IPPO Privacy Policy

This English text is a translation provided for reference only. The Japanese text is the authoritative version and prevails in the event of any discrepancy.

GLOBAL ASTRA, Inc. ("we", "us" or the "Company") sets out this Privacy Policy (this "Policy") regarding the handling of user information in the Japanese-language learning service "IPPO" (the "Service").

We comply with the Act on the Protection of Personal Information of Japan (the "APPI"), the Telecommunications Business Act and other applicable laws and guidelines.

Article 1 (Information about the Company)

Article 2 (Scope and Definitions)

1This Policy applies to the handling of User Information of individuals who use the Service ("Users").

2"User Information" means information identifying a User, records of activity on the Service, and other information generated or accumulated in relation to a User or a User's device that we collect under this Policy.

3"Personal Information", "Personal Data", "Retained Personal Data", "Special Care-Required Personal Information" and "Personal Related Information" have the meanings given in the APPI.

4Where a User accesses the Service through an ID issued under "IPPO for Enterprise" or "IPPO for Japanese Language Schools" contracted by a company, school or other organisation, the privacy policy for that corporate service and our agreement with that organisation prevail.

Article 3 (Information We Collect)

We collect User Information by lawful and proper means. We never acquire User Information by deception or other wrongful means.

(1) Information provided by the User

• Account information: name or nickname, display name, e-mail address, password (we store only an encrypted value).
• Profile information: nationality, country and place of residence, native language, learning goals, Japanese level, year of birth (optional), profile image (optional).
• Content submitted through enquiry forms, e-mail or other methods designated by us.

(2) Information generated through use of the Service

• Learning data: learning history, answers, results, scores, study time, progress, level assessments, and examination results and pass rates.
• Billing data: subscription plan, billing dates, payment status and transaction history.

(3) Device and network information

• IP address, referrer and server access logs.
• Cookies and other identifiers.
• Device type, OS and version, browser type and version, language settings.
• Browser push notification endpoints (only where the User has enabled notifications).

(4) Information obtained through linked external services

If a User permits the Service to link with an external service (such as a social login), we collect the User's ID, name, e-mail address and profile image from that service within the scope agreed at the time of the linkage.

(5) Payment information

Payments for paid plans are processed by Stripe Japan, Inc. as our payment service provider. Credit card numbers and other card details are handled by Stripe and are neither collected nor retained by us. We receive only transaction information such as the result, date, amount and payment method.

(6) Information we do not collect

We do not collect location information derived from device GPS or similar sources. Country and place of residence are collected only as answers entered by the User in response to questions within the Service. Except where permitted by the APPI, we do not acquire Special Care-Required Personal Information (such as race, creed, social status, medical history or criminal record) without the prior consent of the data subject, and we do not intend to collect such information through the Service. Users should not enter such information into any input field.

Article 4 (Purposes of Use)

We use User Information for the following purposes:

(1)to provide, maintain, protect and improve the Service, including registration, identity verification, authentication and recording of settings;

(2)to record learning activity, manage progress and attainment, assess levels and display results;

(2-2)to display display names and pass rates in the ranking feature, as set out in Article 7.6;

(3)to provide AI Features, namely optimisation of question selection, adjustment of review intervals using the Leitner method and automatic scoring, as set out in Article 5;

(4)to invoice and process payment of fees;

(5)to analyse use of the Service and to improve and develop features;

(6)to detect, investigate and respond to misuse, unauthorised access and breaches of our terms;

(7)to respond to enquiries and provide support;

(8)to notify Users of changes to our terms and policies and other important matters;

(9)to deliver and display advertisements and measure their effectiveness;

(10)to send newsletters and information about new features and campaigns, where the User has consented and subject to the right to unsubscribe at any time;

(11)to create and use statistical information processed so that individuals cannot be identified; and

(12)to comply with legal obligations and to respond to lawful requests from public authorities.

We do not use User Information beyond these purposes. We may change the purposes of use only within a scope reasonably considered to be relevant to the purposes before the change, and will post the changed purposes on the Service or notify Users.

Article 5 (AI Features)

1"AI Features" in the Service means features that optimise the selection of questions, adjust review intervals using the Leitner method and score answers automatically, by means of algorithms. This processing takes place within our own systems.

2We do not transmit User input to generative AI or to any other external artificial intelligence service.

3We do not use User Information as training data for machine learning models. If we do so under Article 18.3 of the Terms of Use, we will first convert the information into pseudonymously processed information, anonymously processed information or statistical information in accordance with the standards prescribed by law.

4If we introduce such features in the future, we will amend this Policy in advance to identify the recipients, their countries of location, the information transmitted and the purposes of use, and will complete any procedures required by law.

5Output of AI Features may contain errors and does not guarantee or advise on the result of any examination, on residence status, or on any other legal matter.

Article 6 (Cookies and External Transmission)

1The Service uses cookies and similar technologies to maintain login sessions, remember settings, analyse usage and measure advertising effectiveness.

2By duration, cookies are either session cookies, deleted when the browser is closed, or persistent cookies, retained on the device for a defined period. By origin, they are either first-party cookies issued by our domain or third-party cookies issued by another domain.

3Users may disable cookies, or delete cookies already stored, through their browser settings. Some features of the Service may not function correctly as a result.

4In accordance with Article 27-12 of the Telecommunications Business Act, we disclose in Appendix 2 the information transmitted from a User's device to external parties, the recipients and the purposes of use.

Article 7 (Provision to Third Parties)

1We do not provide Personal Data to third parties without the User's prior consent, except where: (i) required by law; (ii) necessary to protect the life, body or property of a person and consent is difficult to obtain; (iii) particularly necessary for public health or the sound growth of children and consent is difficult to obtain; or (iv) necessary to cooperate with a national or local government body performing statutory duties, where obtaining consent would impede those duties.

2Recipients in the following cases are not third parties for the purposes of the preceding paragraph: (i) contractors entrusted with all or part of the handling of Personal Data within the scope necessary to achieve the purposes of use (including cloud service providers, payment service providers and e-mail delivery providers); and (ii) successors in a merger, company split, business transfer or similar transaction.

3We supervise contractors referred to in the preceding paragraph as necessary and appropriate.

4Where we provide Personal Related Information such as cookies to a third party and it is anticipated that the third party will acquire it as Personal Data, we confirm in advance that the User's consent has been obtained.

5We do not currently engage in joint use of Personal Data.

6In the ranking feature of the Service, a User's display name and pass rate are shown to other Users. Profile information other than the display name, learning history and answers are shown only to the User and to the administrator of the organisation that registered them.

7Statistical information processed so that individuals cannot be identified does not constitute personal information, and we may provide or publish it.

Article 8 (Transfers to Third Parties Overseas)

1We do not currently provide Personal Data to third parties located outside Japan. All contractors to which we entrust the handling of Personal Data are located in Japan.

2Those contractors may use overseas affiliates or process information on overseas systems in the course of their work. The countries concerned and the measures we have verified are set out in Appendix 1.

3If we come to provide Personal Data to a third party located outside Japan, we will first amend this Policy, in accordance with Article 28 of the APPI, to identify the recipient country, the personal data protection regime of that country and the measures taken by the recipient.

Article 9 (Security Measures)

• Basic policy: we have established and published this Policy to ensure the proper handling of Personal Data.
• Organisational: we have appointed a data protection manager, review handling practices, and maintain a reporting line for incidents.
• Human: we train our personnel on the handling of Personal Data and impose confidentiality obligations on them.
• Physical: we take measures to prevent theft or loss of equipment and media used to handle Personal Data.
• Technical: we restrict access rights, encrypt data in transit and at rest, and deploy measures against unauthorised access.
• External environment: we store Personal Data on servers located in Japan. Part of the payment-related information may be processed overseas by affiliates of our payment service provider, and we assess the personal data protection regimes of the countries concerned, as listed in Appendix 1.

Article 10 (Retention and Deletion)

We endeavour to keep Personal Data accurate and up to date within the scope necessary to achieve the purposes of use.

We retain User Information collected in connection with the Service for 90 days from the date of withdrawal and delete it thereafter, except where retention is required by law, in which case we retain it for the period prescribed by that law.

Article 11 (Data Breach Response)

If an incident occurs that falls within Article 26 of the APPI and Article 7 of its Enforcement Rules, we will report it to the Personal Information Protection Commission and notify the affected individuals. Where notification is difficult, we will take alternative measures necessary to protect their rights and interests.

Article 12 (User Rights)

1Users may request notification of the purposes of use, disclosure, correction, addition or deletion of content, suspension of use or erasure, and suspension of provision to third parties, in respect of their Retained Personal Data.

2Disclosure will be made by electromagnetic record or by another method where the User so specifies.

3Requests should be sent to the contact in Article 14. After verifying the identity of the requester, we will respond in principle within two weeks of receipt.

4A fee of JPY 1,000 per request applies to requests for notification of the purpose of use and for disclosure. No fee applies to requests for correction, addition, deletion, suspension of use, erasure or suspension of provision to third parties.

5Where we are not obliged to disclose, correct or suspend use under the APPI or other laws, we will notify the User to that effect together with the reasons.

Article 13 (Minors)

Users under 18 years of age must obtain the consent of a parent or other legal representative before providing User Information. If we learn that we have collected User Information from a person under 18 without such consent, we will delete it without delay.

Article 14 (Contact)

GLOBAL ASTRA, Inc. — Personal Information Enquiry Desk

N&E BLD. 7F, 1-12-4 Ginza, Chuo-ku, Tokyo 104-0061, Japan / info@global-astra.com

Weekdays 9:00-18:00 JST (excluding weekends, public holidays and the year-end period).

Article 15 (Users Outside Japan)

1We are located in Japan and the Service is provided under Japanese law. The Service is intended for use within Japan, and User Information is processed in Japan.

2Users accessing the Service from outside Japan are responsible for complying with the laws of their place of residence.

Article 16 (Amendments)

1We may amend this Policy in response to changes in law or in the Service.

2We will publish the effective date and content of any amendment on the Service or our website a reasonable period before it takes effect.

3Where an amendment legally requires User consent, the amended Policy applies only to Users who have consented in the manner we specify.

Article 17 (Governing Law and Authoritative Text)

1This Policy is governed by the laws of Japan.

2The Japanese text of this Policy is the authoritative version. Translations are provided for convenience only and the Japanese text prevails in the event of any discrepancy.

GLOBAL ASTRA, Inc.

info@global-astra.com