KODAWARI SENSEI

Privacy Policy

Article 1 (Basic Policy)

KODAWARI Inc. (hereinafter referred to as the “Company”) recognizes the importance of users’ personal information, complies with the Act on the Protection of Personal Information and other applicable laws and regulations, takes appropriate security control measures, and handles personal information properly.

Article 2 (Information Collected)

The Company collects the following information.

User Registration Information

Name or nickname Email address Password (managed in encrypted form) Nationality and country of residence Profile information (optional)

Service Usage Information

Lesson history and reservation information Learning progress and evaluation data Content of communications with instructors Access logs (IP address, device information, browser information, etc.)

Communication, Audio, and Video Information

Audio and video data during lessons Connection status and communication quality data

The Company may record or audio-record lessons for the purpose of improving service quality and preventing trouble.

Payment-Related Information

Payment history and billing status

Credit card information is not acquired or retained by the Company and is managed by payment service providers such as Stripe.

Article 3 (Purpose of Use)

The Company uses the information it collects for the following purposes.

Provision and operation of the Service Implementation of lessons and improvement of lesson quality Provision of instruction by instructors User support Prevention of unauthorized use and fraudulent payments Service improvement and data analysis Notification of important announcements Compliance with laws and regulations and handling of disputes

Article 4 (Provision to Third Parties)

The Company will not provide personal information to third parties except in the following cases.

When the user has given consent When required by law When information is provided to contractors within the scope necessary for the provision of the Service

Article 5 (Contractors)

The Company may outsource the following operations to external service providers.

Payment processing (Stripe, etc.) Provision of cloud infrastructure Data analysis and access analytics (Google Analytics, etc.) Customer support assistance

The Company will exercise appropriate supervision over such contractors.

Article 6 (International Transfer and Provision to Instructors)

The Company may provide user information to instructors or service providers located outside Japan for the purpose of providing the Service, including instruction by instructors.

By using the Service, the user agrees that such information may be transferred to countries other than the user’s country of residence.

Article 7 (Security Control Measures)

The Company will take reasonable security control measures to prevent leakage, loss, or damage of personal information.

Article 8 (Handling of Lesson Video and Audio Recordings)

The Company may record video or audio of lessons for the purpose of improving service quality, including instructor training, and preventing trouble. By using the Service, the user is deemed to have consented to such video or audio recording. However, the Company may obtain individual consent when necessary. Recorded data will be used only for the purposes set forth in the preceding paragraph and will not be disclosed to third parties, except as required by law. Recorded data will be appropriately deleted after the expiration of [Retention Period: e.g., 6 months].

Article 9 (Use of Cookies, etc.)

The Company uses cookies and similar technologies to improve the Service and enhance user convenience.

The Company may also use analytics tools such as Google Analytics. The information collected through such tools does not directly identify any individual.

Article 10 (Retention Period)

The Company will retain personal information for the period necessary to achieve the purposes of use and will thereafter delete it appropriately.

However, this does not apply where retention is required by law.

Article 11 (Disclosure, Correction, and Deletion)

Users may request disclosure, correction, or deletion of their own personal information.

However, the Company may not be able to comply with such requests in the following cases.

When retention is required by law When necessary for the operation of the Service When necessary from the perspective of preventing unauthorized use

Article 12 (Use by Minors)

If a minor uses the Service, the minor must obtain the consent of a parent or legal guardian.

Article 13 (Disclaimer)

The Company assumes no responsibility for leakage or other incidents involving personal information in the following cases.

Cases caused by the user’s own negligence Unauthorized access by a third party Interception or alteration during communication transmission Cases caused by the user’s usage environment Cases caused by the systems of payment service providers or other third parties

Article 14 (Changes to this Policy)

The Company may change this Policy, and any changes will be announced by posting them on the Company’s website or by other appropriate means.

Article 15 (Business Operator Information and Contact Point)

For inquiries regarding personal information or requests for disclosure, etc., please contact the following office.

Business Operator: KODAWARI Inc. Representative: Kanta Kobayashi Address: MIEUX Shibuya Building 8F, 5-3 Maruyamacho, Shibuya-ku, Tokyo, Japan Contact: kodawari.sensei.contact@gmail.com

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