1. Introduction (Purpose of the Policy)

This Privacy Policy sets forth the handling of personal information (hereinafter referred to as "Personal Data") of users who use our app "locq" (hereinafter referred to as "the App"). We respect user privacy and are committed to protecting personal information. By using the App, users are deemed to have agreed to this policy.

2. Scope of Application

This policy applies to all Personal Data acquired by us, regardless of the country or region of the user.

2-1. Coverage

We may apply individual privacy policies, terms of use, or additional clauses (collectively referred to as "Individual Policies") for specific services. Individual Policies explain how we collect, use, and provide Personal Data for those specific services. In the event of any conflict between an Individual Policy and this Policy, the Individual Policy shall prevail.

In the application of this policy, we shall be the "controller" responsible for the handling of Personal Data.

2-2. Applicable Laws and Versions

We process Personal Data in accordance with this Policy to the extent permitted by applicable laws.

While we may provide this Policy in multiple languages, to the extent permitted by applicable law, the Japanese version shall apply to users in Japan, and the English version shall apply to users in other countries or regions.

3. Types of Information Collected

3-1. Information Provided Directly by the User

• Name, email address, profile information (such as nickname), date of birth, and gender provided during user registration.
• Language learning progress and status.
• Conversation data (text and audio data).

3-2. Information Collected Automatically

The App automatically collects information regarding when and how you used our services, including:

• Device information (model name, OS version, etc.).
• Usage logs (app usage status, time spent, operation history, etc.).
• IP address.
• Location information (only if granted by the user).

3-3. Information via Cookies and Similar Technologies

• We use cookies and device identifiers to understand the user's usage environment.

4. Purpose of Using Information

• To provide and operate the App.
• To improve conversation features and develop new functions.
• To respond to bugs and provide user support.
• To enhance and customize user experience.
• For marketing and advertisement delivery.
• To comply with laws and protect rights.
• To train and analyze AI technology (conversation data may be used in an anonymized form).

5. Provision of Information to Third Parties

We do not provide Personal Data to third parties without user consent, except as required by law. However, information may be provided to third parties in the following cases:

• When outsourcing operations to cloud services or external AI service providers.
• When disclosure is required by law.
• When necessary to protect the life, body, or property of a person.

In such cases, we will conduct proper management and supervision of the third party. In addition, if any of such third parties are located outside Japan, we will take appropriate protective measures in accordance with applicable laws and regulations.

6. Storage and Management of Information

User Personal Data is securely managed, and we take reasonable security measures to prevent unauthorized access, loss, falsification, or leakage. Unless you request the deletion of your account, we will, in principle, retain most of your Personal Data. If an account is deleted, we will handle Personal Data for a certain period in accordance with applicable laws and internal regulations for the following purposes:

• Responding to inquiries.
• Dispute resolution and fee collection.
• Fraud detection and prevention.
• Obligations under applicable laws or regulations set by financial instrument exchanges.

7. User Rights

Users have the following rights:

• Request for disclosure of Personal Data.
• Request for correction or deletion of inaccurate information.
• Request to suspend use or stop provision to third parties.
• Opt-out from marketing communications.

Please contact our support desk to exercise these rights.

8. Use of Third-Party Modules and Cookies

The App and related services use cookies and similar technologies, such as SDKs (Software Development Kits) provided by third parties, to enhance user convenience and analyze usage. Users can disable cookies via browser settings, but some features may become unavailable. We may install modules such as SDKs provided by third parties for the following purposes:

• To analyze the usage status of the service.
• To deliver advertisements and measure their effectiveness.

For Personal Data handled by third parties through modules provided by them, the respective third party's privacy policy shall apply.

9. Privacy of Minors

For users under 13 years of age, we recommend using the App only after obtaining consent from a parent or guardian.

10. Changes to the Privacy Policy

This Privacy Policy may be changed without prior notice in accordance with legal changes or service modifications. In case of changes, we will notify users through the App or our official website. Significant changes will be notified directly to users.

11. Contact Information

Company Name: locq
Email: kaiwa_support@locq.jp
Business Hours: Weekdays 9:00 AM – 5:00 PM (JST)

12. Governing Law and Jurisdiction

This Privacy Policy shall be governed by the laws of Japan.