Operator / 운영자: Eifer company Contact / 연락처: [email protected] Applies to / 적용 버전: Context Recap v0.1.0 (Chrome Extension)

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1. Identity of the Controller (GDPR Article 13(1)(a))

Field Value
Controller Eifer company
Contact [email protected]
Data Protection Officer (DPO) Not appointed (single-operator beta — Article 37 GDPR threshold not met)
EU Representative Not appointed (Article 27 GDPR — operator does not target EU/EEA market specifically; the extension is globally available via Chrome Web Store but does not actively target EU residents)

EU/EEA users may direct inquiries to [email protected]. Response within 1 month per GDPR Article 12(3); the period may be extended by up to 2 further months for complex or numerous requests, with notification of the extension and reasons within the initial 1-month period.

2. Purposes and Legal Basis of Processing (GDPR Article 13(1)(c))

Context Recap processes personal data for the following purposes:

  1. Automatic capture, summarization, and search of user LLM conversations — to inject relevant prior context when the user starts a new conversation, improving the personalization quality of LLM responses.
  2. Building a multi-LLM cross-platform user model (writing style, patterns, preferences) for personalization.
  3. External enrich processing (summary, tagging, reaction analysis) via Tier 1 cloud LLM (see §4).
  4. User quota enforcement based on Firebase Anonymous Auth UID to prevent abuse and operator cost spikes.

Legal basis (GDPR Article 6): Consent (Article 6(1)(a)) — obtained once via an explicit consent screen at first installation. The consent covers all processing described in this Policy.

The user may withdraw consent at any time by disabling capture on the Options page or by removing the extension (§6).

Explicit-consent flow: On first install, this extension opens a dedicated onboarding page that requires the user to explicitly consent. Before consent is given, no capture or external transmission occurs (Settings.captureEnabled defaults to false); content scripts do not start the MutationObserver. After consent, the user can disable capture immediately at any time via the Options page toggle (existing memories are preserved; only future capture is stopped). Aligned with GDPR Article 6(1)(a) and the Personal Information Protection Act of Korea §15.

3. Categories of Personal Data Processed (GDPR Article 14(1)(d))

3.1 Data automatically collected