Lopal Logo

LO-PAL Privacy Policy

This is an English reference translation. The official version is the Japanese プライバシーポリシー, which prevails in the event of any discrepancy.

Introduction

INNIT LLC (Gōdō Kaisha INNIT) (the "Company", "we", or "us") regards the protection of users' personal information as a top priority. This Privacy Policy (the "Policy") clearly sets out how we collect, use, and manage users' personal information in "LO-PAL" and its related services (including the matching platform, the Japanese-learning app "Lingo", and the guide and travel media; collectively, the "Service"). Please read this Policy carefully before using the Service.

Article 1 (Scope of Application)

    This Policy applies when a user uses the Service. To use the Service, you must agree to this Policy.

Article 2 (Definitions)

    The definitions of terms used in this Policy are as follows.
  1. Personal Information: information about a living individual, including a name, date of birth, address, telephone number, email address, and other information that can identify a specific individual.
  2. User: an individual or corporation that uses the Service.
  3. Requester: a User who requests information or support from Supporters through the Service.
  4. Supporter: a User who receives requests from Requesters and provides information or support.
  5. Lingo: the Japanese-learning application provided by us.
  6. Guest: a user who uses certain features of Lingo and the like without creating an account. In this Policy, "User" includes Guests where the context so requires.

Article 3 (Information We Collect)

We collect the following information within the scope necessary to provide the Service. With respect to Lingo, even where it is used by a Guest who has not created an account, we collect the following information associated with a Guest identifier and store it on our servers.

  1. Information provided directly by the User
    • Registration information
      • display name
      • user name
      • email address
      • password
      • profile image
      • identification document image
      • nationality
      • gender
      • date of birth
      • place of residence (country/region)
      • prefecture of residence
      • municipality of residence
      • language ability (languages used, level)
      • self-introduction
      • profile disclosure settings (public/private choice per item)
      • other information necessary to use the Service
    • Transaction information:
      • the content of Task or Advice requests
      • reward amounts and payment information
      • transaction history and rating information
      • the content of chats and messages
      • other information necessary to use the Service
    • Payment information:
      • credit card information (collected via the payment processor)
      • bank account information (when receiving rewards)
      • other information necessary to use the Service
  2. Information relating to the use of Lingo (Japanese-learning app)
    • display language (UI language), mother tongue, learning goal (such as JLPT level), estimated proficiency, and prior knowledge such as kana
    • learning progress, answer history for questions, test results, and review (spaced-repetition) data
    • the Guest identifier (where not registered) or the linked account information
    • other information necessary to provide Lingo
  3. Information collected automatically
    • Log information
      • access date and time
      • IP address
      • browser type and version
      • device information used
      • information from cookies, local storage, and other on-device storage technologies (including Lingo's Guest identification token)
      • other information necessary to use the Service
  4. Information obtained from third parties
    • Information through social-media integration:
      • information permitted by an external service when integrated with that service
      • other information necessary to use the Service
  5. Other
    • any other information necessary for the use and operation of the Service

Article 4 (Purposes of Use)

We use the personal information we obtain for the following purposes.

  1. Provision and operation of the Service:
    • user authentication and account management
    • matching and transaction management for Tasks and Advice
    • payment processing and payment of rewards
    • public display of profile information on the user list page (enabled by default at registration; can be switched between public and private at any time from My Page)
    • display of the user name and profile image associated with posts (Advice/Task) and answers (viewable by users of the Service when a post or answer is made)
  2. User support:
    • responding to inquiries
    • resolving trouble
    • communicating important notices about the Service
    • delivering notifications about new matters and matching
  3. Service improvement and development:
    • analysis of usage
    • planning and development of new features and services
    • conducting user surveys
  4. Marketing and promotion:
    • delivery of newsletters and campaign information (where the User's consent has been obtained)
    • display of advertisements and measurement of their effectiveness
  5. Provision of Lingo (Japanese-learning app):
    • recording learning progress and answer history and providing learning features
    • optimizing question delivery and review (spaced repetition) according to proficiency
    • carrying over Guest data to an account
    • processing payments for paid plans (subscriptions) and managing subscription status
  6. Prevention of fraud and security:
    • detecting and preventing unauthorized access and improper use
    • responding to conduct that violates the terms of service or laws
  7. Legal compliance:
    • responding under laws and regulations
    • cooperating with requests from public authorities

Article 5 (Provision of Information to Third Parties)

We do not provide a User's personal information to third parties except in the following cases.

  1. where the User has consented;
  2. where based on laws and regulations;
  3. where necessary to protect the life, body, or property of a person and it is difficult to obtain the person's consent;
  4. where especially necessary to improve public health or promote the sound development of children and it is difficult to obtain the person's consent;
  5. where a national agency, a local government, or a party entrusted by them needs to perform statutory duties and obtaining the person's consent is likely to impede the performance of those duties;
  6. Provision to entrusted contractors:
    • Within the scope necessary to provide the Service, we may entrust the handling of personal information to the following contractors. In such cases, we conclude appropriate contracts, supervise them, and ensure the secure management of personal information.
    • Payment processing: Stripe, Inc. (Stripe Connect for reward settlement in the Matching Service; Stripe's payment and recurring-billing features for Lingo paid plans (subscriptions))
    • Email delivery: Postmark (Wildbit, LLC)
    • Server and cloud infrastructure: Google Cloud Platform (Google LLC)
    • Access analytics: Google Analytics (Google LLC)

Article 6 (Joint Use of Information)

We do not currently engage in the joint use of personal information. If we engage in the joint use of personal information in the future, we will specify in advance, in this Policy, the items of information to be jointly used, the scope of the joint users, the purpose of use, and the party responsible for management (INNIT LLC).

Article 7 (Use of Cookies, etc.)

We use cookies and similar technologies to improve user convenience and the Service.

  1. Purposes of using cookies:
    • maintaining login status
    • saving user settings
    • analysis of usage (including the use of access-analytics tools such as Google Analytics)
    • measuring clicks on affiliate links and settling performance-based rewards
  2. Use of cookies by third parties:
    • On the Service, third-party ad-delivery operators, affiliate service providers (such as A8.net, ValueCommerce, Moshimo Affiliate, Access Trade, and Rakuten Affiliate), and individual advertisers may use cookies and the like to deliver advertisements according to users' interests and to measure results.
    • These third parties may obtain information on the use of the Service (such as pages viewed, click history, and IP address); we request that such third parties not use such information for purposes contrary to this Policy.
    • For each operator's privacy policy and opt-out method, please check the operator's official page (for example, you can opt out of Google ads at https://adssettings.google.com/).
  3. Disabling cookies:
    • Users can disable cookies through their browser settings; in that case, some features of the Service may become unavailable.

For purposes such as analyzing usage and measuring advertising effectiveness, we may transmit user information (such as pages viewed, IP address, device/browser information, and cookie identifiers) through the browser to external operators (such as Google Analytics and affiliate service providers). The transmission destinations, the information transmitted, and the purposes of use are as set out in this Article and in each operator's privacy policy. Regardless of whether the user is logged in, such transmission may occur from the point at which use of the Service begins.

Article 8 (Management of Personal Information)

We take the following measures to prevent the leakage, loss, or damage of personal information.

  1. Technical measures:
    • use of firewalls and encryption technologies
    • system monitoring to prevent unauthorized access
  2. Organizational measures:
    • appointment of a personal information protection manager
    • education and training of employees
  3. Physical measures:
    • entry/exit control for offices and server rooms
    • appropriate storage of materials and devices

Article 9 (Retention Period of Personal Information)

We retain personal information within the scope necessary for the purposes of use, and after the retention period ends, we dispose of or erase it by appropriate means. The principal retention periods are as follows.

  1. Account information: until a certain period necessary to prevent improper use, etc., has elapsed after withdrawal.
  2. Records relating to transactions and payments: for the period required by relevant laws (up to seven years after the end of the business year to which the transaction belongs).
  3. Learning data of Lingo Guests: until a certain period (approximately 180 days) has elapsed since last access. Where carried over to an account within that period, it follows that account.
  4. Records of consent obtained (such as the version of the terms/policy agreed to and the date and time): may be retained for a substantial period even after withdrawal, in order to verify the history of revisions and to handle disputes.

Article 10 (Rights of Users)

Users have the following rights against us.

  1. to request disclosure of their own personal information
  2. to request correction, addition, or deletion of their own personal information
  3. to request suspension of use or erasure of their own personal information
  4. to request suspension of third-party provision of their own personal information
  5. to withdraw consent

Method of request:

  1. We will respond through our prescribed procedure after verifying identity.
  2. A fee may apply.

Article 11 (Personal Information of Minors)

Where a minor uses the Service, we deem that the consent of a guardian has been obtained. We may, as necessary, confirm the consent of the guardian.

Article 12 (International Data Transfer)

The Service is primarily intended for users in Japan. Including where Lingo and the like are used from outside Japan, we manage users' personal information on servers located in Japan and handle it in accordance with the laws of Japan. Users agree that their personal information is handled in accordance with the laws of Japan.

Article 13 (Changes to the Privacy Policy)

We may revise this Policy from time to time in line with amendments to laws or changes to the Service. Where there is a material change, we will notify users through an announcement on the Service or by email or other means.

Article 14 (Contact)

For questions, consultations, or requests regarding the handling of personal information, please contact the following.

Article 15 (Governing Law and Jurisdiction)

The interpretation and application of this Policy are governed by the laws of Japan. In the event of a dispute relating to the handling of personal information, the Osaka District Court shall be the court of exclusive agreed jurisdiction for the first instance.

End

Created: November 7, 2024　Last updated: June 22, 2026