Privacy Policy
This Policy sets out the basic approach of Fixus LLC (the "Company") to the handling of users' information in KOTOBA LOOP and related services. This English text is provided for convenience; the Japanese text at /privacy/ is the governing version.
Article 1 (Scope)
This Policy applies to the handling of users' information in KOTOBA LOOP (the applications for Android and Windows provided by the Company; the "Application"), the website relating to the Application (kotobaloop.fixus.studio), the contact channel, and all services incidental thereto (collectively, the "Service"). The Service includes services currently provided and any service the Company provides in the future. For the Service, this Policy takes precedence over any policy the Company sets out for its other websites or products.
Article 2 (Handling of information in the Application)
The Application creates study materials with speech and translations in the language being learned from text, audio, video and other source material prepared by the user, and provides functions for studying those materials. As a principal behavior of the version currently provided, source material, study materials, study records and settings are processed and stored on the user's device, and transcription, translation, speech synthesis and other processing are performed by processing components on the device. Except where the user chooses the services described in Article 3 or Article 4, this information is not transmitted outside the device, and the Company neither obtains nor stores it.
Information stored on the device by the Application includes the following. It is stored on the user's device and is not obtained by the Company.
- Source material prepared by the user, and study materials created from it (text, translations, speech, timing of sentences and words, dictionary-based explanations and other components)
- Study records such as progress, marks placed by the user and the number of times studied
- Audio the user recorded to compare with their own voice. As a principal behavior of the version currently provided, such recordings are temporary, for on-the-spot comparison, and are discarded when the material is closed
- Settings for display, language, parental functions (including a passcode) and other settings
- Authentication keys the user registered in order to use the external services described in Article 3
- The records relating to the use of Google Drive described in Article 4
Users may delete this information from the device through operations within the Application (deleting materials, changing settings, signing out and the like) or by clearing the Application's data. In the Android Application, uninstalling the Application also deletes the information on the device. In the Windows Application, the information is stored in a folder dedicated to the user's Windows account, so it remains after the application itself is removed until that folder is deleted. Where a user exports a study material through a function of the Application and hands it to another person, the content of that material and the recipient are determined by the user, and the Company does not obtain them.
The handling under this Article may be revised from time to time at the Company's discretion in response to changes in the content, functions or form of provision of the Service, applicable laws or other circumstances, and the handling after such revision shall be as set out in the latest version of this Policy.
Article 3 (External services chosen by the user)
Within the Application, users may, by their own choice, use services provided by the external operators listed below. The information transmitted from the device to such operators in the course of that use, and the information those operators obtain, are handled under the policies of those operators; the Company is not involved and does not obtain that information.
- Artificial-intelligence and similar services for transcription, translation, speech synthesis or explanations that the user accesses with an authentication key the user registered. Only where the user has chosen such a service does the Application send the text, audio and other source material needed for processing (including the contents of a study material received from Google Drive under Article 4, where the user selects it) directly from the device to that operator
- Video or audio distribution services. Playback and retrieval of a video or audio item the user specifies are performed through the mechanisms those operators provide. Playback of YouTube videos uses YouTube API Services, and the information Google obtains through it is handled under the Google Privacy Policy
- The platform that distributes the Application, and the payment services described in Article 5
Article 4 (Use of Google Drive)
Only where the user selects the "Google Drive" function within the Application and completes Google's authorization process does the Application use the user's Google Drive as a place to move study materials between the user's own devices and as a place to receive study materials from a folder another user has shared. This Article sets out, separately from the handling of other information, the scope and handling of the information obtained through Google APIs in that function. Creating study materials, studying them and handing them over by export are provided without this function.
1. Permissions used
The Application uses the following two permissions.
- "See, create, edit and delete only the specific Google Drive files you use with this app" (
drive.file). This is used only for the folders and study-material files the Application created in Google Drive. Under this permission, files not created by the Application are neither visible to nor changed by the Application - "See and download all your Google Drive files" (
drive.readonly). This is requested additionally, the first time the user selects the "Connect a shared folder" function. It is used to list the folders shared with the user and their attributes (name, identifier, owner, parent folder) so that the user picks one; to refer to parent-folder attributes in order to check the hierarchy between a candidate and folders already connected; and to list the files inside the folder the user connected (name, identifier, modified time, size and other attributes) and retrieve, upon the user's operation, the KOTOBA LOOP study-material files among them. The contents of other files are not retrieved. This is a view-only permission, and the Application's own operations likewise never modify, move or delete folders shared by other users or the files in them
2. Information obtained and transmitted
Under the permissions above, the Application requests directly from Google, and obtains, the identifier of the user's Google account (email address); attributes of the folder and file listings (name, identifier, modified time, size, a checksum used to compare contents, parent folder, and the owner's display name and email address); and the contents of KOTOBA LOOP study-material files. Upon the user's operations, the Application also transmits directly from the device to Google the study-material files and folders the Application creates, and instructions to rename, move or delete items the Application created.
3. Information stored on the device
For the use of Google Drive, the Application stores on the device the email address of the Google account the user selected, a local copy of the listings of the connected folders and the files in them (the attributes described in the preceding paragraph; parent-folder attributes referred to for checking the hierarchy are not stored), and the retrieved study materials. The Android Application does not store access tokens; it obtains a token from Google each time one is needed. The Windows Application stores the token used to renew authorization and the local copy of the listings on the device, encrypted with the protection facility provided by the operating system.
4. Revoking authorization and deletion
Users may revoke the authorization granted to KOTOBA LOOP at any time from the third-party connections page of their Google Account. The "Disconnect" operation in the Application deletes the local copy of that folder's listing, and the "Sign out" operation deletes the local copies of the listings and the authorization information for that account. In either operation, the user chooses whether to keep the received study materials in the bookshelf or to delete them; materials copied into the bookshelf are deleted in the bookshelf. These operations do not revoke the authorization on Google's side. Clearing the data as described in Article 2 also deletes the information stored on the device. Folders and files created in Google Drive are not deleted by revoking authorization or by removing the Application; manage or delete them in Google Drive.
5. Handling of data obtained through Google APIs
This paragraph governs the information obtained through Google APIs after Google's authorization (including the information described in paragraph 2; "Google user data"). For Google user data, this paragraph takes precedence over the general provisions on purposes of use, provision to third parties and retention period.
- Purpose of use.
Google user data is used to provide the functions under this Article that the user selects (moving study materials between the user's devices, receiving study materials from a shared folder, and storing, viewing, playing and otherwise studying the received materials) and for purposes incidental to providing or improving these features, which are shown prominently in the Application's user interface. - Sharing, transfer and disclosure.
The Company does not share, transfer or disclose Google user data to third parties for purposes other than those set out in this paragraph. This does not apply to transmission from the device to Google at the user's direction; to transmission to the external services described in Article 3 or export of study materials upon the user's operation; to transfers made with the user's consent to provide or improve features shown in the user interface; to cases required by applicable law; to cases necessary for security purposes such as investigating abuse; or to succession as part of a merger, acquisition or sale of assets after obtaining the user's explicit prior consent. - Human access.
Because Google user data remains on the user's device and is not transmitted to the Company, the Company's officers, employees and contractors do not read it. This does not apply where the user has given explicit consent regarding specific data, where necessary for security purposes such as investigating abuse, where required by applicable law, or where aggregated and anonymized information is used for internal operations. - Prohibited uses.
Google user data is not used for serving advertisements (including retargeting, personalized or interest-based advertising), is not transferred or sold to advertising platforms, data brokers or other information resellers, is not used to determine creditworthiness or for lending purposes, and is not used to develop, improve or train generalized artificial intelligence or machine learning models; nor is it transferred or sold to third parties for any of these purposes. - Retention and deletion.
Google user data stored on the device is retained on the device for the period needed to provide the functions under this Article, unless a longer retention period is required or permitted by applicable law. Access tokens used for authorization are used only in memory during processing and are not stored. The token used by the Windows Application to renew authorization is deleted on sign-out. The methods of deleting the information on the device and of revoking the authorization are as set out in paragraph 4. - Changes in handling.
Where the Company intends to use Google user data for a purpose other than those set out in this paragraph, it notifies users in advance and obtains the necessary consent. - Compliance.
KOTOBA LOOP's use and transfer to other apps of Google user data complies with the Google API Services User Data Policy, including the Limited Use requirements.
The handling under this Article may be revised from time to time at the Company's discretion in response to changes in the content, functions or form of provision of the Service, applicable laws or other circumstances, and the handling after such revision shall be as set out in the latest version of this Policy.
Article 5 (Paid functions and payment)
Where the Company provides paid functions in the Service, applications, payment, cancellation, refunds and other procedures relating to purchases are processed on the billing platform of the operator that distributes the Application or of a payment provider designated by the Company. The Company does not obtain users' credit card numbers or other payment information. The conditions and prices relating to purchases shall be as provided by that platform or payment provider and by notices the Company separately sets out.
Article 6 (Information obtained through the website and inquiries)
To the extent necessary for operating the website relating to the Service, responding to inquiries and providing and operating other business, the Company may obtain information including the following. The specific types of information obtained and the methods of obtaining them may be revised from time to time in response to changes in the content, functions or form of provision of the Service.
- Information the user enters or sends in using the Service, making inquiries or in other procedures
- Information about the user's device, OS, browser, communication environment and other usage environment
- Information about usage of the Service, operation history, diagnostic information and other usage analytics
- Information obtained through cookies, identifiers, log information and other technical means
- Information the Company lawfully receives from external operators, distribution platforms or other third parties
Article 7 (Purposes of use)
The Company uses the information it obtains to the extent necessary to achieve purposes including the following.
- Providing, operating, maintaining, servicing and improving the Service
- Providing guidance, notices, new functions and new services relating to the Service, and communicating incidental matters
- Responding to inquiries from users, and investigating and addressing defects
- Understanding, analyzing and compiling statistics on usage of the Service, and business activities based thereon
- Addressing violations of terms, unauthorized use and other inappropriate use
- Planning, development, marketing and related work concerning the Company's business
- Other purposes incidental or related to the foregoing
Article 8 (Provision to third parties and entrustment)
The Company may provide users' information to third parties in any of the following cases. For Google user data, Article 4, paragraph 5 takes precedence.
- Where, to the extent necessary to achieve the purposes of use, the Company provides or entrusts information, in the form the Company deems necessary, to contractors, partner operators, distribution platforms, affiliated companies or other third parties
- Where business succession occurs through a merger, business transfer or other event
- Where required by law, or where a public authority makes a request based on law
- Where necessary to protect the life, body or property of a person
- Other cases permitted under the Act on the Protection of Personal Information of Japan and related laws
Article 9 (Cookies, analytics tools and similar technologies)
On the website relating to the Service, the Company may use cookies, local storage, identifiers and similar technologies, and analytics tools provided by external operators, for improving convenience, understanding usage, analysis, improving the Service and related purposes. Information obtained through such tools is handled under the policies of those operators. These technologies, tools and the scope of their use may be changed from time to time at the Company's discretion.
Article 10 (Management of information and security measures)
The Company takes measures, to the extent it deems reasonable, to prevent leakage, loss or damage of the information it obtains and otherwise to manage it securely. In this Article, "sensitive data" means the Google user data described in Article 4, the authentication keys described in Article 2, and other information the Company deems sensitive.
As principal measures in the version currently provided, the Company takes measures including the following.
- Protection in transit.
Communication between the Application and Google or other external parties uses encrypted channels (HTTPS/TLS). - Protection at rest.
In the Android Application, the on-device information described in Article 2 is stored in the storage area the operating system provides for the Application alone, access by other applications is restricted by the operating system's isolation mechanisms, and authentication keys are stored encrypted with the key-protection facility of the operating system. In the Windows Application, the on-device information is stored in a folder dedicated to the user's Windows account, and authentication keys, the token used to renew authorization and the local copy of the listings described in Article 4 are stored encrypted with the protection facility provided by the operating system. - Handling of authorization information.
Access tokens used for Google's authorization are used only in memory during processing and are not stored in the Application's settings or logs. - Minimization of data obtained and referenced.
The information the Application obtains from Google Drive is limited to the scope set out in Article 4; within a folder shared by another user, the Application does not retrieve the contents of any file other than study-material files. - No use beyond the stated purposes.
Sensitive data is not used for serving advertisements, for sale, or for any purpose other than those set out in this Policy, is not used to develop, improve or train generalized artificial intelligence or machine learning models, and is not provided to third parties for such purposes. - Handling within the Company.
Access to information the Company obtains under Article 6 is limited to persons who need it for business. Where the Company entrusts work under Article 8, it requires the contractor, by contract or other means, to maintain the level of security the Company deems necessary. - Retention and deletion.
Retention periods are governed by Article 11; the methods of deleting on-device information and revoking authorization are governed by Articles 2 and 4.
The measures in the preceding paragraph may be revised from time to time at the Company's discretion in response to changes in the content, functions or form of provision of the Service, applicable laws, the state of technology or other circumstances.
Article 11 (Retention period)
The Company retains the information it obtains for the period necessary to achieve the purposes of use, or for such period as the Company deems necessary for its business, for compliance with law or for handling disputes.
Article 12 (Requests for disclosure and other matters)
Users may request disclosure, correction, addition, deletion, suspension of use or suspension of provision to third parties ("disclosure and other matters") of their own personal data held by the Company, in accordance with the Act on the Protection of Personal Information of Japan. The Company responds to a reasonable extent after identity verification and other procedures the Company prescribes. The Company may decline to respond, in whole or in part, where an exemption under law applies or where the Company reasonably determines that responding would seriously hinder the proper conduct of its business.
Information stored on the device by the Application is not held by the Company and is therefore not subject to disclosure and other matters. Users may handle that information through operations in the Application or by clearing its data.
Article 13 (Eligible users and use by minors)
The Service may be used regardless of age. Where a minor uses the Service, the use, the creation of materials and the choice of external services are made with the consent and under the responsibility of a parent, guardian or other legal representative. Where the function under Article 4 is used with a Google account managed by a parent or guardian, Google's authorization proceeds through the guardian-confirmation procedure Google provides. In the version currently provided, the Application has no function that sends children's personal data to the Company's servers.
Article 14 (Users' responsibilities)
Users confirm and manage, on their own responsibility, the content of the source material and study materials they prepare, create or hand to others in the Service, and their right to use that source material. If a user's violation of law, this Policy or conditions the Company separately sets out, or a user's failure to perform their obligations, causes damage, claims, disputes or costs (including reasonable attorneys' fees) to the Company, its officers, employees, contractors or partner operators, the user shall defend, indemnify and hold them harmless at the user's own cost and responsibility.
Article 15 (Changes to this Policy)
The Company may change this Policy from time to time at its discretion in response to changes in the content, functions or form of provision of the Service, applicable laws, social conditions or other circumstances. The changed Policy takes effect when the Company posts it on this page, without individual notice to users. Users are responsible for checking the latest content posted on this page before using the Service, and continued use of the Service after a change is deemed to constitute the user's consent to the changed Policy. For changes in the handling of Google user data, Article 4, paragraph 5 takes precedence.
Article 16 (Governing law and jurisdiction)
This Policy is governed by the laws of Japan. The district court having jurisdiction over the Company's location shall be the court of exclusive agreed jurisdiction in the first instance for any dispute arising in connection with this Policy or the Service.
Article 17 (Contact)
Inquiries about this Policy may be sent to the following address.
kotobaloop@fixus.co.jp
Note: Due to strengthened security requirements, messages sent from free email services, certain email domains or shared mail servers may be automatically blocked before reaching our server. If you receive no response within 7 business days of sending, please resend from a different email address. Depending on the content of the inquiry and our business circumstances, a response may take a considerable time.
Fixus LLC
2-15-16 Tokuriki-shinmachi, Kokuraminami-ku, Kitakyushu-shi, Fukuoka 802-0979, Japan