1. Controller

염승민, an individual developer based in the Republic of Korea and operator of AVELUNE Browser. Contact: privacy@avelunebrowser.com. Registrations may be accepted from outside Korea; beta availability and invitation timing may vary by country or region. This is the Korean-source operating notice for the beta waitlist, not the Android app privacy policy. Current registration availability is shown in the form.

2. Purposes

Data is used for Android beta waitlist management and invitations. Country or region of residence is used to determine beta availability, plan regional invitations and identify potentially applicable privacy requirements, not advertising or behavioral profiling. Device/model information supports test planning; early-feedback contact is limited to people who opt in. Beta invitations fulfilling the waitlist request are separate from optional recurring development news or marketing emails, which require separate optional consent. Site delivery, security and spam processing are described separately in Flow A.

3. Data collected

Required: email, page language, country_or_region of residence, age 18+ self-confirmation, personal-data and overseas-transfer consents, and application/consent records. Optional: Android device/model, early-feedback participation and updates. Four UTM values and the referrer domain are recorded when available. Applicants select their residence from a controlled list; it is not inferred from IP. No nationality, city, exact address, precise location, birth date, name, phone number, free-text message, search/browsing history or analytics identifier is requested. Technical spam signals are separate from the application Sheet fields below.

• Date
• email
• preferred_language
• android_device_model
• feedback_opt_in
• privacy_consent
• updates_opt_in
• utm_source
• utm_medium
• utm_campaign
• utm_content
• referrer
• landing_language
• consent_timestamp
• consent_version
• age_18_confirmed
• country_or_region
• overseas_transfer_consent
• overseas_transfer_notice_version

4. Required and optional choices

[Required] I agree to the collection and use of my personal data. Email, page language, country or region of residence, age confirmation, consent/application records and attribution support waitlist management, beta availability, regional invitations and review of potentially applicable privacy requirements. Device/model and early feedback are optional. Retention is up to 12 months or the earliest of withdrawal, waitlist closure and purpose completion. Refusing required privacy or overseas-transfer consent prevents registration but does not prevent browsing. All checkboxes start unchecked; age 18+ confirmation, a country/region selection and required consents are needed. Declining optional updates or feedback contact does not prevent registration.

5. Processing and retention

The operator deletes at the earliest of 12 months after collection, withdrawal, closure of the waitlist or completion of the purpose. Provider receipt time Date is the primary operational record; consent_timestamp is supplementary and based on the browser clock. This is the operator policy, not a claim that every provider log or backup has the same retention period.

6. Deletion procedure

A manual retention review occurs monthly and when withdrawal, closure or purpose completion triggers deletion. Both English and Korean Sheets and operator-controlled copies are checked. All matching complete rows, including duplicates, are deleted using trimmed, case-insensitive email comparison. Dots and plus aliases are not removed to merge distinct addresses. Records are excluded from sending lists and operational deletion is verified by searching again. Clearing cells or changing a status alone does not complete the procedure. We do not guarantee immediate individual erasure from inaccessible provider backups, security/audit logs or legally retained copies. Automatic deletion is not implemented.

7. Processing entrustment

The table describes entrusted processing separately from overseas-transfer disclosure. Their final legal relationship is PENDING OFFICIAL INTERPRETATION. On 2026-09-11, the Admin console confirmed a paid Google Workspace Business Starter account and a CDPA acceptance record. A paid subscription and acceptance of terms do not establish legal compliance for this waitlist.

Framer DPA · Google CDPA

8. Overseas transfers

Flow A is Framer hosting/security processing that may begin on page access or form interaction. Flow B begins with submission and sends application data through Framer Native Form to Google Workspace Sheets. Separate required overseas-transfer consent is drafted for Flow B. The basis for pre-submission processing is PENDING OFFICIAL INTERPRETATION; a form checkbox does not retroactively authorize processing that already occurred on page access. See the separate transfer notice and dated appendix for data, countries, recipients, timing, method, purposes, retention and refusal effects.

Use the View Overseas Transfer Notice link at the top of this page to read the recipient and country appendix.

9. Your rights and requests

Use the signup email address to contact privacy@avelunebrowser.com for access, correction, withdrawal, deletion or stopping optional updates. The operator checks relevant records and the relationship to the signup address as necessary. Consent evidence is not proof of identity; unnecessary identity documents or address records are not requested. Withdrawing optional updates does not disadvantage waitlist registration. Withdrawing required processing or transfer consent prevents continued registration under the current system and triggers deletion. You may still browse the site and follow the public build. Depending on where you live, additional mandatory privacy rights may apply. Providing Korean and English notices does not claim compliance with every country or that only Korean law can ever apply.

10. Initial beta age policy: 18+

The initial beta waitlist uses an owner-defined participation policy of age 18 or older. This does not claim that every applicable law requires age 18. Applicants self-confirm; this is not identity or age verification. No birth date is collected, and registrations from people under 18 are not intentionally accepted.

11. Security measures

Operational Sheets are private files owned by the operator Workspace account, which has a registered passkey. Access is limited as needed; sharing and deletion candidates are checked in monthly reviews. Transmission uses encrypted network connections. Native Framer spam settings are retained. In owner-only published QA on 2026-09-11, one spam test input passed the native filter. An additional browser input check was applied and the same test input was confirmed to produce no form submission. This limited test does not guarantee blocking all spam or preventing false positives. We do not guarantee perfect security or that a breach is impossible.

12. Cookies, analytics and attribution

No Google Analytics, Meta Pixel, advertising tracker or behavioral advertising has been added. UTM values and the referrer domain are used only for first-party campaign attribution. HTML/control characters are removed from UTM values, each limited to 128 characters; referrer stores only the hostname. The authored metadata component uses no cookies or persistent storage. Framer delivery, built-in statistics and security processing are separate. In owner-only published QA on 2026-09-11, no cookies or sessionStorage entries were observed, but one Framer editor-bar localStorage key and requests for Framer built-in statistics, error monitoring and content delivery were observed. These findings are limited to the tested browser and conditions and do not guarantee storage-free behavior for every visit. In a separate logged-out Chromium inspection, no cookies, localStorage or sessionStorage entries were observed; Framer built-in events and content/editor-bar requests remained present.

13. Privacy contact

Responsible person: 염승민. Privacy questions and rights requests: privacy@avelunebrowser.com. Questions were submitted to the Korean authority on 2026-09-11; no response has been confirmed. The submitted scope of ages 14 and over and Korea residents differs from the current age-18 minimum and acceptance of registrations from outside Korea. A future response is not assumed to resolve the entire current structure. No professional legal review or regulatory approval is claimed.

14. Changes and versions

Notice date: 2026-09-11; operating notice version: 2026-09-11-v8; transfer notice version: 2026-09-11-ot-v3. This notice applies to registrations on this page from 2026-09-11. Current registration availability is shown in the form. A material change to data, countries, recipients, purpose, retention or refusal effects requires a new transfer version, updated pages and change date before new collection, and preservation of earlier versions. Whether existing applicants need fresh consent is PENDING OFFICIAL INTERPRETATION; previous consent is not assumed to cover the change.