Privacy Policy

1. About this Policy

This Privacy Policy explains how Shotoka株式会社 (Shotoka K.K.) (“Shotoka,” “we,” “us,” or “our”) collects, uses, retains, discloses, and protects personal information when you join the Kikigo waitlist or use Kikigo’s websites, applications, language-learning exercises, and related services (the “Service”). It forms part of our Terms and Conditions.

2. Controller and contact details

The entity responsible for personal information covered by this Policy is Shotoka株式会社, represented by Chrons Otto, at Fukuoka PARCO Shinkan 5F, 2-11-1 Tenjin, Chuo-ku, Fukuoka-shi, Fukuoka 810-0001, Japan.

Privacy, support, and complaints: [email protected]
Phone: 080-1693-5945 (weekdays 10:00–18:00 JST)

3. Information we collect

3.1 Information you provide

• Waitlist information: email address, consent status, consent time and method, form source, withdrawal status, and the IP address and request data needed to secure and evidence the submission.
• Account information: email address, name or display name, authentication information, locale, and account settings.
• Learning profile: target language, proficiency, goals, interests, preferences, selected catalogs or layers, and study settings.
• Practice data: assigned exercises, answers, attempts, progress, hints, scores, mastery estimates, and session history.
• Voice data: recordings you choose to make, transcripts, timing, pronunciation measurements, and speech-assessment results.
• User Material: text, photographs, documents, audio, video, and related permissions or context you submit to create private learning material.
• Communications: support requests, exercise reports, feedback, survey responses, and other messages.
• Subscription information: plan, billing interval, transaction status, and limited billing records. Payment processors handle complete card details; we do not store complete card numbers.

3.2 Information collected automatically

• IP address, browser, operating system, device type, language, and approximate region;
• access times, pages and features used, request and error logs, diagnostics, and security events; and
• essential cookies or local storage used for authentication, security, language, theme, and service preferences.

4. How we use information

We use personal information to:

• create and secure accounts and provide the Service;
• personalize practice, evaluate answers and speech, track progress, and generate private exercises;
• process subscriptions, confirm payments, and prevent billing fraud;
• administer the pre-launch waitlist and send the launch announcement you requested;
• respond to support requests and communicate important service or policy changes;
• diagnose failures, review exercise and speech-assessment quality, and improve reliability;
• detect abuse, protect users and systems, enforce our Terms, and comply with law; and
• produce statistical information consisting of aggregated data from which no individual can be identified.

We do not use private voice recordings or User Material to train shared AI models, add content to shared catalogs, or create exercises for other users without explicit consent.

5. Voice recordings and quality review

When you activate a speaking exercise, Kikigo records audio only after you grant microphone permission and initiate recording. We process the recording to provide features such as transcription, pronunciation or timing assessment, answer evaluation, and feedback.

The Service may extract a transcript, speech timing, pitch, rhythm, articulation, pronunciation, confidence, and related assessment features. These features are used to assess language practice. They are not used to identify you, authenticate you, create a voiceprint for identification, match you across accounts, or enable a third party to identify you.

Raw voice recordings may be retained for quality review for up to 60 days after collection and are then deleted, unless a shorter period applies or longer retention is required to investigate abuse, resolve a support request you initiated, preserve evidence, or comply with law. Derived records such as transcripts, scores, progress, and quality measurements may remain with your learning history until deleted under Section 8.

Access to retained recordings is limited to specifically authorized personnel and providers with a documented operational, security, support, or quality-review need. Access is logged and reviewed. Quality review uses limited samples to investigate scoring failures, transcription errors, and reported exercise defects.

Do not submit medical records, immigration records, another person’s messages, or other sensitive or third-party information unless the upload flow expressly supports it, you have authority and any legally required consent, and the processing notice shown at upload is acceptable to you. Where prior consent is legally required for sensitive information, we will not intentionally accept it without a separate consent step.

6. Service providers and disclosure

We use a limited set of service providers to support hosting and storage, authentication and transactional email, payment processing, customer support, and AI, transcription, or audio processing. They receive only the information reasonably necessary to perform their services and are subject to contractual or other appropriate safeguards.

Providers used now or approved for planned features, together with their functions, data categories, processing locations, safeguards, and whether use has begun, are listed on the Service Providers page. We update that page before a newly selected provider begins processing personal data.

We will not send private voice recordings or User Material to a model provider unless the applicable terms prohibit the provider from using those submissions to train models for itself or other customers, except where you separately give informed consent to a different use.

We may also disclose information:

• when you direct us to or consent to the disclosure;
• to comply with law, legal process, or a valid government request;
• to investigate fraud, security incidents, Terms violations, or threats to rights and safety; or
• in connection with a merger, financing, acquisition, reorganization, or sale of assets, subject to appropriate notice and protection.

We do not sell personal information or share it for cross-context behavioral advertising.

7. International processing

Information is controlled in Japan and may be processed through providers in the United States, Germany, other parts of the European Economic Area, and locations on Cloudflare’s global network, as detailed on the Service Providers page. For a foreign recipient that maintains a standards-conforming system, we use contractual and organizational arrangements intended to ensure continuous implementation of measures equivalent to those required under Japan’s Act on the Protection of Personal Information, periodically review those measures and the relevant foreign legal environment, and suspend a transfer if equivalent protection can no longer be ensured. Where that route is unavailable and prior consent is required, we provide the country, its privacy system, and the recipient’s safeguards before asking for consent. Further information is available on request.

8. Retention and deletion

• Waitlist: until the requested launch announcement is sent or you withdraw, followed only by the limited period needed to complete deletion and retain legally required consent or suppression records.
• Raw voice recordings: up to 60 days, subject to the limited exceptions in Section 5.
• Account and learning records: while your account is active and for a limited period afterward to complete deletion, restore an account where offered, resolve disputes, and meet legal obligations.
• Submitted learning material: while needed to provide your private learning features, until you delete it or your account, subject to technical backup and legal-retention periods.
• Billing, security, and legal records: for the periods required by tax, accounting, fraud-prevention, dispute, and other applicable laws.

When information is no longer required, we delete it or convert it into statistical information from which no individual can be identified. Deleted information is removed from routine backups within 30 days, unless preservation is legally required; backup copies are isolated and not restored to active use except for disaster recovery.

9. Your choices and rights

Depending on applicable law, you may request notice of purpose, access or disclosure, correction, suspension of use, deletion, or suspension of third-party provision of personal data. You may also withdraw consent where processing relies on consent. Some requests may be limited by identity verification, another person’s rights, security, or a legal obligation to retain information.

Send a request identifying the right you wish to exercise and the relevant account or email address to [email protected]. We first acknowledge the request, then verify identity through the signed-in account where possible. If that is not possible, we may request limited matching account information or a suitably redacted identity document. An authorized representative must provide evidence of authority. We respond without undue delay, ordinarily within 30 days, or explain the reason and expected timing if more time is reasonably required. We explain any lawful refusal or limitation. No fee is charged for these requests unless applicable law permits a reasonable fee for a manifestly unfounded or excessive request and we notify you in advance.

You can control microphone access in your browser or device settings and can use non-recording features where the Service makes them available. To withdraw from the waitlist, email the same address; we will stop launch messages and retain only any legally required consent or suppression record.

10. Security

We use administrative, technical, and physical safeguards appropriate to the nature of the information, including access controls, encryption in transit, service isolation, logging, backups, and review of privileged access. We maintain data-handling rules, restrict production access by role, review privileged access, separate service environments, use allowlisted error reporting that excludes prompts, model output, raw voice and complete user payloads, and assess the external environment of providers handling data in the United States, Germany, the European Economic Area, Japan, and other locations described on the Service Providers page. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

If a leak, loss, or damage event is reportable under applicable law, we will report it to Japan’s Personal Information Protection Commission and notify affected people promptly, without undue delay, unless a lawful substitute measure applies. We also investigate, contain, remediate, and document security incidents.

11. Cookies and local storage

Kikigo uses technologies necessary to keep you signed in, protect sessions, route language preferences, remember display settings, and operate requested features. We may use limited first-party measurement to understand reliability and feature usage. We will update this Policy and provide any required choice before introducing materially different advertising or tracking technologies.

12. Adults only

Kikigo is intended only for people who are 18 or older. We do not knowingly collect personal information from minors. If you believe a minor has provided information, contact [email protected] so we can investigate and delete it as appropriate.

13. Optional proactive messages

If proactive practice reminders or memory-refresh messages become available, they are off unless you expressly opt in. Audio messages require a separate opt-in. Account controls will let you choose channels, frequency and quiet hours and turn text or audio messages off at any time. A promotional message is sent only with the consent, sender identification, refusal method, address, and complaint contact required by applicable law. Service and security notices that are necessary to operate an account are managed separately.

14. Changes to this Policy

We may update this Policy as Kikigo, our providers, or legal requirements change. To the extent this Policy forms part of the agreement concerning the Service, the process in Section 13 of the Terms applies. Before a change takes effect, we will publish the fact of the change, the amended Policy, and a specified future effective date on our website or by another appropriate method. If a change requires consent, we will obtain it before applying the change. We retain dated copies of prior published versions.

15. Contact and complaints

Questions, requests, or complaints concerning this Policy may be sent to [email protected] or mailed to Shotoka株式会社, Fukuoka PARCO Shinkan 5F, 2-11-1 Tenjin, Chuo-ku, Fukuoka-shi, Fukuoka 810-0001, Japan.

We are not a member of an authorized personal information protection organization. You may also contact Japan’s Personal Information Protection Commission about the applicable complaint channel. The Commission does not act as our representative or decide private disputes.