Privacy Policy (Pre-registration)

Article 1 (Information We Collect)

We collect the following information when accepting a Pre-registration.

1. Information you provide

1. Your email address
2. Whether you agreed to this Policy, whether you agreed to receive our news emails, the date and time of your agreement, the version of this Policy you agreed to, and the wording of the consent statement shown to you

2. Information collected automatically

1. Information included in the URL to identify (i) the source, channel, or advertising campaign associated with your visit to this website and (ii) the version or identifier of the registration page (collected only if present in the URL when you submit the Pre-registration)
2. Your IP address (see paragraph 3 for how we use it)
3. Information relating to cookies and similar technologies (see Article 5)
4. Delivery information for the emails we send (sent, bounced, and complaint events)

3. Handling of IP addresses
We use your IP address to prevent bulk registrations from the same source and other misuse. Our service providers may process the IP address as described in paragraph 4 and Article 6.

4. Bot detection
To prevent automated registrations, we use the bot-detection mechanism (Turnstile) provided by Cloudflare, Inc. During this process, information including your IP address, browser and device characteristics, information about your interaction with the check, and the result of the check is transmitted to or generated by Cloudflare.

Article 2 (Purposes of Use)

We use the information we collect for the following purposes.

1. To accept, verify, and manage Pre-registrations
2. To verify the email address you provided (by sending a confirmation email and authenticating it)
3. To send you news about the App, including its release and availability date
4. To respond to your inquiries and to verify your identity
5. To prevent fraudulent registration, impersonation, malicious or nuisance registrations, bulk registration, and other misuse
6. To monitor email delivery status and improve delivery quality
7. To aggregate and analyze traffic sources, channels, and campaign effectiveness, and to improve this website and our advertising and promotional activities
8. To create and use statistical information processed so that individuals cannot be identified
9. To exercise rights, perform obligations, and respond to disputes under applicable laws
10. For administrative and operational activities reasonably necessary to carry out the purposes listed above

We do not use information collected through the Pre-registration to train or improve the AI used in the App.

Article 3 (News Emails and Unsubscribing)

1. In accordance with the Anti-Spam Act, we send news emails containing advertising only where you have given your prior consent.

2. A Pre-registration is completed when you press the button in the confirmation email we send after you enter your email address (double opt-in). We do not send news emails to addresses that have not completed this confirmation. The confirmation link is valid for 24 hours from issuance.

3. You may unsubscribe from our news emails at any time using the unsubscribe link included in every email we send, or from our unsubscribe page. We also accept unsubscribe requests by email at contact_ryzachat@go-spiral.ai.

4. When you unsubscribe, we stop sending you news emails. We also keep a record of your unsubscribe request so that we do not email you again by mistake. We mark the existing registration record as unsubscribed and retain it until the time set out in Article 8.

5. We limit both the minimum interval between confirmation emails to the same address and the total number of such emails. This is a safeguard against abuse in which a third party repeatedly submits someone else's email address.

Article 4 (Changes to Purposes of Use)

We will change the purposes of use only where the change is reasonably deemed to be related to the purposes before the change. If we make such a change, we will notify you by a method we designate, or publish the changed purposes on this website. If we make a change that is not reasonably deemed to be related to the purposes before the change, we will notify you in advance and obtain your consent.

Article 5 (Cookies and Similar Technologies)

1. This website may use cookies and similar technologies for the following purposes.

2. Cookies other than necessary ones are used only with your consent. You can change or withdraw your consent at any time from "Cookie settings" at the bottom of any page.

3. Disabling cookies other than necessary ones does not affect your ability to complete a Pre-registration.

Article 6 (Provision to Third Parties and Outsourcing)

1. We will not provide personal information to third parties without your prior consent, except in the following cases.

1. Where required by law
2. Where necessary to protect the life, body, or property of a person and it is difficult to obtain your consent
3. Where particularly necessary to improve public health or promote the sound growth of children and it is difficult to obtain your consent
4. Where it is necessary to cooperate with a national or local government body, or a party commissioned by one, in performing duties prescribed by law, and obtaining your consent is likely to impede the performance of those duties

2. Notwithstanding the preceding paragraph, a recipient is not deemed a third party where we outsource the handling of personal information within the scope necessary to achieve the purposes of use, or where personal information is transferred as a result of a merger or other business succession.

3. We transmit information to, or outsource its handling to, the following providers to the extent necessary to operate the Pre-registration.

4. When outsourcing the handling of personal information, we select providers recognized as handling personal information appropriately, require them by contract to implement appropriate confidentiality and security measures and to apply appropriate safeguards to subprocessors and onward disclosures, and supervise them as required by applicable law.

5. The transmissions and outsourcing described above may constitute a provision to a third party located in a foreign country under Article 28 of the APPI. The principal destinations are the United States and other countries or regions where the relevant providers operate. The United States has no comprehensive federal data protection law comparable to the APPI or the EU General Data Protection Regulation (GDPR); protection is instead governed by sector-specific federal laws and state laws.

6. Provision of personal data to third parties located in foreign countries is made, for each recipient, on a basis permitted under applicable law — your consent, the recipient having established a framework conforming to the standards prescribed by the rules of the Personal Information Protection Commission under Article 28 of the APPI, or the foreign country being designated by those rules as having a personal information protection system recognized as equivalent to that of Japan. Where we rely on such a framework, we take the measures necessary to ensure the recipient's continued implementation of equivalent measures, and we provide information about those measures on request.

7. We do not provide personal data to third parties under the opt-out notification procedure set out in Article 27, paragraph 2 of the APPI.

Article 7 (Security Measures)

1. We manage the personal information we collect appropriately and store it securely so as to prevent leakage, loss, damage, or unauthorized access. We also provide regular training to our personnel on the handling of personal information.

2. The security measures we take include managing access privileges, encrypting communications, monitoring how information is handled, supervising our service providers, minimizing the information we handle, and deleting information that is no longer needed or converting it into a form that is not personal information. For the Pre-registration in particular, we keep the information we hold to a minimum by limiting what we collect to your email address and the records associated with it.

3. We may decline to publish or disclose specific methods or details where doing so could compromise security. For information on our security measures beyond what is set out in this Article, please contact us using the details below.

Article 8 (Retention Period)

1. We retain the information we collect only for the period necessary to achieve the purposes of use. The Pre-registration is a time-limited sign-up whose purpose is to notify you of the App's release; once that purpose has been fulfilled, we delete the information as set out below.

2. The retention period for each category of information is as follows.

3. These periods take into account the retention periods prescribed by the Enforcement Regulation of the Anti-Spam Act for records evidencing consent: where specified commercial email has been sent, such records must be retained until one month has elapsed from the date of the last such email; where no such email is sent, until the date on which the sender decides not to send it. Where a longer retention period is required by law, or where retention is necessary to address misuse or a dispute, we may continue to retain the information to the extent and for the period necessary.

4. When deleting information, we take appropriate technical and organizational security measures to prevent unauthorized access, leakage, loss, or damage. After deletion, information may remain for a limited period in disaster-recovery backups. Information in backups is not used for ordinary business purposes and is deleted when the applicable backup-retention period expires.

Article 9 (Requests for Disclosure, Correction, Suspension of Use, and the Like)

1. Under the APPI, you may request disclosure of retained personal data that identifies you and, where applicable, records of third-party provision relating to your personal data. You may also request correction, addition, deletion, cessation of use, erasure, or cessation of provision to third parties of retained personal data, in each case subject to the requirements and exceptions under the APPI (collectively, "Disclosure and Related Requests").

2. Please send Disclosure and Related Requests by email to contact_ryzachat@go-spiral.ai. Requests to delete your registered email address are handled through the same channel.

3. To confirm that a request comes from you, we may ask you to provide information we designate or identity documents. For requests made by an authorized representative, we may ask for documents evidencing that representative's authority together with their identity documents.

4. After receiving your request, we will respond within a reasonable period in accordance with applicable law. Where we find your request to be well founded, we will act without delay and notify you accordingly. This does not apply where we are not obliged to comply under the APPI or other laws.

5. We charge a fee of JPY 1,000 per request for requests to disclose retained personal data and for requests to be notified of the purpose of use. No fee is charged for requests for correction, addition, deletion, cessation of use, erasure, or cessation of provision to third parties.

Article 10 (Age Requirement)

1. The App is intended for use by individuals aged 18 or over. The Pre-registration is likewise intended for individuals aged 18 or over; please do not register if you are under 18.

2. If we learn that personal information about a person under 18 has been registered, we will delete that registration and stop sending further emails. However, where retention is required by law or is otherwise necessary for legitimate reasons, we may retain such information to the minimum extent and for the minimum period necessary.

3. We do not target children under 13 and do not knowingly collect their personal information. If we learn that a person is under 13, we will promptly delete that information, subject only to the limited exceptions permitted by law.

Article 11 (Changes to This Policy)

We may review and revise this Policy in response to changes in law, changes to the Pre-registration, changes to the external services we use, or other operational needs. If we revise this Policy, we will publish the revised version on this website. Where there is a material change to how personal information is handled, we will provide prior notice or obtain consent to the extent required by law.

Contact

For questions about this Policy, and for requests to disclose, correct, erase, restrict, or otherwise exercise your rights regarding your personal information, please contact us using the details below. We have appointed a person responsible for overseeing our handling and protection of personal information.