Privacy Policy

This English translation is provided for reference only. The Japanese version is the governing version; if there is any discrepancy, the Japanese version prevails.

Sakakikaen Co., Ltd. (hereinafter, the "Company") handles the personal information and personally referable information of Users of the Service as set out below, in accordance with the Act on the Protection of Personal Information of Japan (APPI) (hereinafter, the "APPI") and other laws and regulations.

1. Information We Collect

The Company collects the following information.

  1. Registration information: name and nickname, e-mail address, authentication credentials used in place of a password, identifiers, name, e-mail address and profile image provided by external services (such as Google), year of birth and age group, occupation, country or region of residence, language used, and the examinations the User plans to take and when the User plans to take them
  2. Payment-related information: the details and history of subscriptions, the country and postal code of the billing address, and the customer IDs and transaction IDs issued by the payment service provider (credit card numbers are collected by the payment service provider and are not retained by the Company)
  3. Learning data: the questions answered, the answer options selected, whether the answers were correct or incorrect, the time taken to answer, the dates and times, number of times and duration of study, saved questions, the history of incorrect answers, the history of viewing and operating the study notes and diagrams, goal settings, and changes in results over time
  4. Usage information: dates and times of access, pages viewed, operation history, referrers, search terms, and error records
  5. Device and communication information: IP address, device type, OS, browser, language settings, screen size, cookies and other identifiers, and approximate location (as estimated from the IP address)
  6. Inquiry information: the content of inquiries, records of correspondence, feedback, and responses to surveys
  7. Corporate plan information: the name of the contracting organization, the name and contact details of the person in charge, and the names, affiliations, e-mail addresses and learning status of the learners

Where a User logs in with an external account (Google, Apple or Microsoft), the Company receives from that provider the User's e-mail address, name and the identifier assigned to the User by the provider, and uses them for creating the account, verifying the User's identity and logging in. The Company does not receive the password for the provider.

Where a User logs in with a Google account, the Company receives and stores the items Google provides within the standard scopes (openid, email and profile): the Google user ID, the e-mail address and whether it is verified, the name (given name and family name), the profile picture URL, the language setting (locale) and the Google Workspace domain (if any). The Company does not obtain additional items such as date of birth, gender or address from Google.

Learner attributes and answer records: Before starting to study, the Company asks Users to choose their age group, gender and area of residence (a prefecture of Japan or outside Japan); "Prefer not to say" may be chosen for each item. The Company also obtains the country and region estimated from the IP address and the answer records (questions answered, options chosen, whether correct, and date and time). These are used to improve questions and explanations and to produce statistics such as accuracy by age group, gender and region. The Company does not publish them in a form that identifies individuals and does not provide them to third parties except in the cases set out in Section 3. Statistics are handled only with small groups (fewer than 5 people) hidden.

2. Purposes of Use

The Company uses the information it collects for the following purposes.

  1. Providing the Service, verifying identity, logging in, managing subscriptions, billing fees, and activating the app
  2. Saving learning records, synchronizing across devices, analyzing results and weak areas, marking items for review and in the study notes, and presenting recommended questions and study plans
  3. Responding to inquiries, and sending important notices and notifications of changes to the terms and the like
  4. Improving the quality, content and functions of the Service: verifying and correcting the accuracy of questions and explanations, adjusting the level of difficulty and the distribution of questions, improving screens and usability, and investigating defects
  5. Research and development of new services, products and content: planning and producing question banks for new examinations and qualifications, developing new functions, and market research
  6. Use of artificial intelligence and machine learning: The Company uses learning data and usage information, in statistically processed or pseudonymized form, for the development, training, evaluation and improvement of models for the following purposes.
    • Automatic creation and automatic marking of questions
    • Prediction of weak areas
    • Optimization of learning
    • Improvement of translation quality
    • Detection of fraudulent use
  7. Creating statistical information (in a form that does not identify individuals), and publishing it and using it in sales materials and advertising (for example, the average rate of correct answers across all Users, and topics that are frequently answered incorrectly)
  8. Providing information on the Company's services, products, campaigns and new examinations (e-mail newsletters and push notifications can be stopped at any time)
  9. Under a corporate plan, reporting the learning status of learners to the contracting organization
  10. Preventing and investigating fraudulent use and violations of the terms, ensuring security, responding to disputes, and protecting rights
  11. Responding as required by laws and regulations
  12. Purposes incidental to the above purposes

3. Provision to Third Parties

The Company does not provide personal data to third parties without the consent of the individual concerned, except in the following cases.

  1. Where required by laws and regulations
  2. Where it is necessary for the protection of the life, body or property of a person and it is difficult to obtain the consent of the individual concerned
  3. Where it is particularly necessary for improving public health or promoting the sound upbringing of children and it is difficult to obtain the consent of the individual concerned
  4. Where it is necessary to cooperate with a national government organ or the like in performing affairs prescribed by laws and regulations
  5. Where the handling of personal data is entrusted to the extent necessary to achieve the purposes of use (Section 4)
  6. Where personal data is provided in connection with the succession of business due to a merger, company split, business transfer or other cause
  7. Under a corporate plan, where the learning status of learners is provided to the contracting organization (learners are deemed to have consented to this by using the corporate plan)

4. Entrustment of Handling and Provision to Third Parties in Foreign Countries

  1. For the operation of the Service, the Company entrusts the handling of personal data to the following business operators and the like. The entrusted parties include business operators located in foreign countries (mainly the United States).
    • Cloud, database, delivery and prevention of unauthorized automated access (Cloudflare Turnstile): Cloudflare, Inc. (United States)
    • Payment: Stripe, Inc. (United States) and the distribution operators of each app store
    • Access analysis (Google Analytics) and login: Google LLC (United States). Login: Apple Inc. (United States) and Microsoft Corporation (United States)
    • E-mail delivery: e-mail delivery service providers (United States and other countries)
    • Artificial intelligence (reading of documents, creation of questions, translation, support and the like): Anthropic, PBC (United States) and other AI service providers
  2. Where the Company provides personal data to a third party in a foreign country, the Company takes one of the following measures pursuant to Article 28 of the APPI.
    • Obtaining the consent of the individual concerned
    • Confirming that the recipient has established a system conforming to the standards prescribed by the rules of the Personal Information Protection Commission
  3. The name of the recipient's country, information on that country's system for the protection of personal information, and information on the measures taken by the recipient are set out in "Information on Foreign Systems" at the end of this Policy (in the case of the United States, there is no comprehensive personal information protection law at the federal level, and protection is provided by state laws and sector-specific laws and regulations).
  4. Users are deemed, by registering to use the Service, to have consented to the provision to third parties in foreign countries described in the preceding items.

5. Pseudonymized Information and Anonymized Information

  1. The Company may create pseudonymized information as defined in the APPI from learning data and usage information, and use it within the Company for the purposes set out in items 4 through 7 of Section 2.
  2. Where the Company has created anonymized information, it will publicly announce the items of information created. Where the Company provides anonymized information to a third party, it will publicly announce the items of information to be provided and the method of provision, and will clearly indicate to the recipient that the information is anonymized information.
  3. Statistical information (information from which any correspondence with a specific individual has been eliminated) does not constitute personal information, and the Company may freely use, publish and provide it.

6. Cookies and Analytics Tools

  1. The Service uses cookies, local storage and the like to maintain login status, save settings and analyze usage. At present, the Service does not use cookies or advertising identifiers for the delivery of third-party advertising.
  2. The Company loads typefaces from "Google Fonts" of Google LLC in order to display text on the screens. When a screen is opened, the user's IP address and browser type, etc. are sent to the servers of Google LLC in order to retrieve the font files. No cookies are used for this.
  3. On screens such as those for the introduction of the Service, pricing, login and initial guidance (excluding the screens for answering questions and the study notes; on the portal, only the screen shown after completing a paid-plan order), the Company uses "Google Analytics" of Google LLC in order to understand usage and improve the service. When these screens are opened, the URL and title of the page viewed, the referrer, the type of device and browser, the screen size, the language, the approximate region, identifiers stored in cookies and the like, and the IP address are sent to Google. The Company does not send names, e-mail addresses or the content of answers to Google Analytics. The information sent is handled in accordance with Google's Privacy Policy (https://policies.google.com/privacy). The sending of information can be stopped by using the opt-out add-on provided by Google (https://tools.google.com/dlpage/gaoptout) or through browser settings. In addition, the Company runs Google Ads and imports Google Analytics events into Google Ads in order to attribute sign-ups, trial starts and paid-plan purchases to ad clicks (this uses cookies of Google LLC; from October 13, 2026). These events are not used for personalized advertising. This is not done in the iOS app or for access from the EU, EEA, the United Kingdom or Switzerland. For access from the EU, the EEA, the United Kingdom and Switzerland, measurement is performed with a setting that does not store cookies for analytics or advertising.
  4. The Company advertises the Service through "Google Ads" of Google LLC. To measure the effectiveness of advertising, for users who visit the Service by clicking an advertisement, the Company sends the completion of registration, the start of trial questions and the completion of a paid-plan order to Google Ads through Google Analytics (linked to the click by identifiers stored in cookies and the like). Names, e-mail addresses and the content of answers are not sent. This is not used for personalized advertising. It can be stopped through Google's Ads Settings (https://adssettings.google.com/) or browser settings. Inside the iOS app, this advertising measurement is not performed. Measurement in the iOS app is limited to understanding how screens are used (Google Analytics); it is not used to deliver or personalize advertising or to measure advertising conversions, and no advertising identifier (IDFA) is collected (Google's advertising signals are disabled).
  5. In order to prevent unauthorized automated access (bots and the like), the Company uses "Cloudflare Turnstile" of Cloudflare, Inc. on the screens for account registration, sign-in, sending of verification codes and inquiries. In doing so, information on the User's device, browser and connection (such as the IP address) is sent to Cloudflare. Cloudflare Turnstile is intended to confirm whether an operation is performed by a human; it does not fall under the analytics tools referred to in the preceding item, and the Company does not use it for the delivery of advertising or the analysis of usage.
  6. For the free IELTS Speaking try (one question, no sign-up), the Company sends the audio recorded by the user to "Workers AI" of Cloudflare, Inc. to transcribe it, and sends the transcript to Anthropic, PBC to produce an estimated score and advice. The audio and the transcript are not stored after the result is returned. To prevent repeated use, the Company records only the time of use and a non-reversible value derived from the IP address.
  7. On the free trial screens (10 questions available without registration), we record on our own servers a random identifier generated by the browser (cleared when the tab is closed; not a cookie), the exam, the type of action, the question number, the language and the approximate country, in order to understand how far each exam's trial is used and to improve the Service. We do not record names, email addresses, IP addresses or whether answers were correct.
  8. Cookies can be disabled in the browser settings; however, in that case, part of the Service may not be available.

7. Security Control Measures

The Company takes the following measures to prevent the leakage, loss or damage of personal data and otherwise for its security control.

  1. Establishment of rules on handling
  2. Training of workers
  3. Access control
  4. Encryption of communications
  5. Supervision of entrusted parties
  6. Measures taken in light of foreign systems

The Company will respond regarding the main details upon request, to the extent provided by laws and regulations.

8. Retention Period

The Company retains personal data for the period necessary to achieve the purposes of use. Handling after withdrawal from membership is as follows.

  1. Registration information and learning data: As a general rule, within one year after withdrawal, these are deleted or processed into a form that does not identify individuals. Where the user withdraws by using “Delete account” in My Portal (also available in the apps), these are deleted at the time of that procedure (payment records used for sales totals are kept in a form that is not linked to the individual).
  2. Records of payments and transactions: These are retained for the period for which retention is required by laws and regulations.
  3. Information necessary for the prevention of fraudulent use: This is retained for the period necessary.
  4. Processed information: The pseudonymized information and statistical information referred to in Section 5 may be retained and used without limitation of period.

9. Requests for Disclosure and the Like

An individual may make the following requests with respect to his or her retained personal data held by the Company. The Company will, after confirming the identity of the individual through the procedures prescribed by the Company, respond without delay in accordance with laws and regulations.

The Company may charge a fee of JPY 1,000 per request for disclosure.

10. Information of Minors

Persons under 16 years of age are asked to use the Service and provide personal information only after obtaining the consent of a person with parental authority or other legal representative.

11. Additional Provisions for Users Outside Japan

  1. Persons in the EU, the EEA and the United Kingdom (GDPR and UK GDPR)
    • Legal bases for processing: The Company processes personal data on the basis of the performance of a contract, legitimate interests (improvement of the service, prevention of fraud, and statistics), consent (information by e-mail, use for the development of AI, and certain analytics), and legal obligations.
    • Rights of the individual: Individuals have the rights of access, rectification, erasure, restriction of processing, data portability, objection and withdrawal of consent, and the right to lodge a complaint with a supervisory authority.
    • Transfers outside the region: Personal data is transferred to Japan and the United States. Japan has received an adequacy decision from the EU. Transfers to the United States are made on the basis of standard contractual clauses or other appropriate safeguards.
  2. Persons in the State of California, United States (CCPA/CPRA)
    • The Company does not "sell" personal information for monetary consideration.
    • The Company does not "share" personal information for cross-context behavioral advertising.
    • Individuals have the right to know, the right to delete and the right to correct, and the Company will not discriminate against any individual for exercising these rights.
  3. Persons in China, Korea and other countries and regions: To exercise rights under the laws and regulations of each country, please contact the inquiry desk.

12. Changes to This Policy

The Company may change this Policy due to changes in laws and regulations, changes to the Service or other reasons. In the event of a change, the Company will give notice on the Service. Where the change is one for which the consent of the individual is required by laws and regulations, the Company will obtain consent anew.

13. Inquiry Desk

Sakakikaen Co., Ltd. Personal Information Inquiry Desk

Address: 1747 Heda, Numazu-shi, Shizuoka 410-3402, Japan

Representative Director: Hirofumi Inagi

E-mail: contact@sakakikaen.com

Information on Foreign Systems (Main Recipient Country: United States)

Established: October 6, 2026
Revised: October 13, 2026 (added Google Ads conversion measurement to section 6; stated that no advertising-related measurement is performed in the iOS app; section 8: added deletion upon withdrawal from the account screen; October 9, 2026: added handling of audio for the Speaking try; October 7, 2026: added Google Ads conversion measurement; October 6, 2026: added learner attributes, country and region estimated from IP addresses, and Google account items)

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