent to users who have given all required newsletter-related optional consents, for the purpose of measuring delivery performance and managing newsletter content and recipient lists. They are email-based tracking technologies distinct from ordinary website/app cookies and from the social-media or web advertising pixels described in Section 4.4.

The Company has not configured this newsletter tracking feature to set an additional cookie itself. As a precaution, the Company is still verifying whether Amazon SES, another external provider, or the runtime environment may issue a separate Set-Cookie header in connection with tracking requests or redirect responses. Accordingly, this Policy does not state that no cookie can ever be set in connection with those responses. If a separate cookie is confirmed in production, the Company will add its name, purpose, setting party, essential/non-essential status, expiration period, and management method to Section 5 and the Appendix.

Item Details
Applies to Newsletter emails sent to users who have given both the consent to collection and use of personal information for marketing purposes and the consent to receive newsletter (marketing) emails under the Piuda Privacy Policy
Does not apply to Service/transactional emails such as password resets, email verification, security alerts, payment notices, and terms or policy update notices (Open Tracking and Click Tracking are off)
Open tracking A recipient-specific, invisible 1×1 transparent image is included in the email. When the recipient’s mail app requests the image, open status, time, and related information may be recorded
Click tracking Links in the email route through a recipient-specific tracking URL before redirecting to the original destination, allowing the clicked link identifier, time, and related information to be recorded
Processor Amazon Web Services Korea LLC (Amazon SES)
Company-configured processing location Amazon SES resources and email event stores are configured only in the Seoul Region (ap-northeast-2)
Final email delivery Depending on where the recipient’s mail service operates, information necessary to deliver the message, including the email address and email content, may be sent to that mail service outside Korea. See Section 13.1 of the Piuda Privacy Policy
Data processed Newsletter open status and time; clicked link/link identifier and time; IP address and User-Agent at the time of an open or click, including device, operating system, browser, and mail-app information
Purpose Analyze newsletter sending, delivery, opens, and link clicks; measure newsletter performance; improve content and delivery methods; manage recipient lists
Use restrictions Without additional consent, the data is not used to infer interests or preferences, serve personalized ads, retarget users, build individual advertising profiles, or support third-party ad targeting
Tracking on service/transactional emails Open Tracking and Click Tracking are not used
Company DB retention Until the earliest of: 1 year from collection, withdrawal of the consent to collection and use of personal information for marketing purposes, or account deletion. At the end of the retention period, the data is deleted or converted into statistics that no longer identify an individual
AWS-side event data Related event data separately stored in AWS event paths or stores configured by the Company is automatically deleted after 30 days under the Company’s retention settings
Consent basis Not the web cookie banner. Processing is based on the consent to collection and use of personal information for marketing purposes and the consent to receive newsletter (marketing) emails under the Piuda Privacy Policy
Separate cookies in tracking responses The Company has not configured the feature to set an additional cookie itself. It is conservatively verifying whether an external provider or runtime environment may set a separate cookie; if one is confirmed, the cookie list and management procedures in this Policy will be updated

4.7.1 How to Stop or Limit Tracking

Newsletter email open and click tracking is managed separately from ordinary website cookie settings.

Method Effect
Restrict automatic loading of external images in the mail app To the extent the open-tracking image request is prevented, an open record may not be generated. If the user clicks a link directly, click tracking may still occur
Withdraw consent to receive newsletter (marketing) emails Use the unsubscribe link in the email footer, the unsubscribe control provided by the mail app, or Settings > Data & Privacy in the Service. The consent status is changed to “withdrawn,” future newsletters are stopped, and no new open/click records are generated. Unsubscribing through the email link withdraws only the email-receipt consent and does not automatically withdraw the consent to collection and use of personal information for marketing purposes. Existing records remain subject to the retention periods in Section 10.1 of the Piuda Privacy Policy
Withdraw consent to collection and use of personal information for marketing purposes Use Settings > Data & Privacy or contact [email protected]. The consent status is changed to “withdrawn,” newsletter delivery stops, and identifiable newsletter sending, delivery, open, and click records retained on the basis of that consent are deleted without undue delay. Newsletter suppression data, statistics that no longer identify an individual, and consent/withdrawal evidence retained under the Company’s retention standards are handled separately

Stopping newsletter emails or withdrawing consent to collection and use of personal information for marketing purposes does not affect use of the Piuda Service.

4.7.2 Notes on Measurement Accuracy

  • Some mail apps and email security systems may fetch images before the user actually opens the email, so an open record may not correspond to an actual user open.
  • Enterprise email systems or security services may automatically inspect or pre-fetch links, which can be recorded as clicks even when the user did not click them. The Company takes these technical limitations into account when interpreting newsletter performance metrics.
  • For more information about the personal information processed, see Sections 3, 5, 10, 12, and 13 of the Piuda Privacy Policy.

5. Cookies Used by the Company

This section describes the website and web-application cookies currently confirmed by the Company. Newsletter email open and click tracking is described separately in Section 4.7. The Company has not configured newsletter tracking to set an additional cookie itself, but is conservatively verifying whether an external provider or runtime environment may set a separate cookie in connection with tracking requests or redirects. If a separate cookie is confirmed, it will be added to this section and the Appendix.

5.1 Cookies in Use

Cookie Category Purpose Set by HttpOnly Secure Expiration
Better Auth session cookie Essential (authentication) Maintain login session Better Auth (Company server) Applied Applied According to session policy (Access 15 minutes, Refresh 7 days)
i18n_redirected Essential (functionality) Store language preference @nuxtjs/i18n Not applied Depends on runtime configuration Browser default or runtime configuration
Cloudflare infrastructure cookies (__cf_bm, etc.) Essential (infrastructure) Bot management, DDoS protection Cloudflare Varies by cookie Varies by cookie About 30 minutes for __cf_bm; other cookies follow Cloudflare policy
_gcl_au and related Google Ads cookies Non-essential (advertising/conversion linking) Advertising conversion measurement Google Ads gtag.js (first party) Not applied Depends on runtime configuration About 90 days (Google Ads policy)

5.2 Cookies Not Used

Category Status
Client-side analytics/tracking cookies Not used — PostHog uses the client SDK’s localStorage instead of cookies
Personalized advertising / retargeting cookies Not used — see Section 5.1 for conversion-measurement cookies such as _gcl_au
Third-party tracking cookies Not used
Sentry tracking cookies The Company does not use Sentry for user-tracking cookies
Google Analytics cookies (_ga, _gid, etc.) Not used — Google Analytics is not used

5.3 Authentication Data Processing (Reference)

Authentication-related data associated with cookies is handled as follows.

Item Details
Web session management HTTP-only Secure Cookie
Desktop session management OS Keychain (Electron safeStorage) — secure OS-level storage rather than cookies
Token expiration Access: 15 minutes / Refresh: 7 days
Token rotation Previous token is invalidated on refresh
Session data Session ID, token, expiration time, optional IP address, optional User-Agent

6. Managing Cookies and Similar Technologies

6.1 Browser Controls

Users can manage acceptance, blocking, deletion, and notifications for cookies through browser settings.

Browser Example settings path
Chrome Settings > Privacy and security > Site settings > Cookies and site data
Safari Settings or Preferences > Privacy > Cookies and website data
Firefox Settings > Privacy & Security > Cookies and Site Data
Edge Settings > Cookies and site permissions > Cookies and site data

Blocking all cookies may limit normal use of the Service, particularly login functionality.

6.2 Mobile Devices

Device How to manage
iOS (Safari) Settings > Safari > Privacy & Security, then adjust cookie-related settings
Android (Chrome) Chrome > More > Settings > Site settings, then adjust cookie-related settings

6.3 Desktop App

Session information in the Electron-based desktop app is stored in the OS Keychain using Electron safeStorage. To end a session, use the logout function in the app. Some web content or external pages may use browser technologies, so the exact storage behavior may vary depending on the runtime environment.

6.4 Consent Banner Operation

The web cookies used by the Company consist of authentication, security, and language-preference cookies needed to operate the Service, plus non-essential Google Ads conversion-measurement cookies. The Company does not operate a separate consent banner for Google Ads conversion-measurement cookies and manages them through notice in this Policy + user opt-out (see Section 4.6). Users can block or delete cookies through browser settings or change Google ad personalization settings to limit use of those cookies.

PostHog behavioral analytics uses client-side localStorage rather than cookies. For personal information transferred outside Korea, the Company follows the consent process described in Section 13.4 of the Piuda Privacy Policy. When the Company operates an opt-in banner for identified behavioral analytics and anonymous-to-sign-up conversion measurement, an analytics identifier such as distinct_id is stored in localStorage and persistent behavioral tracking is enabled only after the visitor gives explicit consent. Before consent or after refusal, that identified path is not activated. The user’s consent choice itself may be stored on the device, together with the applicable policy version and timestamp, to avoid repeatedly displaying the banner and to honor the user’s choice.

Separately, the Company may operate anonymous usage statistics that do not store values on the device and do not create personal profiles. These statistics may cover visits, referrers, download-button clicks, sign-up/login starts, pricing-page views, and other key interactions. A temporary identifier used to connect page transitions within a single visit exists only in browser or app memory and is deleted when the window is closed or the app restarts, so it cannot link a returning user to a prior visit or session. IP addresses are not sent, no personal profile is created in the analytics tool, and collected fields are limited to predefined event-specific lists. The detailed scope and handling are described in Section 13.4 of the Piuda Privacy Policy.

If the Company later introduces additional non-essential cookies or tracking technologies on the website or app, such as personalized-advertising/retargeting cookies or marketing pixels, it will update this Policy and apply the notice or consent process required by the nature of the technology and applicable law.

Newsletter email open and click tracking (Section 4.7) is an email-based tracking technology separate from ordinary browser cookies set when a user visits the website. It is operated based on the consent to collection and use of personal information for marketing purposes and the consent to receive newsletter (marketing) emails under the Piuda Privacy Policy. The Company has not configured this feature to set an additional cookie itself. As a precaution, it is still verifying whether an external provider or runtime environment may set a separate cookie in connection with the tracking response. If a cookie is confirmed, the Company will update the cookie list and management instructions in this Policy.

6.5 Global Privacy Control (GPC)

If a user’s browser sends a GPC signal, the Company will make reasonable efforts to take that signal into account for non-essential identifiable data collection. The Company’s non-essential web cookies are Google Ads conversion-measurement cookies, which users can limit through the opt-out methods described in Section 4.6. Anonymous usage statistics that do not store values on the device and do not identify individuals may operate through a separate technical path.

6.6 Do Not Track (DNT)

The Company does not currently respond consistently to DNT signals. The Company’s non-essential web cookies are Google Ads conversion-measurement cookies, and the Company does not build behavioral advertising profiles. Users can limit advertising cookies using the opt-out methods described in Section 4.6.

6.7 Managing Email Tracking Technology

Newsletter email open and click tracking is managed separately from ordinary browser cookie settings. The Company has not configured the feature to set an additional cookie itself, but is conservatively verifying whether an external provider or runtime environment may set a separate cookie in connection with tracking responses. See Section 4.7.1 for ways to stop or limit tracking. If a separate cookie is confirmed, the Company will also add browser-management instructions for that cookie to this Policy.

7. Local Storage (Reference)

In addition to cookies, Piuda uses the following forms of local storage. Storage location and server transmission differ by item.

7.1 Local SQLite in the Desktop App (Free Plan Research Data)

Free plan research data, including paper metadata, analysis results, and notes, is generally stored in a local SQLite database on the user’s device.

Item Details
Storage location User device (embedded SQLite in Electron)
Transmission to Company servers Generally not transmitted. Information needed for AI analysis or other functions may be transmitted temporarily as described in the Piuda Terms of Service and Privacy Policy
Original PDF files Under the current technical architecture, original PDFs do not leave the user’s device
Deletion The user can delete the data by uninstalling the app, resetting the device, or similar actions
Risk of data loss The user bears the risk of loss caused by device loss, app deletion, storage corruption, and similar events
Backups Users are responsible for backing up important research materials

7.2 localStorage

Piuda may use localStorage to store UI state and, with consent, to support PostHog behavioral analytics.

Stored item Purpose Server transmission
UI state Onboarding-card visibility, recommendation settings, analysis overlay mode, and similar preferences Not sent to the server
PostHog analytics identifiers Stores identifiers such as distinct_id and super-properties after consent After consent, sent to PostHog Cloud in the United States with behavioral events / not stored before consent

7.3 OS Keychain (Electron safeStorage)

Desktop app session information is stored securely in the operating system’s credential store, such as macOS Keychain, Windows Credential Manager, or Linux Secret Service, rather than in a cookie.

8. Effects of Disabling Cookies or Stopping Tracking

Item disabled or stopped Effect
Better Auth session cookie Login may fail or session continuity may be lost, limiting use of the Service
Cloudflare infrastructure cookies (__cf_bm, etc.) Bot management and DDoS protection may be limited, which can restrict access to the Service
i18n_redirected The language preference may not be retained, so the user may need to select a language again
Google Ads conversion-measurement cookies No effect on use of the Service; advertising conversion measurement is limited
Withdrawal of consent to receive newsletter (marketing) emails Newsletter delivery stops; no effect on use of Piuda
Withdrawal of consent to collection and use of personal information for marketing purposes Newsletter delivery and processing of identifiable sending, delivery, open, and click data based on that consent stop; no effect on use of Piuda

9. Cross-Border Transfers Related to Cookies

9.1 Overview

Among the web cookies used by the Company, Better Auth session cookies are processed in the GCP Seoul Region and therefore do not constitute a cross-border transfer. Information related to Cloudflare infrastructure cookies and Google Ads advertising cookies is transferred to the United States and therefore constitutes a cross-border transfer.

Newsletter email open and click tracking is described separately from web cookies in Section 4.7. The Company’s Amazon SES resources and email event stores are configured only in the Seoul Region. However, during final delivery, information necessary to deliver an email may be sent to a recipient’s mail service outside Korea depending on where that mail service operates. See Section 13.1 of the Piuda Privacy Policy for details.

Cookie Processing location Cross-border transfer
Better Auth session cookie Seoul (GCP asia-northeast3) No
i18n_redirected User device (browser) No — stored in the browser
Cloudflare infrastructure cookies (__cf_bm, etc.) Global Edge Yes — Cloudflare, Inc. (U.S. entity)
_gcl_au and related Google Ads cookies User device + transfer to Google Yes — Google LLC (U.S. entity)

9.2 Cross-Border Transfer of Cloudflare Infrastructure Cookie Information

Item Details
Recipient Cloudflare, Inc.
Destination United States (global Edge network)
Purpose Bot management, DDoS protection, CDN traffic optimization
Data transferred HTTP metadata (IP address, User-Agent) and information related to bot-management cookies such as __cf_bm
Retention According to each cookie’s expiration period and Cloudflare policy
Timing / method When the user accesses the web service / HTTPS
Safeguards TLS encryption and related security measures

9.3 Cross-Border Transfer of Google Ads Cookie Information

Item Details
Recipient Google LLC
Destination United States
Purpose Measure advertising conversions (landing-page views, form submissions, desktop-app downloads) and analyze advertising performance
Data transferred Conversion-event metadata (page path and timestamp), IP address, User-Agent/device/browser information, and conversion-linking identifiers such as _gcl_au
Retention According to Google Ads policy (cookie approximately 90 days)
Timing / method When a conversion event occurs after an ad-driven visit / HTTPS
Right to opt out Yes — use the opt-out methods in Section 4.6. Opting out does not affect use of the Service

9.4 Essential Cookie Notice

Cloudflare infrastructure cookies are used to the extent necessary for service access and security. Restricting these technologies may limit access to the Service or certain security functions.

For additional information about cross-border transfers of personal information, see Section 13 of the Piuda Privacy Policy.

10. Additional Regional Information

10.1 Users in the Republic of Korea (PIPA / Information and Communications Network Act)

The Company is a Korean corporation and seeks to comply with applicable privacy and information-communications laws.

10.1.1 Consent and Management Rules for Cookies and Email Tracking

Category Status Consent / management
Essential cookies (Better Auth session, Cloudflare infrastructure, i18n) Used Used to the extent necessary to provide the Service
Additional functionality cookies None -
Analytics cookies Not used -
Advertising cookies (_gcl_au, etc., Google Ads conversion measurement) Used Managed through notice + opt-out (see Section 4.6)
Personalized advertising / retargeting cookies Not used -
Newsletter open-tracking images / link-click tracking Used only in newsletters sent to users who have given all relevant optional consents Managed separately from the web cookie banner through the consent to collection and use of personal information for marketing purposes and the consent to receive newsletter (marketing) emails under the Piuda Privacy Policy (see Section 4.7). The Company has not configured the feature to set an additional cookie itself, but is conservatively verifying whether an external provider or runtime environment may set a separate cookie in connection with tracking responses

10.1.2 Cross-Border Transfer of Cookie-Related Information

HTTP metadata such as IP addresses and User-Agent information associated with Cloudflare infrastructure cookies is transmitted to Cloudflare’s global Edge network in the United States.

Conversion-event metadata, IP addresses, User-Agent information, and related Google Ads cookie information are transmitted to Google LLC in the United States (see Section 9.3). Users can limit this processing through the opt-out methods in Section 4.6 without affecting their ability to use Piuda.

Cross-border transfers associated with PostHog behavioral analytics use a client SDK and localStorage rather than cookies and are handled through the Article 28-8 PIPA consent process described in Section 13.4 of the Piuda Privacy Policy.

Newsletter open and click tracking is governed by Section 4.7. The Company-configured SES resources and email event stores are located only in the Seoul Region, while final email delivery may involve a mail service outside Korea depending on where the recipient’s provider operates (see Section 13.1 of the Piuda Privacy Policy).

10.1.3 Changing Cookie Settings and Effects of Blocking

See Sections 6 and 8 for cookie-management methods and the effects of restricting cookies.

10.1.4 Remedies and Complaint Channels

For privacy complaints related to cookies or similar technologies, users may contact the remedies and complaint bodies listed in Section 14.6 of the Piuda Privacy Policy.

10.2 Users in Japan (APPI)

10.2.1 Cookies and Personally Related Information

A cookie does not automatically constitute personal information under Japan’s APPI. However, the APPI may apply when cookie information can identify an individual when combined with other information or when it is handled as “personally related information” (個人関連情報).

10.2.2 Company Practices for Cookies and Email Tracking

Item Description
Advertising conversion cookies The Company uses Google Ads conversion tracking (gtag.js) to set conversion-linking cookies such as _gcl_au. They are not used for personalized advertising or profiling, and users can limit them through opt-out controls
No analytics cookies The Company does not use client-side analytics cookies. PostHog behavioral analytics uses the client SDK’s localStorage instead
Email tracking The Company uses open-tracking images and link-click tracking only in newsletters sent to users who have given all relevant optional consents. The Company’s SES resources and email event stores are configured only in the Seoul Region, so information needed to send email to users in Japan and related open/click events may be processed in Korea. Final delivery may occur in another country depending on where the recipient’s mail service operates
Third-party disclosure The Company does not provide personally related information about users in Japan to third parties for those third parties’ own purposes
Cross-border processing HTTP metadata related to Cloudflare infrastructure and information related to Google Ads conversions may be transmitted to the United States. For Amazon SES processing, see the email-tracking row above and Section 19.2 of the Piuda Privacy Policy

10.2.3 Japanese-Language Version

If a separate Japanese version of the Cookie Policy is provided, it may take precedence for users residing in Japan.

10.3 Other Supported Regions

10.3.1

This Policy also applies to users in supported regions other than the United States, EU/EEA, United Kingdom, and any region the Company expressly designates as unsupported.

10.3.2

The Company applies any notice or consent process required by mandatory law in the applicable region. The web cookies used by the Company consist of essential cookies for authentication, security, and language preferences, together with non-essential Google Ads conversion-measurement cookies. The Company does not use analytics cookies or personalized advertising/retargeting cookies. Newsletter open and click tracking is described separately in Section 4.7.

10.3.3

If mandatory law in the applicable region gives users rights that are more protective than this Policy, that mandatory law prevails.

10.4 Excluded Regions, Including the United States, EU/EEA, and United Kingdom

The United States, EU member states, EEA member states, the United Kingdom, and any other country or region expressly designated by the Company as unsupported are not currently official Piuda service regions. This Policy should not be interpreted as a representation or guarantee that the Company already satisfies all requirements of laws in those excluded regions, including the GDPR, UK GDPR, ePrivacy Directive, and CCPA/CPRA (see Sections 4 and 25C of the Piuda Terms of Service).

11. Changes to This Policy

11.1

The Company may update this Policy in response to changes in the cookies or similar technologies it uses, including the introduction of non-essential cookies or tracking technologies, as well as changes in law or operating practices.

11.2

The Company will provide notice of changes as follows.

Type of change Notice method
Material change (for example, introduction of a new non-essential cookie or tracking technology, or a material change in processing purpose) Notice at least 30 days before the effective date by email, in-service notice, pop-up, banner, or similar method. If applicable law requires separate consent, the Company will obtain that consent
Minor change (for example, correcting a typo, clarifying wording, or making a routine update to external-provider information) Update the “Last Updated” date and publish the revised Policy

11.3

If the Company later introduces a new non-essential cookie or tracking technology on the website or app, it will update this Policy before introduction and provide the notice, consent, and opt-out mechanisms required by the nature of the technology and applicable law.

12. Contact Information

For questions about cookies or similar technologies, please contact us using the information below.

Item Details
Company Passion Factory Corporation (주식회사 열정팩토리)
Address 161 Hakdong-ro, Gangnam-gu, Seoul, Republic of Korea
Email [email protected]
Suggested subject line “Cookie Policy Inquiry”
Phone +82-70-7756-1070

For general questions about personal information processing, see Section 22 of the Piuda Privacy Policy or contact the Company’s privacy officer.

Appendix: Cookies and Similar Technologies in Use

This Appendix summarizes the cookie list in Section 5.1 and the email-tracking technologies in Section 4.7. Actual cookie names, retention periods, and technical configurations may vary with the production environment. Material changes will be handled under the change process described in this Policy.

Cookies Currently in Use (3 Essential Cookie Categories + 1 Advertising/Conversion-Linking Cookie Category)

Cookie Category Purpose Set by HttpOnly Secure Expiration
Better Auth session cookie Authentication Maintain login session Better Auth (Company server) Applied Applied Access 15 minutes, Refresh 7 days
i18n_redirected Functionality Store language preference @nuxtjs/i18n Not applied Depends on runtime configuration Browser default or runtime configuration
Cloudflare infrastructure cookies (__cf_bm, etc.) Infrastructure Bot management, DDoS protection Cloudflare Varies by cookie Varies by cookie About 30 minutes for __cf_bm; other cookies follow Cloudflare policy
_gcl_au and related Google Ads cookies Advertising (conversion linking) Advertising conversion measurement Google Ads gtag.js (first party) Not applied Depends on runtime configuration About 90 days

Cookie Categories Not Used

Category Status Notes
Client-side analytics cookies (_ga, _gid, etc.) Not used PostHog behavioral analytics uses the client SDK’s localStorage instead of cookies
Personalized advertising / retargeting cookies Not used See conversion-measurement cookies such as _gcl_au above
Behavioral advertising profiling cookies Not used -
Cross-site tracking cookies Not used -
Social-media tracking pixels (Facebook Pixel, LinkedIn Insight, etc.) Not used Newsletter open-tracking images are a separate email technology
Profiling cookies Not used -
Independent Sentry tracking cookies Not used sendDefaultPii: false and other data-minimization settings are applied

Non-Cookie Tracking Technologies (Newsletter Email Only)

The technologies below are email-tracking technologies separate from website/app cookies. The Company has not configured them to set an additional cookie itself. As a precaution, the Company is still verifying whether an external provider or runtime environment may set a separate cookie in connection with tracking requests or redirects. If a separate cookie is confirmed, it will also be added to the cookie list above.

Technology Applies to Purpose Processor / location Retention
Open-tracking image (recipient-specific 1×1 transparent image) Newsletters sent to users who have given all relevant optional consents Record open status and time Amazon Web Services Korea LLC (Amazon SES) — Company resources and event stores configured only in the Seoul Region / Company DB in Seoul See Section 4.7
Link-click tracking (recipient-specific redirect) Same as above Record clicked link and time Same as above See Section 4.7

Non-Cookie Local Storage (Reference)

Item Location Purpose Server transmission
Local SQLite Desktop app (embedded Electron SQLite) Free plan research data, including paper metadata, analysis results, and notes Generally not transmitted. Information needed for AI analysis or other functions may be transmitted temporarily as described in the Piuda Privacy Policy
localStorage (UI state) Browser / Electron UI state such as onboarding-card visibility, recommendation settings, and analysis overlay mode Not sent to the server
localStorage (PostHog SDK) Browser / Electron Analytics identifiers such as distinct_id and super-properties, stored only after consent After consent, sent to PostHog Cloud in the United States / not stored before consent
OS Keychain (Electron safeStorage) Desktop OS Session information Not sent to the server

End of Policy

This Policy was originally written in Korean. If an English or other translated version is provided, the Korean version prevails for users in the Republic of Korea. If a Japanese version is provided, it may take precedence for users residing in Japan. In other supported regions, the English version or another version separately designated by the Company may apply.

This Piuda Cookie Policy supplements the Piuda Privacy Policy and should be read together with the Piuda Terms of Service and Piuda Privacy Policy.

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