Privacy Policy

This policy describes how Fenrir Inc. (“We”, “Us” or “Our”) collects and uses personal information through the Japanese conversation application “tomowa” (the “Software”) that We provide for iOS and Android devices. This policy applies to the Software and to all users who use the Software or who contact Us directly or indirectly in relation to the Software.

If you contact Us through a service provided by other companies, We will manage the information received in accordance with Our corporate privacy policy (https://www.fenrir-inc.com/jp/privacy/; the “Company Privacy Policy”); provided, however, that the privacy policies separately agreed between you and the service providers of other companies will apply to your use of such services.

When you use the Software, this policy applies in addition to the Company Privacy Policy. If there is any inconsistency between this policy and the Company Privacy Policy, this policy shall prevail with respect to the Software.

Article 1 (Collection, Purpose of Use, and Grounds for Use of Personal Information)

We receive the following information from users (collectively, “Personal Information, etc.”). We will use Personal Information, etc. only for the purpose of use notified to users at the time of provision thereof or within the scope of the purposes listed below, and will not use it for any other purpose without prior consent. In addition, Personal Information, etc. will be deleted immediately when its use is no longer necessary. Collected data may also be anonymized as necessary and processed as statistical data. In such cases, We will endeavor to treat such data as irreversibly anonymized.

  1. Information We Collect

    We collect the following information. The details of the information to be collected are shown as examples below.

    Software Usage Information

    1. Device Information
      1. Device identifiers
      2. Device model
      3. OS version
    2. Network Information
      1. Access date and time
      2. IP address
    3. Operation Information
      1. Operation logs necessary to analyze usage status (e.g., screen transitions, button actions)
      2. Error logs and crash reports

    Software Data

    1. Account Information (managed through Microsoft Azure authentication infrastructure)
      1. Display name
      2. Email address
      3. Account creation date
    2. Profile Information
      1. Uploaded icon images
    3. Learning-related Data
      1. Learning progress information
      2. Bookmarked learning phrases
    4. Dialogue-related Information
      1. Conversation history with AI (chat logs)
      2. Text transcribed from voice input
        1. Text transcribed from voice input is obtained using the speech recognition functions provided by the user’s device OS. Such functions may transmit input audio to the OS provider (such as Apple Inc. or Google LLC) and process it in accordance with the provider’s privacy policy. We do not transmit, collect, or store the audio data itself on Our servers.
        2. Based on the transcribed text, responses are generated by using generative AI services.
      3. Review results of conversation history (chat logs) generated by generative AI services

    Inquiry-Related Information (Information voluntarily provided by users when submitting inquiries)

    1. Inquiry details
    2. SNS account information
    3. Company name, department name, organization name, etc.
    4. Address
    5. Name
    6. Contact information (email address, telephone number)

  2. Purpose of Use of Collected Information

    Response to Inquiries

    1. Responding to various inquiries

    Provision of Services

    1. Providing the Software to users

    Improvement of Services

    1. Improving quality, developing new features, and enhancing user experience

    Statutory Procedures

    1. Investigation and resolution of claims and disputes by Us or users concerning the use of Our services
    2. Provision to national agencies or local governments to which it is permitted by laws and regulations

  3. Grounds for Use of Collected Information

    We will use Personal Information, etc. based on one or more of the following grounds.

    Consent

    We collect Personal Information, etc. of users based on the consent of the users. You have the right to withdraw your consent at any time.

    Responding to User Requirements

    We collect Personal Information, etc. when processing is necessary to perform contracts or to take steps at the request of users prior to contract conclusion, including responding to inquiries.

    Compliance with Legal Obligations

    We collect Personal Information, etc. to comply with the legal obligations that We must comply with.

    Protection of Important Interests of Users or Third Parties

    We collect Personal Information, etc. in order to protect important interests of users and third parties. Important interests of users include reducing the need for users to re-enter information and the display of the most appropriate content for the users.

    Protection of the Public Interest

    We collect Personal Information, etc. to the extent necessary to protect the public interest.

    Pursuit of the legitimate interests of Us or third parties

    We collect Personal Information, etc. in order to pursue Our legitimate interests or those of third parties. Our legitimate interests include preventing and detecting fraud in Our services and responding to it, providing customer support, and conducting investigations and analyses to improve Our services or security.

  4. Account Deletion (Cancellation)

    Users may request deletion of their account (cancellation) in accordance with the procedures prescribed in the Software. When a cancellation request is made, after completing Our prescribed procedures such as identity verification, We will delete, within a reasonable period, data relating to users stored on servers managed by Us (including learning progress information, bookmarks, conversation history (chat logs), and uploaded icon images).

    Account information used for login authentication is managed on the Microsoft Azure authentication infrastructure used by Us, and We will take necessary steps, including deletion processing on such authentication infrastructure.

    However, We may retain certain information for a certain period to the extent necessary for compliance with legal obligations, prevention and detection of fraudulent activities, dispute response, and security assurance.

  5. Use of Cookies, etc.

    We may use Cookies on the websites We operate and related websites. A Cookie is a text file stored on your computer system through your Internet browser. By using Cookies, you can save usage history and entered information exchanged between the browser and the server when you use websites on your computer. Cookies may be used to deliver optimized content.

    Users can disable Cookie settings by using the settings in the users’ Internet browsers.

  6. Use of the Software

    1. The Software is provided through platforms operated by Apple Inc. and Google LLC (the App Store and Google Play). Users must agree to the privacy policies and terms of use of those platforms.
    2. The Software uses speech recognition functions provided by Apple Inc. (iOS) and Google LLC (Android) for voice input features. Audio data used for voice input may be transmitted to such OS providers and processed in accordance with their privacy policies. We do not transmit, collect, or store the audio data itself on Our servers.
    3. The Software provides conversation functions using generative AI in order to enhance the Japanese conversation experience. When you use such functions, text you enter (including text converted on your device through voice input) and contextual conversation information (e.g., immediately preceding conversation history) will be transmitted, for the purpose of generating responses, to the generative AI infrastructure on Microsoft Azure used by Us, and will be processed on such infrastructure. Inputs transmitted to such infrastructure and outputs generated thereon will not be used for training or improving AI models.
    4. The Software may restrict certain functions depending on the user’s age due to changes in applicable laws or platform requirements.
    5. The Software uses various analytics tools described in the following section, and users must also agree to the privacy policies presented by the providers of such analytics tools when using the Software.
    6. The Software may communicate with servers managed by Us. In such cases, access-related information associated with such access will be recorded. Such access-related information will be strictly managed in accordance with Japanese law and this policy.

  7. Transmission of Information to Cloud Services and Analytics Tools

    The Software uses SDKs of the following cloud services and analytics tools, and user information may be transmitted to these services. The purposes of use, types of data transmitted, and an overview of how such data is processed for each service are as follows.

    Microsoft Azure

    Service Provider

    Microsoft Corporation

    Purposes of Use

    1. As the cloud server and authentication infrastructure for the Software
    2. To provide generative AI-based conversation features
    3. To provide text-to-speech functionality
      1. Only text generated by generative AI or text pre-stored by the Software is transmitted to Microsoft Azure for text-to-speech purposes.

    Data Transmitted

    1. Access information (IP address, access date and time, device information, etc.)
    2. Account information
    3. Profile information
    4. Learning-related data
    5. Information related to conversation features

    Data Storage and Processing Locations

    1. Data storage and processing locations for providing the Software may be located in Japan, the United States, and other countries or regions, depending on Microsoft Azure operations.
    2. User information may be transferred to, and stored or processed in, such countries or regions by the operation of Microsoft Azure.
    3. We use Microsoft’s cloud infrastructure after confirming that appropriate security measures are implemented by Microsoft.

    Opt-Out

    1. As Microsoft Azure is indispensable for providing the Software, individual opt-out settings are not available.
    2. Users who do not wish their information to be transmitted to this cloud service cannot use the Software.

    Terms of Use and Privacy Policy

    1. Microsoft Azure Legal Information
      https://azure.microsoft.com/ja-jp/support/legal/
    2. Microsoft Privacy Statement
      https://www.microsoft.com/ja-JP/privacy/privacystatement

    Google Analytics for Firebase (and Firebase Crashlytics)

    Service Provider

    Google LLC

    Purposes of Use

    1. Analyzing usage of the Software to improve functionality and quality
    2. Identifying and fixing errors and crashes

    Data Transmitted

    1. Access information (IP address, access date and time, device information, etc.)
    2. Device information (OS version, device model, etc.)
    3. Client ID (application-specific identifier)
    4. Operation logs (screen transitions, button actions, etc.)
    5. Error logs and crash reports

    Data Storage and Processing Locations

    1. Information collected through Google Analytics for Firebase (and Firebase Crashlytics) may be transferred to and stored or processed on servers operated by Google in the United States and other countries or regions.
    2. We use these analytics tools after confirming that Google implements appropriate security measures.

    Opt-Out

    1. Users may stop transmission to these services in the Software’s settings.

    Terms of Use and Privacy Policy

    1. Google Analytics Terms of Service
      https://marketingplatform.google.com/about/analytics/terms/us/
    2. Firebase Terms of Service
      https://firebase.google.com/terms
    3. Google Privacy Policy
      https://policies.google.com/privacy?hl=en

Article 2 (Other Provisions)

Matters not provided for in this policy shall be governed by Our corporate privacy policy.

Supplementary Provision
Established on January 1, 2026