Privacy Policy

The Japanese-language version is the authoritative text (see Section 15). The enactment date and the date of the most recent revision are not yet determined.

Summary (the formal provisions begin at Section 1)

1. Introduction

Kento Ito ("we," "us," or "our") establishes this Privacy Policy ("this Policy") to govern the handling of personal information and other privacy-related information of users ("Users") of the iOS application "Watagumo" (the "App").

The App handles records of Users' extremely private conversations. We recognize that this information requires special care, and we design and operate the App giving priority to privacy and safety over adding new features.

Users are asked to agree to this Policy when they first start using the App. If you do not agree, you will not be able to use the App.

2. Information We Collect

2.1 Account information

The App's only authentication method is "Sign in with Apple." No password is ever set or stored.

We do not store the Apple user identifier in its original form; we convert it into a form that cannot be reversed (a hash value) before storing it. We do not collect names or email addresses. Even if you choose to share or not share your email address through "Sign in with Apple," we do not store that value.

2.2 Information related to imported conversation history

Users can load conversation history files that they have exported themselves from LINE, WhatsApp, KakaoTalk, and similar services into the App.

The original conversation history file (the file itself) is processed on the user's device and is never sent to or stored on our servers. After analysis on the device, only the following is sent to our servers.

The extracted portion (sample) of the conversation includes statements made by third parties who appear in the conversation. After import, any temporary working files created on the device are deleted regardless of whether processing succeeds or fails. Original files remaining in the source app (such as LINE) or in the Files app are the user's own responsibility to manage and delete.

2.3 Information about AIs created from user input

Instead of using conversation history, users can also create an AI by entering text describing the other person's name, way of speaking, relationship, and topics of conversation. In this case, the content entered by the user is sent to and stored on our servers.

2.4 Chat information

Chat content is stored on our servers so that conversation history can be viewed again later. It is also retained as a cache on the device for a certain period to allow offline viewing.

2.5 Purchase and billing information

Payment method information such as credit card numbers is processed by Apple. Neither we nor RevenueCat ever collect it.

About purchase data being passed to RevenueCat (a third party). The App's billing infrastructure (purchase UI and receipt processing) uses RevenueCat, Inc. When you purchase tickets or subscribe, purchase transaction information issued by the Apple App Store (product ID, purchase date and time, transaction ID, auto-renewal status, etc.) reaches our servers via RevenueCat, Inc. (through a RevenueCat webhook notification). RevenueCat's role is limited to notifying us that a purchase has occurred based on this information; the granting, consumption, and balance management of tickets continues to be handled by our own servers (the balance itself is never entrusted to RevenueCat). Payment method information such as credit card numbers is processed by Apple and is never passed to us or to RevenueCat. Please refer to RevenueCat's own website for its privacy policy.

2.6 Device and usage information

Our application logs never record the content of conversations, AI display names, entered profile text, file names, or similar content. However, Cloudflare's platform-level access logs record IP addresses and similar information for a certain period, in accordance with their own specifications.

2.7 Information we do not collect

For clarity, we state here what we do not collect.

• Name, date of birth, gender, address, phone number
• Email address (except when you contact us)
• Location data, contacts (address book), calendar, entire photo library
• Advertising identifier (IDFA), and tracking for advertising purposes
• Continuous access to the device microphone or camera

3. How Information Is Collected

• Direct input and actions by the user (sign-in, file selection, AI creation, sending chat messages)
• Automatic collection incidental to use of the App (IP address, app version, error information)
• Provided by Apple (user identifier at sign-in, purchase transaction verification results)

The App does not use cookies or tracking technologies for advertising purposes. Nor do we purchase or obtain information from third-party data brokers or similar sources.

4. Purposes of Use

We use the information we collect only for the following purposes.

We do not do the following.

• Sell the information we collect
• Use the content of conversations for advertising targeting
• Read the content of conversations ourselves for our own enjoyment, or show it to third parties (except at a user's explicit request for the purpose of investigating an issue)
• Use conversation content we have collected to train our own AI models

5. Disclosure to and Entrustment with Third Parties

5.1 Business operators we use to provide the service

The above are business operators to whom we entrust the handling of information under conditions we set.

5.2 About sending conversation data to OpenAI

To provide the App's core features — "creating an AI" and "talking with an AI" — we send a portion of the user's conversation data to an API provided by OpenAI, L.L.C.

Information not sent: The original file or full text of imported conversation history files; account-identifying information such as the Apple user identifier or internal user ID; purchase information; IP address.

Data sent is handled in accordance with OpenAI's privacy policy and API terms of use. We use OpenAI's API under settings and conditions under which our API usage is not used to train OpenAI's models. OpenAI may retain sent data for a certain period for purposes such as monitoring for misuse; the retention period and conditions are as determined by OpenAI. There are limits to our ability to have data stored on OpenAI's side deleted, and deletion of data on our own servers (Sections 7 and 8) does not automatically extend to records on OpenAI's side.

As described above, the content of your conversations with the AI through the App is sent to OpenAI. Please keep this in mind, and avoid entering information you would not want sent.

5.3 Disclosure required by law

We may disclose information to the extent necessary, only where required by law, or where necessary to protect a person's life, body, or property and it is difficult to obtain the user's consent.

5.4 Business transfer

Information may be transferred in connection with a business transfer, merger, or similar event. In that case, the transferee will be required to handle the information in a manner equivalent to this Policy.

6. International Transfers

Data for the App is stored and processed on servers located outside Japan.

By using the App, users are deemed to consent to these international transfers. Personal information protection systems in other countries may differ from those in Japan. For an overview of the protective measures taken by each operator, please refer to the information published by each company.

6.1 Regions where the App is offered

The App is currently offered only in the following 8 regions: Japan / Taiwan / South Korea / United States / Canada / Australia / New Zealand / Singapore.

The App is not currently offered in the EU (European Union), the EEA (European Economic Area), or the UK. This is because the App's coverage is geographically aligned with the regions supported by the provider of the AI API the App relies on, and use outside that provider's supported regions may result in the service being suspended under that provider's terms. The regions offered may change in the future. Please check the App Store listing for the most current information on regions offered.

7. Retention Period and Deletion

7.1 Retention period

7.2 How to delete data

Users can perform the following actions at any time from within the app.

A confirmation screen is shown before any of these actions is carried out. Deletion is processed asynchronously. When you perform an in-app action, we first complete acceptance of the deletion request; the actual deletion processing then proceeds in the background afterward. While processing is underway, the app shows "Deleting…" After deletion processing is complete, we automatically verify that nothing subject to deletion actually remains. The app will not show "Deleted" until this verification is complete. If verification reveals that something subject to deletion still remains, deletion processing is automatically retried.

The on-device cache is also discarded upon account deletion or logout. Deleting your account does not automatically cancel your App Store subscription. You must cancel separately through iOS Settings. This is also indicated on the account deletion confirmation screen.

7.3 Information that remains even after deletion

7.4 Removal from backups

For disaster recovery purposes, our database has a mechanism that allows restoration to a point within a certain past period. Because of this, it may take a certain number of days after a deletion is carried out before the corresponding record on backups is removed. During this period, the data in question is never used to provide the service in the ordinary course.

8. User Rights

Users have the following rights regarding their own information.

We generally respond to requests within a reasonable period. For identity verification, we plan to use methods such as presenting information displayed on the in-app settings screen. Users residing in the EU, the UK, and similar jurisdictions may separately be entitled to rights such as data portability, restriction of processing, and lodging a complaint with a supervisory authority.

9. Security

We take the following measures to protect the information we collect.

• All communications are encrypted (HTTPS)
• To ensure that only the authenticated user can access their own data, the user's identity is enforced server-side for every data operation
• Sensitive information such as the OpenAI API key is never included in the app itself (it is all managed server-side)
• Login information (tokens) is stored in the device's Keychain and is not synced to other devices or backups
• Our server-side logs are designed not to record the text of conversations or personally identifiable information
• We have implemented limits to prevent excessive access and misuse

That said, we cannot guarantee complete security for communications over the internet or for electronic storage.

9.1 About managing your device (an important request)

The App also retains conversation content on the user's device for a certain period. We ask that you protect the device itself, for example by setting a passcode or enabling Face ID. If your device is lent to a third party, the content of the App may be viewed by that person. Also, due to how iOS works, the App cannot prevent screenshots from being taken.

10. Use by Minors

• The App is intended for users 17 years of age or older.
• We do not intentionally collect information from anyone under the age of 13.
• If a minor uses the App, they should do so only with parental consent.
• If we discover that we have collected information from someone under 13, we will promptly delete that information. If you believe this may apply, please contact us at the address in Section 12.

11. Cookies and Tracking

• The App is a native app and does not use cookies for advertising purposes.
• We do not perform cross-app or cross-website tracking that would be subject to App Tracking Transparency (ATT). Accordingly, no tracking permission dialog is shown.
• Only information used to maintain login state and improve display speed is stored on the device.

12. Contact

For inquiries regarding this Policy and the handling of personal information, please contact us at the following.

13. Changes to This Policy

We may revise this Policy in response to changes in law or in the App's content. If we make a change that has a material effect on users' rights, we will provide notice, such as through an in-app notification, before the change takes effect. If you continue using the App after a change takes effect, you are deemed to have agreed to the revised content. If you do not agree, please delete your account and discontinue use.

14. Notes on AI-Generated Content

The following is outside the scope of this Policy but is noted here as an important matter.

• The AI created through the App is a character generated from conversation history or user input, and is not the actual specific person.
• What the AI says does not represent the intentions, statements, or views of any real person.
• Content generated by the AI may include information that differs from fact.

15. Governing Law

The interpretation and application of this Policy are governed by the laws of Japan.