Privacy Policy - Kotodama

 

Kotodama Inc. (the “Company”, “we” or “our”) hereby declares to promote the protection of Personal Information, in regard to the handling of Personal Information of Users (the “Users”) of the Company’s service “Kotodama” (the “Services”), through setting out the privacy policy as defined below (this “Policy”), establishing a system for protecting Personal Information, and ensuring that all employees observe and understand the importance of protecting Personal Information together with rigorous implementation of these measures. 

 

  1.               (Personal Information)
    1.           “Personal Information” in this Policy means “Personal Information” as defined in the Act on the Protection of Personal Information of Japan (Act No. 57 of 2003; “Personal Information Protection Act”); and therefore, means information which can identify a specific living individual by name, date of birth or other description contained in such information; or which includes a code that can identify a specific individual.　
    2.           Kotodama AI may access the user's external storage to facilitate the uploading of audio and video files. Additionally, we may collect and process images.

 

  1.                (Purpose of Use of Personal Information)

We may acquire and use Personal Information of Users of our Services within the scope necessary for the following purposes. If we seek to use such Personal Information beyond the following purposes, we will obtain the prior written consent of the Users whose Personal Information is concerned:

  1.      to perform the Services;
  2.     to provide and maintain our Services;
  3.     to notify Users about changes to our Services;
  4.     to allow Users to participate in interactive features of our Services when Users choose to do so;
  5.     to provide customer support;
  6.       to gather analysis or valuable information so that we can improve our Services;
  7.     to monitor the usage of our Services;
  8.     to detect, prevent and address technical issues;
  9.       to fulfill any other purpose for which Users provide it;
  10.       to carry out our obligations and enforce our rights arising from any contracts entered into between Users and us, including for billing and collection;
  11.     to provide Users with notices about Users’ account and/or subscription, including expiration and renewal notices, email-instructions, etc.;
  12.       to provide Users with news, special offers and general information about other goods, services and events which we offer that are similar to those that Users have already purchased or enquired about unless Users have opted not to receive such information; and
  13.     to identify Users who have violated the Terms of Use or who intend to use the Services for unlawful or illegitimate purposes, and to block their use of the Services.

 

  1.                (Management and Protection of Personal Information)

We will carefully and closely manage Personal Information and will not disclose or provide such Personal Information to any third parties without the prior written consent of Users whose Personal Information is concerned, except in the following circumstances and shall take precautional and correctional measures to an illegal access to Personal Information, risks of loss, destruction or leakage of Personal Information considering a security perspective:

  1.         if such disclosure of Personal Information is necessary for the protection of the life, body, or property of a person and it is difficult to obtain the consent of such person;
  2.        if such disclosure of Personal Information is necessary for improving public health or promoting the sound growth of children and it is difficult to obtain the consent of the person whose Personal Information is concerned;
  3.         if such disclosure of Personal Information is necessary for cooperating with a state organ, a local government, or an individual or a business operator entrusted by such state organ or local government in executing the affairs required by laws and regulations, and if obtaining the consent of the person whose Personal Information is concerned is likely to hinder the execution of such affairs; and
  4.        if it is permitted by laws and regulations. 

 

We will take preventive and corrective measures against risks resulting from any unlawful access to Personal Information, or any loss, destruction, falsification, or leakage of Personal Information.

 

  1.                (Entrustment of Personal Information Handling)

We may entrust an individual or a business operator to handle Personal Information in whole or in part. In such case, we will examine their eligibility sufficiently, obligate such individual or business operator to maintain confidentiality obligations by contract, and will perform the necessary and appropriate supervision over such individual or business operator.

 

  1.                (Disclosure of Personal Information)

Users may request the Company to disclose Personal Information held by Us in accordance with the procedures set forth in Article 8. Upon receiving such a request from the Users, We will disclose the information to the Users without delay; provided, however, if the following would be applicable, We may decide not to disclose whole or part of the information, in which case we will send a notification to that effect without delay.

  1.         if such disclosure is likely to harm the life, body, property, or other rights or interests of such User or any other third parties;
  2.        if such disclosure is likely to hinder the proper execution of our business; and
  3.         if such disclosure may result to violation of any laws and regulations.

 

  1.                (Correction of Retained Personal Data)
  1. If Personal Information of Users held by Us is false, the Users may request that We make the correction of, the addition to, or the deletion of such Personal Information (“Correction”) in accordance with procedure prescribed in Article 8.
  2. If We receive the request as stipulated in the immediately preceding paragraph, We will conduct necessary research without delay, and if the result of such research finds any ground, Correction will be made to such Personal Information without delay.
  3. If We makes any judgment as to whether to implement the Correction in accordance with the immediately preceding paragraph, We will notify the Users of such judgment without delay.

 

  1.                (Discontinuation of Personal Information Use)
  1. Any Users may request that We cease to make the utilization of, make the erasure of, or cease the third-party provision of, personal data retained by Us (“Cessation”), in accordance with procedures set out in Article 8.
  2. Upon request as stipulated in the immediately preceding paragraph, We will conduct necessary research without delay. If We consider as a result of such research that such request is well-grounded, we will implement Cessation of such personal data without delay; provided, however, that if such Cessation is unduly expensive or is otherwise difficult to implement and alternative measures to protect the rights and interests of the Users are available, then We will take such measures instead.
  3. If We reach any conclusion as to whether to implement Cessation in accordance with the immediately preceding paragraph, We will notify the Users of such conclusion without delay.

 

  1.                (Procedures for Disclosure of Personal Information)

When making a request as stipulated in Articles 5 through 7, the Users shall fill out the request form separately designated, and send it together with the identification documents stipulated below. Please note that a handling fee of 2,000 yen will be charged for each request for disclosure of Personal Information.

 

 Identification documents

【In the case of a request from the Users】

A copy of the User’s driver’s license, passport, or health insurance card (whichever is applicable).

 

【In the case of a request by an agent】

(i) A copy of the User’s driver’s license, passport, or health insurance card (whichever is applicable).

(ii) A copy of the representative’s driver’s license, passport, or health insurance card (one of the above).

(iii) A letter of attorney indicating that the proxy is the User’s representative.

 

  1.                (Procedures for Amending Privacy Policy)

We will review the content of this Policy appropriately and endeavor to improve this Policy. The content of this Policy can be amended unless otherwise stipulated in laws, regulations, and this Policy. The amended Policy will be valid when notified to all Users or uploaded on our website in accordance with our procedures.   

 

  1.           (Compliance with Laws, Regulations and Norms)

We will comply with the laws and regulations in Japan and other rules that are applicable to the use of Personal Information we retain.

 

  1.           (Response to Complaints and Consultations)

We will respond to any complaints from Users and will provide consultation to any User whose Personal Information is concerned as to the handling of his or her Personal Information. We will respond properly and promptly to any request for disclosure, correction, addition, deletion, refusal of use or provision regarding Personal Information.

 

  1.           (Security Measures)

As to Personal Information provided by Users to the Company shall be protected from illegal access, lost, destruction, falsification, leakage and other issues through organizational, physical, personal and technical measures such as restricting access to Personal Information files, recording access logs, and taking security measures to prevent illegal access from outside. If, by chance, any leakage and other incidents are occurred, we will make report to relevant authorities in accordance with the Personal Information Protection Act and relevant guidelines, and as per instructions to be given by the authorities, will take required measures to avoid an occurrence of similar incidents or the same type of incidents. Please refer to the “Security Measures for Personal Information” attached for details.

 

 

  1.           (Customer Desk)

E-mail: support@kotodama.app

 

Established on and valid from February 13, 2024.