# Privacy Policy StarlitWhale (the "Operator") processes the personal information of people who use the game Starlit Song ([ciel.starlitwhale.com](https://ciel.starlitwhale.com/), the "Game") in accordance with the Personal Information Protection Act of Korea (개인정보 보호법), and publishes this privacy policy as follows. This policy applies only to the Game. The Operator's company website (starlitwhale.com) is covered by that website's own [privacy policy](https://starlitwhale.com/en/privacy/). Effective date: October 21, 2026 ## 1. Personal information we process and why The Game does not collect email addresses, real names or phone numbers. An account is created with only a username and a password. ### Information processed to perform the service agreement (processed without consent — Personal Information Protection Act of Korea, Article 15(1)4) This information is essential to providing the Game and is processed to perform the service agreement formed when you accept the terms of use. | Item | Purpose | | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | --------------------------------------------------------- | | Username | Identifying member accounts, signing in | | Hash of the password verifier (the password itself is never sent to the server; see section 7) | Verifying sign-in | | Sign-in state (login cookie, server session and connection check value to detect the same account in another browser) | Keeping you signed in and detecting duplicate connections | | Agreement records (language and version of the text you agreed to, and whether you agreed) | Confirming which text you agreed to | | Inquiries (subject, message, time sent, game language, game version, member account or hash of the guest inquiry key, status, Operator's reply, Korean translations and notes for Operator review (only for inquiries with consent to AI processing)) | Reviewing and answering inquiries | | Failed sign-in records (IP address, time) | Blocking attacks that try passwords at random | | Inquiry rate-limit records (account for members, IP address for guests, time) | Preventing too many inquiries in a short time | | Sign-up rate-limit records (IP address, time) | Preventing too many sign-ups in a short time | | Failed code entry records (account, time) | Preventing codes from being tried at random | ### Information processed with consent (statistics collection consent — Article 15(1)1 of the same Act) Processed only if you agree to "Statistics collection" in the Game. The full list of items is the same as the text on the consent screen. | Item | Purpose | | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ----------------------------------------------------------------------------------------------------------------------- | | Settings (display and voice language, cut-in display, on/off settings, volume, key settings, title screen outfit, setting values) | Statistics for improving the Game, totals on the in-game "Statistics" screen, keeping your settings for your next visit | | Unlock status (gallery, outfits), story progress | Same as above | | Saves (up to 3 slots — progress point, play time, region, outfits and accessories, recipes, records of puzzles, bosses and quests, defeat and pickup counts, spells and mastery, etc. For members the whole save is kept on the server) | Same as above, keeping member saves | | Guest ID (a random number created the first time this browser saves) | Distinguishing statistics of users who are not signed in | Statistics do not store IP addresses, browser information or device information. When guest statistics are sent, the IP address is used only in server memory to limit the number of requests and is not stored. ## 2. Processing and retention periods | Information | Retention period | | --------------------------------------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | Username, hash of the password verifier | Until you delete your account | | Sign-in state (session and connection check value) | 30 days from last use (extended each time you use the Game). Deleted when you sign out, sign in again or delete your account. Expired session records are deleted together when you delete your account | | Agreement records | Members: until you delete your account / Guests: kept only in your browser | | Information processed under statistics collection consent | Until you withdraw consent, delete your account or request deletion | | Guest ID | Until you withdraw consent or it is merged into your member record when you sign up | | Inquiries and replies | Until you delete your account or delete them yourself | | Failed sign-in records | Only records from the last 10 minutes are used. Records older than 10 minutes are deleted when a later failed sign-in is processed | | Inquiry rate-limit records | Only records from the last 10 minutes are used. Records older than 10 minutes are deleted when a later inquiry is received | | Sign-up rate-limit records | Only records from the last hour are used. Records older than one hour are deleted when a later sign-up is processed | | Failed code entry records | The previous record is deleted the next time the same account fails a code entry. This record remains even after you delete your account | If the Game service ends, any remaining information is destroyed without delay. ## 3. Destruction procedure and method - When you delete your account, your account, saves, settings, sessions, and inquiries and replies are deleted from the database immediately. - When you withdraw statistics collection consent, your stored saves and settings are deleted immediately (for members, only the account, sign-in information and agreement records remain). - When you delete an inquiry yourself, that inquiry and its replies are deleted immediately. - All information is kept only as electronic files and is destroyed by deleting it from the database. ## 4. Provision to third parties The Operator does not provide personal information to third parties, except when required by law. ## 5. Outsourcing and overseas transfer To run the Game, the Operator entrusts personal information processing to the companies below, and in the process personal information is transferred outside Korea. The transfer to Cloudflare is based on Article 28-8(1)3 of the Personal Information Protection Act of Korea (overseas outsourcing and storage to perform the service agreement), and the transfer to Anthropic is based on your separate consent under Article 28-8(1)1 of the same Act. The matters required by Article 28-8(2) are as follows. **Why is this "outsourcing"?** - Cloudflare: The Game's server program and database do not run on a computer the Operator owns but on Cloudflare's cloud. Information such as accounts, saves and inquiries is stored on Cloudflare's equipment and processed there, which means the work of processing personal information is entrusted to Cloudflare (outsourcing). Because that equipment is also outside Korea, it is an overseas transfer as well. - Anthropic: When the Operator drafts a reply, the inquiry is sent to Anthropic's AI tool (Claude) to be processed, so it is listed in this table for the same reason. Anthropic's equipment is in the United States. | Category | Cloudflare | Anthropic | | ----------------------------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ | | Recipient | Cloudflare, Inc. — 101 Townsend St, San Francisco, CA 94107 USA / privacy contact [dpo@cloudflare.com](mailto:dpo@cloudflare.com) | Anthropic, PBC — 548 Market St, PMB 90375, San Francisco, CA 94104 USA / privacy contact [privacy@anthropic.com](mailto:privacy@anthropic.com) | | Work entrusted | Running the game server, database storage, storing and delivering image files, handling connections | Providing the AI tool (Claude) the Operator uses to draft replies to inquiries | | Legal basis for transfer | Overseas outsourcing and storage necessary to perform the service agreement (Article 28-8(1)3 of the same Act) | Your separate consent (Article 28-8(1)1 of the same Act), obtained on a consent screen the first time you use the in-game inquiry window | | Items transferred | All items in section 1, and your IP address when you connect to the Game | Inquiry subject and message, inquiry language | | Destination country | Database: Cloudflare Asia-Pacific (APAC) region — Cloudflare does not disclose locations at the country level / Server execution and connection handling: the Cloudflare data center nearest to you among its data centers worldwide (in many countries, including the United States), [list of Cloudflare data centers](https://www.cloudflare.com/network/) | United States | | Time and method of transfer | Sent over encrypted connections (HTTPS) each time you use the Game | Sent over encrypted connections when the Operator drafts a reply | | Recipient's purpose of use and retention period | Performing the work above. Kept for the periods in section 2 of this policy | Drafting replies. The Operator's Claude account is set not to be used for model training, and in that case Anthropic keeps conversations for 30 days. Conversations that Anthropic determines to violate its Usage Policy are kept for up to 2 years | | How to refuse and the effect | The Game runs only on Cloudflare, so if you refuse you cannot use the Game. If you do not want this, you can delete your account (guests: withdraw consent) or request deletion at the contact in section 9 | You can decline on the consent screen of the inquiry window. If you decline, you cannot use the in-game inquiry window, but you can send your inquiry by email to [no-ai@starlitwhale.com](mailto:no-ai@starlitwhale.com) instead. Inquiries to this mailbox are not handled with AI tools, and replies may take longer. Even after agreeing, you can withdraw at any time under "Inquiry AI processing consent" in Settings → "Manage agreements"; once withdrawn, no AI drafts are made even for inquiries already sent, and AI drafts already made are not sent | Replies made with the AI tool are saved only as drafts and are sent after the Operator reviews them. Replies sent without changes by the Operator are labeled "AI-written reply". ### Information passed on when fonts are loaded Some fonts on the game screen are loaded from external font services. Because your browser requests the fonts directly, your IP address and browser information are passed to those companies. The Operator does not send any other personal information to them. | Company | Country | Information received | Privacy policy | | ------------------------------- | -------------- | -------------------------------------------------------- | ---------------------------------------------------------------------------------------------------------------------------------- | | jsDelivr (Volentio JSD Limited) | United Kingdom | IP address, browser information, requested address, time | [jsDelivr Privacy Policy](https://www.jsdelivr.com/terms/privacy-policy) (contact [legal@jsdelivr.com](mailto:legal@jsdelivr.com)) | | Google Fonts (Google LLC) | United States | IP address, requested address, browser information | [Google Privacy Policy](https://policies.google.com/privacy) | ## 6. Your rights and how to exercise them You may at any time access your personal information, request its correction, deletion or suspension of processing, or withdraw your consent. In accordance with Article 41(1) and (2) of the Enforcement Decree of the Personal Information Protection Act of Korea (applied mutatis mutandis by Articles 43 and 44), the Operator provides the following features so that you can exercise these rights in the same way and in the same place where the information was collected: inside the Game. - **Access**: Under Settings → "Manage agreements" → "View my information" you can see the information the Game has stored on the server and in this browser, and save it with "Download file". - **Deletion**: Choosing "Delete account" in "Manage agreements" deletes your account, saves, settings, sessions and inquiries. Choosing "Withdraw statistics consent" deletes your stored saves and settings; for guests, the saves and guest records in this browser and their inquiries are deleted as well. You can delete inquiries you sent yourself on the inquiry screen. - **Suspension of processing**: Choosing "Withdraw statistics consent" in "Manage agreements" stops the processing of information processed under statistics collection consent, and the stored information is deleted. You can agree again in the same place. - **Correction**: Information that can be corrected (settings such as display and voice language, volume and key settings) can be changed directly in the in-game settings. - **Withdrawal of consent**: You can withdraw your consent to having inquiries handled with AI tools at any time under "Inquiry AI processing consent" in Settings → "Manage agreements". Once withdrawn, no AI drafts are made even for inquiries already sent, and AI drafts already made are not sent. Inquiries that have not yet received a reply receive a reply explaining how to contact us by email without AI processing (no-ai@starlitwhale.com), and are marked as completed. - For requests you cannot make in the Game, please contact the privacy officer at the contact in section 9. You may also make requests through a representative. - Because the Game does not collect email addresses or real names, there is no other means of verifying your identity, so access or deletion requests for the account of a member who has forgotten their password cannot be processed. - If we refuse a request or carry it out only in part, we will tell you why, and you can object at the same contact. - We do not accept account registrations from children under 14 or knowingly process their personal information. If we learn that a child’s personal information has been processed, we delete it, and their legal guardian may exercise the rights above. ## 7. Security measures - All communication is encrypted with HTTPS. - The password itself is never sent to the server. The server hashes the verifier computed in the browser once more and stores that. - The login cookie is set so that scripts in the browser cannot read it (HttpOnly) and it is sent only over HTTPS (Secure). - Sign-in state records and connection check values are stored as hashes, not as the original values. - Operator features can be used only with a secret key held by the Operator. The Operator's admin screen is behind a sign-in on the Operator's server, and the secret key never goes to users' browsers. - Failed sign-ins and the number of inquiries and sign-ups are limited to block random guessing and excessive requests. ## 8. Automatic collection tools (cookies and browser storage) The Game does not use cookies or tracking tools for advertising or visitor analytics. | Name | Type | What and why | | --------------------- | --------------- | --------------------------------------------------------------------- | | Login cookie | Cookie | Keeps members signed in. 30 days, extended each time you use the Game | | ciel-consent | Browser storage | Guest agreement records | | ciel-stats-uid | Browser storage | Guest ID (if you agreed to statistics collection) | | Guest saves | Browser storage | Guest saves and settings (if you agreed to statistics collection) | | Guest inquiry keys | Browser storage | Keys for viewing inquiries a guest sent, and inquiries not yet sent | | Other display records | Browser storage | Mute, and whether notices and inquiry replies have been read | If you block the login cookie you cannot sign in, but you can still play as a guest. You can clear browser storage at any time in your browser settings; doing so also removes guest saves and inquiry keys. Information in browser storage exists only in your browser and is not kept separately by the Operator (guest information for which statistics collection was agreed is also kept on the server, as described in section 1). ## 9. Privacy officer The Game is run by an individual, and the Operator personally serves as privacy officer, handling inquiries, complaints and remedies related to personal information processing. - Privacy officer: StarlitWhale - Email: [ryuhaneul@starlitwhale.com](mailto:ryuhaneul@starlitwhale.com) — inquiries to this mailbox are handled with the help of AI tools. - Inquiries you do not want handled by AI: [no-ai@starlitwhale.com](mailto:no-ai@starlitwhale.com) — inquiries to this mailbox are not handled with AI tools, and replies may take longer. ## 10. Remedies for infringement If you need to report or get advice about a personal information infringement, you can contact the following organizations in Korea. - 개인정보침해신고센터 (Personal Information Infringement Report Center) ([privacy.kisa.or.kr](https://privacy.kisa.or.kr/) / 118 within Korea) - 개인정보분쟁조정위원회 (Personal Information Dispute Mediation Committee) ([www.kopico.go.kr](https://www.kopico.go.kr/) / 1833-6972) - 공소청 (Prosecution Service) ([www.spo.go.kr](https://www.spo.go.kr/) / 1301 within Korea) - 경찰청 사이버수사국 (Korean National Police Agency, Cyber Investigation Bureau) ([ecrm.police.go.kr](https://ecrm.police.go.kr/) / 182 within Korea) ## 11. Changes to this policy If this policy changes, we will announce it in a game notice and on this page. - Effective date: October 21, 2026