Privacy Policy

1. Scope and Responsible Party

This Policy describes the handling of information within the App and the server functions provided by Genyoo in connection with the App. The entity responsible for information handling is Genyoo.

The App is designed for users aged 18 and older and does not include functionality to collect date of birth or create user categories for children or teenagers.

The App is primarily designed to store data locally on the device. However, certain functions—including AI chat, editing, explanations, test/lesson generation, billing, and rewarded ads—transmit information to the service’s servers or external services to the extent necessary for functionality provision.

2. Information Stored on the Device

The App may store the following information locally on the device to enable continued learning experiences:

• App settings
• Conversation content
• Learning profile
• Learning progress
• Test/lesson records
• Phrasebook
• Anonymous session identifier and authentication credentials
• Cache used for displaying Prime subscription status and invitation pass status
• State required to verify usage allowance granted via rewarded ads
• Request identifiers, trace information, and other technical information necessary for troubleshooting
• Other information necessary for providing App functionality

These information items are primarily stored within the App’s local data area on the device. For information requiring protection, such as anonymous session authentication credentials, the operating system’s credential protection features are utilized.

The App itself does not use contact or device location permissions. However, advertising partners may estimate approximate geographic location from IP addresses and similar data.

3. Anonymous Sessions and Information Processed on Servers

To provide server functions without requiring account registration, the App uses an anonymous user identifier and session token issued by the server. These are used to identify and authenticate requests to the service’s servers.

The service’s servers may receive or process the following information depending on the function used:

• Content input by the user
• Contextual information from conversations or learning activities
• UI language and learning language
• Grammar profile
• Information regarding learning history or progress
• Type of AI function utilized
• Anonymous user identifier and session authentication credentials
• Information necessary to verify Prime usage rights, product details, purchase status, usage volume, or available allowance
• Information necessary to validate invitation codes and determine eligibility for invitation passes
• Irreversible values for matching conversations, phrases, learning states, settings, and transfer codes; transfer status; expiration; data volume; and integrity verification values when the user explicitly initiates data transfer from an old device
• Advertising unit, anonymous user identifier, processing identifier, and confirmation information received from advertising partners necessary for displaying rewarded ads, server verification, and granting chat usage allowance
• IP address, request timestamp, request destination, response status, processing time, requestId, traceId, AI processing volume, error classification, and other communication and operational information

The server manages Prime usage rights, invitation pass status, usage volume, available allowance, and other server-side states linked to the anonymous user identifier. The information transmitted varies depending on the function used, input content, app state, and user selections.

When a user explicitly initiates data transfer from an old device, the App temporarily stores compressed transfer data—including conversations, phrases, learning states, and settings—in a private Google Cloud Storage bucket in the Tokyo region. The new device sends and receives the transfer data directly to and from that private storage; the service’s server manages transfer status, expiration, target files, volume, integrity verification values, and correspondence with the anonymous user identifier. The original transfer code, original session token, and learning content are not stored in Firestore. Data transfer is not linked to Google, Apple, or email account integration.

4. Purposes of Use and Legal Basis for Processing

Genyoo uses the information it handles for the following purposes:

• Provision of learning functions, conversation practice functions, phrasebook functions, and test/lesson functions
• Adjustment of display and responses according to the user’s learning status
• Generation of AI responses, editing, explanations, and learning questions
• Authentication of anonymous sessions and prevention of unauthorized use
• Purchase, restoration, rights verification, and functionality provision for Prime
• Redemption, usage limit management, expiration, and functionality provision for invitation passes
• Display of rewarded ads, completion verification, prevention of unauthorized use, and granting of chat usage allowance
• Storage of app settings, progress, and history
• One-time data transfer from an old device to a new device explicitly initiated by the user
• Troubleshooting, quality improvement, stable service operation, and security assurance
• Response to inquiries
• Fulfillment of legal obligations and exercise or defense of rights

Where required by applicable law to demonstrate a legal basis for processing, Genyoo relies on contractual necessity for service provision, user consent, legitimate interests relating to prevention of unauthorized use, security, and service improvement, or legal obligations, as appropriate to the processing activity. Processing based on consent may be withdrawn at any time; withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

5. Use of External AI Services

The service’s servers utilize Amazon Bedrock for AI response generation, editing, explanations, and question generation. AI processing occurs in the US West (Oregon) region, and necessary input content and learning context are transmitted from the service’s servers.

Genyoo does not provide user input content or AI-generated output to Amazon Bedrock or model providers for the purpose of training AI models or improving foundational models. Under Amazon Bedrock’s current specifications, inputs and outputs during normal inference are not shared with model providers nor used for foundational model training. However, AWS may perform automated processing or retain data within necessary limits for purposes such as ensuring service security, detecting unauthorized use, and complying with legal requirements.

Genyoo does not enable logging of model invocation logs in the production US West (Oregon) region; therefore, inputs and outputs are not stored in Genyoo’s Amazon CloudWatch Logs or Amazon S3 via this functionality.

The service’s standard server operation logs do not record the full text of user input or AI-generated output. Technical information such as request identification, processing status, processing time, usage volume, and error classification may be recorded for purposes of stable service operation, troubleshooting, prevention of unauthorized use, and security assurance.

The AI models used may be changed as necessary. If there are material changes to external AI services, processing regions, information transmitted, or their handling, this Policy will be updated and, where appropriate, users will be notified.

6. Prime and Payment Information

To obtain Prime product information, process purchases, restore purchases, and verify rights, the App utilizes RevenueCat in conjunction with Apple App Store or Google Play billing systems.

The App uses the anonymous user identifier as RevenueCat’s app user identifier. RevenueCat may process the anonymous user identifier, technical information regarding the device, OS, and app, store receipts or purchase tokens, product information, and other information necessary to verify Prime purchase, restoration, subscription status, and rights.

The service’s server correlates the purchase status confirmed by RevenueCat with the anonymous user identifier to determine available functionality. The App does not store payment method information such as card numbers.

7. Rewarded Ads and Privacy Settings

The App utilizes Google AdMob for rewarded ads that allow limited access to AI chat. The advertising SDK and Google may process device information, app information, advertising identifiers, IP address, approximate location, ad display and interaction data, and other necessary information in accordance with the user’s consent status, device settings, Google’s conditions, and the App’s settings.

The service’s server does not grant chat usage allowance based solely on in-app view completion notifications; it verifies server-side confirmation received from AdMob before granting chat usage allowance to the anonymous user identifier.

Genyoo does not sell user personal information for monetary consideration. However, transmission of advertising identifiers or similar data to Google may constitute “sharing” or targeted advertising under applicable regional laws. Affected users may exercise available choices or withdraw consent via the displayed consent screen or the App’s advertising privacy settings.

8. Invitation Passes

When an invitation pass is used, the service’s server stores: an irreversible value derived from the invitation code; issuance timestamp; expiration date; AI usage limit and number of uses; invalidation timestamp; and, depending on the type of invitation pass, redemption timestamp, number of eligible redemptions, redemption conditions, and the anonymous user identifier of the recipient. The original invitation code is not stored on the server.

These data are used to manage redemption limits, provide functionality via invitation passes, determine usage limits, prevent unauthorized use, enable administrator-initiated invalidation, and respond to inquiries.

9. Voice Input and Permissions

The App may use the device’s microphone or speech recognition permissions for voice input functionality.

Speech recognition processing follows the specifications and settings of the operating system or speech recognition service. Processing, storage, and logging by the OS or speech recognition service are governed by the respective service’s terms or device settings.

Currently, the App does not provide functionality to save recorded audio files locally or transmit raw voice data to the service’s servers.

10. On-Device Translation Preparation Function

On Android, the App may utilize features such as ML Kit, Google Play Services, and OS TranslationManager for translation preparation.

On iOS 18 and later, the App may use Apple’s Translation framework to prepare and perform on-device translation for supported languages. This translation function will not be displayed on iOS versions below 18, unsupported devices, or unsupported language combinations.

Translation model downloads, updates, and on-device preparation may occur as needed, potentially resulting in data usage and storage consumption.

11. Third-Party Processors and International Processing

Genyoo engages or utilizes Amazon Web Services, Google Cloud, RevenueCat, Google, Apple, and other service providers to the extent necessary for functionality provision. Genyoo selects providers, implements contractual protections, restricts access, and conducts other necessary oversight based on the nature and risks of the processed information.

The service’s servers and primary server-side states are processed in the Tokyo region of Japan. AI processing occurs in the US West (Oregon) region. RevenueCat, Google, Apple, and other providers may process information in Japan, the United States, or other countries or regions outside the user’s country of residence.

When data transfer is utilized, compressed transfer data is temporarily stored in a private Google Cloud Storage bucket in the Tokyo region. Processing for storage and transmission is entrusted to Google Cloud.

Where applicable law requires protective measures for international transfers, Genyoo employs adequacy decisions, Standard Contractual Clauses, Data Processing Agreements, or other available lawful transfer mechanisms as appropriate to the processing activity.

12. Retention Period and Deletion

Information stored on the device is retained for as long as the user utilizes the App’s functionality or until the user deletes it. Handling of data associated with App deletion, OS backup, or device restoration follows OS specifications and user device settings.

Server-side states linked to the anonymous user identifier are retained for as long as necessary for service provision or until the user executes “Delete Service Data.” If retention becomes unnecessary due to service termination or other reasons, information is deleted or anonymized except as required by law, for prevention of unauthorized use, or for exercise or defense of rights.

Standard server operation logs are retained for 30 days from the date of recording. In cases involving security incidents, unauthorized use, legal obligations, or disputes, targeted data may be retained for as long as necessary.

Email addresses, inquiry content, device/OS/app information, error details, requestId, traceId, and similar data received during inquiries are retained for one year after inquiry resolution, unless retention is required by law or for dispute resolution.

Temporary data for data transfer is subject to a contractual limit of 30 minutes from code issuance to input, and an additional 30 minutes after valid code acceptance. Data is deleted upon success, expiration, cancellation, reaching the maximum number of code inputs, or integrity mismatch. Failed deletions are retried, and an automatic deletion is scheduled one day after creation to account for potential manual deletion omissions. Data on the old device is not deleted until transfer is confirmed; upon confirmation, the old device is reset to its initial state. Data transfer does not cancel or delete Prime recurring purchases or purchase records in Apple App Store or Google Play.

Users may delete server-side usage status linked to the current anonymous user identifier and App data and anonymous session authentication credentials stored on the device via the “Delete Service Data” option in settings. Deletion returns the App to its initial state and cannot be undone.

The customer record in RevenueCat associated with the current anonymous user identifier is also subject to deletion when Service Data is deleted. However, Prime recurring purchases in Apple App Store or Google Play are not canceled, and purchase records in each store are not deleted. To terminate Prime recurring purchases, users must separately cancel subscriptions via the respective store’s subscription management interface before or after deletion.

Information not linked to the anonymous user identifier—including records for unauthorized use prevention, purchase records managed by each store, OS speech recognition services, translation models, device backups, and other information not directly managed by Genyoo—may not be subject to deletion under Service Data deletion. If Genyoo receives a request to delete information retained by external services, Genyoo will take necessary actions or procedures in accordance with applicable law and agreements with providers.

13. User Rights and Choices

Users may, to the extent permitted by applicable law, request notification of the purpose of use, disclosure or copy of their information handled by Genyoo, correction, addition, deletion, restriction or cessation of use, cessation of provision to third parties, data portability, objection to processing, withdrawal of consent, or other similar requests.

To make such a request, please contact the designated inquiry channel. Genyoo may require the user to provide anonymized user identifiers, requestId, traceId, purchase information, and other minimum necessary information, or to undergo identity verification, in order to identify the relevant information and prevent fraudulent requests. If Genyoo is unable to respond to all or part of the request due to reasons permitted under applicable law, it will explain the reason.

Users residing in the European Economic Area, the United Kingdom, or other regions recognized under applicable law may have the right to lodge a complaint with the data protection supervisory authority responsible for their place of residence. Users residing in applicable U.S. states may, depending on applicable law, have the right to confirm, correct, or delete information, exercise data portability, opt out of the sale, sharing, or targeting of information for advertising, or object to the outcome of a request.

14. Security Measures

Genyoo implements security measures appropriate to the nature and risks of the information handled, including the following:

• Encryption of communications between this application and the service servers
• Utilization of the operating system’s credential protection features for anonymized session authentication credentials
• Restriction of access permissions to servers, databases, and external services
• Segregation of confidential information, proper management of authentication credentials, and implementation of least-privilege access controls
• Limitation of information recorded in operational logs and establishment of retention periods
• Selection, contracting, and necessary oversight of external service providers
• Operational procedures to detect and respond to defects, failures, or security incidents

15. Inquiries and Business Information

Information Handling Operator: Genyoo

Privacy Inquiry Contact: [email protected]

Location and other matters required by law to be made known to the individual may be requested via the above inquiry channel. Genyoo will respond without undue delay in accordance with applicable law after verifying the content of the request.

When making an inquiry, Genyoo may handle information such as email address, inquiry content, device information, OS version, application version, error details, requestId, traceId, and other information necessary for investigation and response.

Do not transmit passwords, confidential information, unnecessary personal information, personal information of third parties, or confidential information.

16. Amendments

This policy may be amended in response to changes in applicable law, service content, or information handling practices. In the event of material changes, Genyoo will provide clear notice prior to implementation, either within the application or on a public page, and will obtain consent where required by applicable law.