Children’s Privacy Notice

1Scope and Governing Law

The service is offered to residents of Japan. Information about children is handled in accordance with Japan’s Act on the Protection of Personal Information.

This English text is provided for reference only. The Japanese version is the authoritative text and prevails in the event of any discrepancy.

This Notice applies to the handling of personal information of a child registered in the service by the contracting guardian, and supplements the Privacy Policy.

2The Relationship Between the Guardian and the Child

The contracting guardian is one adult who is the parent with parental authority, the guardian of a minor, or otherwise the statutory legal representative of the registered child under Japanese law.

The child uses the service but is not a party to the contract. The child learns using the contracting guardian’s account; there is no separate login for the child.

The child does not independently make payments, change plans, cancel, change registration details, or delete the account. Such requests are accepted from the contracting guardian.

3The Child’s Position

Although the child is not a party to the contract, the child is the "principal" under the Act on the Protection of Personal Information with respect to their own personal information.

On screens used by the child, the operator uses expressions appropriate to the child’s age and level of understanding. Explanation of how information is handled is given by the contracting guardian, as described under "Explanation to the Child".

The operator takes the best interests of the child into account when handling the child’s information.

4Information Collected

The operator collects the following information about the child, to the extent necessary to provide the service.

• Nickname or display name, and school year
• The initial assessment at the start of learning, learning methods, display settings, and other information entered during onboarding
• Problems presented, answers, correctness, answer times, and time taken to answer
• Learning sessions, learning days, continuity, levels, achievement, and other learning history
• Difficulty, mood, impressions, and other feedback the child enters at their option
• Information about the device, communications, and logs
• Internal identifiers linking the child to the contracting guardian’s account

5Information Not Collected

The nickname and school year are entered by the contracting guardian during guardian onboarding.

Unless necessary to provide the service, the operator does not collect the child’s real name, address, telephone number, school name, photograph, voice, or location information.

6Purposes of Use

The operator uses information about the child for the following purposes.

• Providing problems, learning screens, hints, and feedback suited to the child
• Recording learning history and progress, and displaying them to the contracting guardian
• Synchronizing learning records held on the device with the server
• Investigating and recovering from failures, errors, and synchronization problems
• Implementing security control measures and responding to fraudulent use
• Improving the service, learning materials, and methods of learning support
• Creating and analyzing statistical information from which individuals cannot reasonably be re-identified

7No Advertising or Profiling

The operator does not use information about the child for the purpose of advertising delivery, behavioural targeting, or provision to third parties through profiling.

8Explanation to the Child

Explanation to the child about the handling of information is given by the contracting guardian, in a manner suited to the child’s level of understanding.

On screens used by the child, the operator uses expressions appropriate to the child’s age and level of understanding.

In its guidance for guardians, the operator indicates matters worth conveying to the child: that learning records are saved, that the saved records can be reviewed by the guardian, and that the child may talk to their guardian if something troubles them.

9Exercise of Rights

Requests concerning the child’s information — notification of the purpose of use, disclosure, correction, addition, deletion, suspension of use, erasure, or suspension of provision to third parties — are in principle accepted from the contracting guardian, who should contact the support desk from the registered email address.

The operator investigates without delay in accordance with law, and notifies the outcome or the reason for not responding.

Where a guardian other than the contracting guardian makes a request, the operator responds after confirming statutory representative authority or other legitimate authority. Watching over the child’s learning does not by itself confer authority to change the contract or the account.

Where the child makes a request, the operator responds taking into account the child’s age, the content of the request, and applicable law, liaising with the contracting guardian as necessary.

10Security Control Measures

The operator implements reasonable security control measures, including restriction of access rights, encryption of communications, and separation of data by user.

The operator handles information about the child only to the extent necessary to provide the service and to maintain security.

For security reasons, the operator may not disclose specific configuration values or information that could be used for attacks.

11External Providers, Retention, and Interviews

Where the handling of information about the child is entrusted to external providers, the names of those providers, the purposes, and any handling outside Japan are as set out in the Privacy Policy.

The retention period for information about the child, how to request deletion, and the scope of information retained after deletion are as set out in the Privacy Policy.

Interviews with a child are conducted only where the contracting guardian gives individual consent and is present. Participation is voluntary and is not a condition of using the service.