TO Apps

Privacy Policy

Japanese version prevails

This document is provided in Japanese and English. In case of any discrepancy between the Japanese and English versions, the Japanese version shall prevail.

Article 1 Personal Information Collected

The Service collects and uses the following personal information (including personal information as defined in Article 2, Paragraph 1 of the Act on the Protection of Personal Information, as well as personally linkable information as defined in Article 2, Paragraph 2 of the same Act).

1.1 AsyncStorage Persistent Items

The Service uses @react-native-async-storage/async-storage to store the following information on the device. This data is not sent to any server.

Storage key	Content	Purpose
hasSeenIntro	Onboarding completion flag	Controls first-launch tutorial display
consentState	Terms consent status	Manages agreement to Terms of Use and Privacy Policy
subscriptionStore	Subscription status, next renewal date, trial end date	Feature gating based on subscription status
settingsStore	Audio settings, theme settings, session settings	Cross-session restoration of user preferences
customDecksStore	Word lists and names of user-created decks	Persistence of Custom Word Sets feature

1.2 Purchase Information via RevenueCat

The Service uses the RevenueCat SDK to manage the following information on RevenueCat servers. This data is not stored on the Operator’s servers.

• Anonymous customer ID (auto-generated by RevenueCat)
• Purchase history, subscription status, and trial usage
• Billing provider identifier (Apple / Google)

1.3 Technical Information Collected by Expo SDK

The Service uses certain features of the Expo SDK to collect the following technical information.

• expo-device: Device model name, OS version, OS build ID
• expo-updates: OTA update request logs (update date/time, version)
• expo-constants: App version, build number, Bundle ID / Package name

1.4 Information Generated and Used In-App but Not Stored

The following information is used during sessions or temporarily, but is not persisted on the device or any server.

• Audio playback logs during sessions (held in memory only during playback, discarded when the session ends)
• Free-text cancellation reasons (discarded at the same time the cancellation CTA is pressed)

1.5 Information Not Collected (Explicit Statement)

The Service does not collect the following information.

• Location data (GPS, etc.)
• Microphone or camera (expo-audio is used for audio playback only; recording permissions are disabled)
• Contacts or photo library
• IDFA / Advertising identifiers (expo-tracking-transparency is not implemented; no advertising SDK is integrated)
• Biometric data or HealthKit data
• User names, email addresses, or other personally identifiable information (Apple ID / Google Play account information is not obtained on the Service side)

Article 2 Purpose of Use

Personal information collected will be used only within the scope of the following purposes. The information will not be used beyond these purposes.

1. Service provision and maintenance: Enabling and disabling features based on subscription status, subscription management, and free trial period management
2. Persistence of user settings: Cross-session restoration of audio settings, theme settings, session settings, Custom Word Sets, and other preferences
3. Customer support: Querying and verifying the RevenueCat customer ID for purchase restoration troubleshooting
4. App improvement: Verifying behavior by OS version and confirming OTA update distribution status (Crashlytics and similar crash analysis tools are not currently integrated; only basic EAS Update logs are available at this time)
5. Consent management: Re-consent control when the Terms of Use or Privacy Policy are revised

Article 3 Provision to Third Parties / Joint Use

1. Except where disclosure is required by law, Personal Data will not be provided to third parties without the individual User’s consent.
2. Statistical information processed in a form that does not identify individuals may be used and published for the purpose of app improvement.

Article 4 Service Providers

The Service entrusts part of its operations to the following entities and delegates the handling of Personal Data to them as necessary.

Service Provider	Delegated Operations	Location
RevenueCat, Inc.	Purchase information management, subscription processing	United States
Apple Inc.	iOS app distribution, billing processing	United States
Google LLC	Android app distribution, billing processing	United States
Expo, Inc.	OTA update distribution	United States / Various
GitHub, Inc.	Public URL hosting (GitHub Pages)	United States

Article 5 Cross-Border Transfer

1. Some of the service providers listed in the preceding article are located outside Japan, and Personal Data may be transferred outside Japan as a result.
2. Cross-border transfers are conducted under appropriate safeguards, such as Standard Contractual Clauses.
3. As this Service is operated by an individual developer, large-scale ISMS certification has not been obtained; however, communications are encrypted via HTTPS, and the service providers comply with their respective privacy policies and security standards.

Article 6 Security Safeguards

1. The following security safeguards are implemented to prevent leakage, loss, or damage of Personal Data.
   • Data is stored in AsyncStorage on the device; sensitive information (passwords, authentication tokens, payment information, etc.) is not stored
   • Payment-related information is managed by the App Store / Google Play / RevenueCat and is not retained on the app side
   • Communications use HTTPS (public URLs / RevenueCat API / Expo Updates)
2. This Service is operated by an individual developer and does not hold certification for a large-scale Information Security Management System (ISMS).

Article 7 Requests for Disclosure, Correction, or Cessation of Use

1. Users may request disclosure, correction, or cessation of use of retained Personal Data.
2. Requests should be sent to the contact email address listed in Article 13. For identity verification purposes, Users may be asked to provide information such as their RevenueCat customer ID.
3. Upon receiving a request, a response will be provided within 14 business days in principle.
4. Data stored in AsyncStorage can be deleted from the device by using “Settings” > “Delete all data” within the app, or by uninstalling the app.

Article 8 Cookies / Tracking

1. The Service is a native app and does not use cookies.
2. No advertising SDKs or tracking SDKs are integrated.
3. No analytics tools (such as Google Analytics / Firebase Analytics) are integrated.

Article 9 Users Under 16

1. Users under the age of 16 should use the Service with the consent of a parent or guardian.
2. The Service does not provide a UI for age verification (soft consent model). Use under parental supervision is expected.

Article 10 Breach Notification

1. In the event of leakage, loss, or damage of Personal Data, a report will be made to the Personal Information Protection Commission, and notification will be sent to Users who may be affected.
2. Notification methods include in-Service announcements, email, or other appropriate means.

Article 11 Revision

1. This Policy may be revised in response to changes in laws and regulations or changes in the Service.
2. Revisions will be published via in-Service notifications and at a public URL.
3. For material revisions (such as additions to the items collected or changes to the scope of third-party provision), legalManifest.json’s minRequiredRevision will be updated, and Users may be required to re-consent.

Article 12 Operator Information

Item	Content
Name (business name)	<Operator’s name / business name>
Address	<Operator’s business address>
Representative	The same individual as the name above

Article 13 Contact Information

For inquiries regarding this Policy, please contact the following.

• Email: <Operator’s contact email address>