E-MANABU Privacy Policy
Effective Date: August 3, 2024
Enforcement Date: September 10, 2024
Article 1: Personal Information
Article 2: Scope of Application
Article 3: Collection and Use of Personal Information
Article 4: Transfer and Disclosure of Personal Information
Article 5: Storage of Personal Information
Article 6: Use of Cookies and Similar Technologies
Article 7: Security Protection of Personal Information
Article 8: Management of Personal Information
Article 9: Recommendations
Article 10: Minor Provisions
Article 11: Revisions and Notifications
Article 12: Contact Information
Article 1: General Provisions
Rakki Japan Co., Ltd. (hereinafter referred to as "the Company") recognizes that personal information is of great importance to users of E-MANABU (hereinafter referred to as "the Service" in this Privacy Policy). The Service is committed to protecting users' personal information and privacy in accordance with laws and regulations, referencing industry best practices. This Privacy Policy has been established to emphasize the following points: users are encouraged to read, understand, and make appropriate judgments regarding this Privacy Policy before using E-MANABU and related services.
The Service places a high priority on the protection of children's personal information and has established "Guidelines for the Protection of Children's Personal Information" concerning the rights of children under the age of 14. Users should take special care in this regard. Hereinafter, "users" refers to the guardians of users under the age of 14 or users aged 14 and older, unless otherwise specified.
The Service will collect and use users' information in accordance with this Privacy Policy; however, simply agreeing to this Privacy Policy does not mean that personal information will be collected in bulk. When users utilize or enable related functions, the Service will collect and use the information necessary to implement those functions and services. Users can refuse to provide information that is not required for basic business functions or necessary under laws and regulations without affecting other functions or services. The Service will explain the information collected in detail within this Privacy Policy.
If users wish to use only the basic functions of E-MANABU, they can use the Basic Function Mode. In this mode, the Service will only collect the personal information necessary for the secure operation of the software and services based on laws and regulations. In Basic Function Mode, users will not be able to register, log in, purchase courses, attend classes, or participate in events.
If users are not logged into their accounts, the Service will ensure basic information push functions through identification information corresponding to the device. If users are logged into their accounts, the Service will implement information push based on their account information.
To realize business functions or as required by laws and regulations, the Service may collect and use users' sensitive personal information when using specific functions or services. For details on specific collection scenarios, purposes, and scope, please refer to the list of sensitive personal information.
Permissions for the camera, microphone, album (storage), etc., are not enabled by default and will only be used to realize specific functions or services with the user's explicit consent. Users can also withdraw their consent. It is particularly important to note that even if the Service obtains these sensitive permissions with the user's consent, it will not collect users' information unless necessary for related functions or services. For specific permission requests and usage status, please refer to the explanation of permission requests and usage status in the E-MANABU application.
This Privacy Policy applies when users access and use the products and services of the Service through the E-MANABU application, the official E-MANABU website, third-party websites, and applications that use the E-MANABU Software Development Kit (SDK) and Application Programming Interface (API). If users use specific services provided by the Service or its affiliates, and those services have their own privacy policies, the privacy policy applicable to those services or products will apply. If there is no separate privacy policy, this Privacy Policy will also apply to that portion of the products or services.
Article 2: Scope of Application
This Privacy Policy applies to all personal information acquired by the Company and the Service, regardless of region or country. The Company may use special privacy policies for specific services. These special privacy policies apply to those specific services and outline the acquisition, use, provision, and other aspects of personal information related to those services. In the event of any conflict between a special privacy policy and this Privacy Policy, the special privacy policy shall take precedence over this Privacy Policy.
The Company's Privacy Policy is available in multiple languages. To the extent permitted by applicable law, the Japanese version applies to users in Japan, the Chinese version applies to users in China, and the English version applies to users in other countries and regions.
Article 3: Collection and Use of Personal Information
The Service collects information that users voluntarily provide when using the service, as well as information generated during the use of features or services, which is collected through automated means. Information is collected in accordance with the following provisions during each service process.
3.1 Registration and Login
Users can create an account within E-MANABU using their phone number or email address when registering or logging in to E-MANABU and related services. Users may also supplement relevant network identity identification information (avatar, nickname). This information is collected to assist users in completing their registration. The phone number is necessary for network identity requirements. If users cannot provide a phone number for registration or login, the Service will be unable to create the user’s account, and the user will not be able to use services closely related to the account, such as purchasing courses. However, this does not affect the use of other basic functions of E-MANABU. After registering or logging into their account, users can fill in personal information (avatar, nickname, self-introduction) and select their preferences. The Service collects voluntarily provided personal information from users to display it to other users and provide content.
Users may also log in to E-MANABU using a third-party account. With the user’s consent, the Service will obtain relevant public information (avatar, nickname, and other information permitted by the user) registered on the third-party platform, link it with the E-MANABU account, and allow users to log in directly and use the product and related services.
After registering an account, users can set up their child’s avatar (the Service will request camera and album permissions to implement the avatar setting function), nickname, and personal introduction to facilitate communication between the child and the teacher. This information is collected to further facilitate communication between children and teachers and to provide courses more suitable for children. Users can also refuse to provide avatar, nickname, and personal introduction information.
3.2 Course Participation
When using E-MANABU's online live course feature (including live course video playback), the Service will request camera and microphone permissions to better resolve learning-related questions that course participants may have regarding the course content. The Service will record the video and audio content of the course participants' communications with teachers. Additionally, for educational analysis and quality improvement, the Service allows teachers conducting courses to view students' videos and spoken content. Users can contact the Service through the contact information provided in this Privacy Policy to refuse or withdraw permission for the above information collection. If users refuse or withdraw consent, the Service will stop processing the relevant information, and course participants will not be able to receive related services, but this will not affect the use of other functions of E-MANABU.
To ensure the safety of course content, the Service adheres to the principle of minimum necessity and strictly controls the permissions and scope, arranging for specialized staff to conduct safety checks on course content. Staff will review the videos and spoken content of course participants. If any content violates laws and regulations, the Service will promptly take action in accordance with regulations.
The Service may also have specialized staff review the videos and spoken content of course participants for educational quality assessment and learning situation analysis, strictly controlling the permissions and scope. Users can contact the Service through the contact information provided in this Privacy Policy to refuse or withdraw permission for the above information processing. If users refuse or withdraw consent, the Service will stop processing the relevant information, and users will not be able to receive related services, but this will not affect the use of other functions of E-MANABU.
To assist course participants with post-course review, the Service provides users with the ability to download course materials. Course materials may include names and photos of some course participants, as well as subsequent assignments. Other users may view this information when using this feature. Course materials are created by teachers, and if the disclosure of the aforementioned names, photos, and assignments is included during the creation process, teachers will do so with the user’s consent or permission. If users do not want the aforementioned information to be seen by other users, they should not provide this information to teachers. If users wish to withdraw their consent or permission, they should contact the Service. The Service will promptly notify the relevant teacher and remove the information from the course materials. However, the decision to withdraw consent or permission will not affect any disclosures that have already occurred based on the user's consent.
When users take courses using E-MANABU, the Service may access the device's sensors (gravity sensor, rotation vector sensor, gyroscope, accelerometer, magnetic sensor, etc.) to adapt to the state of the user's device, identifying whether the device is in landscape or portrait mode for easier viewing of the course.
When users use E-MANABU, the Service will request storage permissions to record and display users' learning preferences, other settings related to product functions, and cached learning information (e.g., words added to a vocabulary list, English learning videos). If users refuse to provide this information, they will not be able to use this feature, but this will not affect the use of other functions of E-MANABU.
3.3 Playback and Viewing
To ensure the quality of recommended content and push courses and related information that users may find interesting, E-MANABU may collect relevant necessary log information.
The log information mentioned above may include feedback, comments, and user operation and usage behavior information such as views, clicks, searches, and purchases that users voluntarily provide.
Users have the right to voluntarily turn on or off personalized recommended content. For details, please refer to Article 6.2 of this Privacy Policy.
3.4 Information Dissemination and Interaction
3.4.1 Information Dissemination
When users comment, the Service collects the information posted by users and displays the user's nickname, avatar, post content, and information.
When users use the feature to disseminate assignments or works through E-MANABU, the Service collects the assignment content posted by users to optimize the service. The Service will also display the assignment content to other users to promote the sharing and interaction of learning outcomes. With the user's consent, the Service may publish the assignment content uploaded by users to enhance their experience with the service.
Users can use the feature to disseminate images, audio, video, or assignments through E-MANABU. When users use these features, the Service will request permissions for the camera, album (storage), and microphone. If users refuse to provide these permissions, they will not be able to use this feature, but this will not affect the use of other functions of E-MANABU.
By using the products or services of the Service, the information collected may include some of the user's information contained in information disseminated by other users (e.g., comments, messages, information related to images, audio, and video).
In accordance with relevant legal and regulatory requirements, to maintain a truthful and orderly platform, build a healthier and higher-quality network ecosystem, and reduce malicious acts such as imitation, rumors, and misuse of traffic, when users use information disclosure features such as notes, the platform will display the user's information dissemination location in the content posted by users. Specifically, this will be displayed up to the province (district, city) level domestically and to the country (region) level internationally, based on the data of the network operator.
3.4.2 Message Notifications
Users understand and agree that the Service may send various notifications to the user's contact information (such as phone numbers) provided during the use of products and services in one or more ways. These notifications are used for information notifications to users, identity verification, safety checks, user experience surveys, and other purposes. Additionally, the Service may provide commercial information related to services, functions, or activities via SMS or phone to the mobile number collected in the aforementioned process. However, if users do not wish to receive this information, they can opt out through the unsubscribe method provided in the SMS or contact the Service directly to opt out.
3.4.3 Interactive Exchange
If users purchase courses, view, comment, communicate in classes, or share, the Service will collect the aforementioned information and display the published content.
3.5 Order Management
Users can manage orders through E-MANABU. When users purchase specific products or services from the Service, the Service generates an order for that product or service through the system. During the ordering process, users must provide at least the recipient's nickname, delivery address, and recipient's phone number. The order will also include information about the products or services purchased, a specific order number, the order creation time, and the amount to be paid and payment method. The Service collects this information to verify the user's identity, complete payment and delivery, provide order inquiries, customer service consultations, and after-sales service. To provide better service, the Service may share the collected information with other third parties that provide services to users. The Service will also use the above information to determine whether there are any anomalies in the user's transactions and ensure the safety of the user's transactions. If users order products or services for others, they must provide the aforementioned personal information of the actual purchaser and ensure that they have obtained the actual purchaser's consent. If the information of a child is included, users must obtain the consent of the relevant child's guardian before providing it.
3.6 Payment Function
Users can complete payments through E-MANABU. After users pay for an order, they can choose a third-party payment institution affiliated with the platform to receive payment services. The Service needs to share the user's order amount information and payment-related information with these payment institutions. This enables the confirmation of payment instructions and completion of payment. Additionally, users agree to share necessary device information and network type information with payment institutions to prevent fraud and ensure the safety of platform transactions. Users also agree to collect information related to payment progress from the chosen transaction partner or other financial institutions.
3.7 Operations and Security
3.7.1 Operations and Security
The Service strives to provide users with a safe and reliable product and usage environment. Providing high-quality, efficient, and reliable services and information is the core goal of the Service. To maintain the normal operation of services and protect the legitimate interests of users, other users, and the public, the Service may collect necessary information to maintain the safe and stable operation of products and services.
3.7.2 Device Information and Log Information
To ensure the safe operation of software and services and maintain the quality and efficiency of operations, the Service may collect users' hardware model, operating system version number, device identifiers (for Android: IMEI/MEID, Android ID, OAID, IMSI, SIM card information (ICCID, etc.), GAID, hardware serial number (SN); for iOS: IDFV, IDFA; identifiers vary in validity period, reset options, and acquisition methods), network device hardware address (device MAC address), IP address, WLAN access point (SSID, BSSID, etc.), Bluetooth, base station, software version number, network connection method, type, status, network quality data, operation, usage, service logs, and device sensor data (accelerometer, linear acceleration sensor, gravity sensor, gyroscope, vector sensor, magnetic sensor).
To prevent malicious programs and ensure the quality and efficiency of operations, the Service may collect information on the software installation list, information on installed mobile apps, software list or running process information, overall app operation, usage frequency, app crash conditions, overall installation usage, performance data, and app sources.
The Service may use users' account information, device information, service log information, and information that the Service's affiliates or partners can provide with user approval or under legal provisions. This allows for assessing the safety of accounts and transactions, identity verification, identifying illegal activities or rule violations, detecting and preventing security incidents, and taking necessary legal recording, analysis, and processing measures.
3.8 Other
When users utilize payment services on E-MANABU, the Service may store users' payment records to ensure traceability and security of related transactions. However, the Service does not collect or store users' bank card information or identity verification information.
When users contact the Service, the Service may retain users' communication and call records or the contact information left by users. This is to facilitate communication with users, help resolve issues, and record the policies and outcomes of related issues.
When users purchase courses or other services from the Service on E-MANABU, the Service collects users' phone numbers to generate a dedicated order for the user. The order number is randomly generated and is not associated with the user's actual identity. If users purchase E-MANABU courses on a third-party platform, the Service will obtain order and course-related information for the purchased E-MANABU courses from the third-party platform to manage courses and orders and assist users in successfully attending courses.
3.9 Changes to the Purpose of Collection and Use of Personal Information
Users understand that as the operations of the Service develop, there may be adjustments or changes to the functions of E-MANABU and the services provided. In principle, if new functions or services are related to the functions or services currently offered by the Service, the personal information collected and used will be directly or reasonably related to the original processing purpose. If it is not directly or reasonably related to the original processing purpose, the Service will notify users again and obtain consent through page prompts, interactive processes, or contract confirmation methods in accordance with legal and relevant rules.
3.10 Exceptions Where Consent Is Not Required
Users understand that in the following situations, the Service is not required to obtain user consent when collecting and using personal information based on laws and relevant regulatory rules:
When the Service is related to fulfilling obligations based on laws and regulations.
When directly related to national security and national defense safety.
When directly related to public safety, public health, and significant public interests.
When directly related to criminal investigations, prosecutions, trials, and enforcement of judgments.
When it is difficult to obtain consent from the individual to protect significant legitimate interests of the user or others, such as life or property.
When the user has publicly disclosed personal information.
When necessary to conclude and perform a contract based on the request of the personal information subject.
When collecting personal information from legally disclosed information (e.g., through legitimate news reporting or government information disclosure).
When necessary to maintain the safe and stable operation of software and related services, such as discovering and addressing software and service failures.
When necessary for legitimate news reporting.
When necessary for academic research institutions to conduct statistics or academic research based on public interest, and when providing results externally, personal information included in the results is anonymized.
Other cases specified by laws and regulations.
Users are particularly urged to note that information that cannot identify the user or child personally, either alone or in combination with other information, is not considered personal information under the law. If the user's information can identify the user personally, either alone or in combination with other information, and the Service combines specific personal information with other users' or children's personal information, this information will be processed and protected as personal information of the user or child in accordance with this Privacy Policy during the period of combined use.
Article 4: Transfer and Disclosure of Personal Information
4.1 Collaborators in the Service Process
4.1.1 Principles
Legality Principle: When involved in data usage activities with collaborators, there must be a legitimate purpose, and the requirements for building a system that ensures safety as defined by law must be met. If a collaborator fails to comply with the legality principle when using information, that collaborator may not reuse the user's personal information until they meet the requirements for building a safe system as defined by relevant laws.
Principle of Justification and Minimum Necessity: Data usage should have a legitimate purpose and be limited to the scope necessary to achieve that purpose.
Safety and Caution Principle: This service carefully evaluates the purposes for which collaborators use data and comprehensively assesses the security capabilities of these collaborators, requiring them to comply with legal contracts. This service conducts strict safety monitoring of software development kits (SDKs) and application programming interfaces (APIs) used by collaborators to obtain information, ensuring data safety.
4.1.2 Entrusted Processing
In cases of entrusted processing of personal information, this service enters into relevant processing contracts with entrusted collaborators according to the law and monitors their activities regarding the use of personal information.
4.1.3 Joint Processing
In cases of joint processing of personal information, this service enters into relevant contracts with collaborators according to the law, defining each party's rights and obligations, ensuring compliance with relevant legal provisions during the use of related personal information, and protecting data safety.
4.1.4 Scope of Collaborators
In specific functions or scenarios, when related companies or third parties provide services for this service, the scope of collaborators includes these related companies and third parties.
4.1.5 Data Usage for Function or Service Realization
When users use functions provided by collaborators in this service on E-MANABU, or when software service providers, smart device providers, and system service providers collaborate with this service to provide services to users, this service statistically aggregates the necessary information to achieve business objectives and forms an indirect user profile. This allows the service to push, display, or notify users of information they may find interesting, providing more suitable specific functions or services.
When users log into apps or services of collaborators with their E-MANABU accounts, these apps or services will use the user's nickname, avatar, and other information approved by the user with their consent.
To adapt the message push function to the user's device, device manufacturers (Android system devices) may use the model, version, and related device information of the user's mobile phone through technologies such as SDK.
Payment functions are provided to users by third-party payment institutions in partnership with this service. Third-party payment institutions will use the user's name, type and number of bank cards, expiration date, identification certificate number, and phone number to provide the function. This information is necessary for the payment function, and refusal to use it will prevent the user from utilizing this function, but it will not affect the normal use of other functions.
When users use the "My Orders" function in E-MANABU, this service will provide the user's order information to the relevant service providers with the user's approval, allowing the user to review their order information in a unified manner.
To mail materials related to the courses purchased by the user, it is necessary to provide the recipient's nickname, contact phone number, and delivery address. The user agrees to provide the necessary information (recipient's nickname, contact phone number, and delivery address) to the teacher for mailing purposes. If the user does not provide this information, the teacher will not be able to mail materials, products, or gifts to the user.
This service places great importance on the safety of accounts, services, and content. To ensure the safety of users and other users' accounts and property, and to protect the legitimate interests of users and this service from illegal infringements, this service and its related companies or service providers may share necessary devices, accounts, and log information.
This service collaborates with audio and video service providers to collect audio and video stream data related to courses, realizing the basic functions and playback functions of the courses. This service conducts careful safety evaluations of related service providers.
To promptly address user complaints, suggestions, and other requests, this service provides customer service providers with information related to the user's account and complaints, enabling them to quickly understand and address relevant issues.
4.1.6 Data Usage for Advertising and Promotion Activities
Implementation of Advertising and Promotion, Related Analysis Services: To optimize and enhance the reach of advertising and promotion, the following collaborators must use de-identified or anonymized device, network, channel information, location information, and tag information. Collaborators providing advertising and promotion and related analysis services.
User Data Usage: Collaborators providing advertising, promotion, and related analysis services must use information such as the user's device, network, clicks, views, displays, and conversion data related to advertising and promotion to conduct analysis and measurement, improving the effectiveness of advertising and promotion services.
Optimization of Advertising Effectiveness: Collaborators for advertising and promotion may optimize advertising and promotion effectiveness by combining the above information with other data obtained in accordance with the law. This service requires that the use of information complies with the principles of legality, justification, and necessity, ensuring that users' legal rights are not infringed.
Collection of User Information: If users voluntarily fill in their contact information, address, etc., on advertising and promotion display pages provided by advertisers or their commissioned service providers, this information may be directly collected and used by the advertisers.
4.1.7 Data Usage for Security and Statistical Analysis
Account and Service Security: This service places great importance on the safety of accounts, services, and content. To ensure the safety of users and other users' accounts and property, and to protect the legal rights of users and this service from illegal infringements, collaborators of this service may use necessary devices, accounts, and log information. To ensure the safety of user accounts, if this service determines there is a risk of another person's phone number being used for the user's login account, it will provide the user's phone number and account registration time to the telecommunications operator to verify the phone number's ownership.
Analysis of Product Usage: To analyze the usage and performance of this service's products, collaborators of this service may use information such as product usage (crashes, freezes), device identification information, and overall installation status of the app.
4.1.8 User Participation and Support in Marketing Promotion Activities
If users choose to participate in marketing activities hosted by this service and its collaborators, this service and its collaborators need to use the user's name, address, contact information, bank account, etc., to ensure a consistent service experience in joint activities or to enable collaborators to quickly provide rewards to users (the information used may vary for different activities and will follow the specific activity rules). Refusal to use this information may affect participation in relevant activities but will not affect the use of other functions.
4.2 Transfer
As the business of this service continues to develop, there may be mergers, acquisitions, or asset transfers, which may result in the transfer of users' personal information. In the event of such changes, this service will require the transferee to continue fulfilling the obligations of personal information processors under the law and regulations and under conditions that do not fall below the safety standards described in this privacy policy. If the transferee changes the original processing purpose or method, this service will require the transferee to obtain renewed consent from the user.
4.3 Disclosure
This service will not disclose user information unless required by the laws and regulations of the relevant countries or with the user's consent. When disclosing users' personal information, this service will take safety protection measures in accordance with industry standards.
When announcing penalties for violating accounts or fraudulent activities, this service will disclose information related to the relevant accounts.
4.4 Exemptions from Consent for Disclosure of Information Based on Law
Users understand that in the following situations, this service may provide or disclose users' personal information to collaborators without obtaining user approval, according to the laws and regulations of the relevant countries:
When necessary for the user to enter into or perform a contract as one of the parties, or when necessary for implementing personnel management according to labor rules established by law or legally concluded collective agreements.
When necessary to perform statutory duties or legal obligations.
When directly related to national security or defense safety.
When this service receives requests in accordance with legal procedures such as warrants and discloses personal information to law enforcement agencies or courts based on applicable laws.
When necessary to respond to unexpected public health incidents or to protect the safety of individuals' lives, health, and property in emergencies.
When there is an imminent threat to physical safety or property, such as suicide threats or bomb threats.
When processing personal information disclosed by the user or legally disclosed by others in accordance with relevant laws.
When collecting personal information from information disclosed in accordance with the law.
Article 5: Storage of Personal Information
5.1 Retention Period
This service will retain users' personal information only for the period necessary to provide E-MANABU and related services. When users register or log in using their mobile phone numbers, this service needs to continuously retain the user's mobile phone number to provide normal services, address user inquiries and complaints, and ensure the safety of accounts and systems.
Information, comments, collections, and related data posted by users will be retained by this service as long as the user does not withdraw, delete, or deactivate their account, allowing the service to provide ongoing business functions. If a user deactivates their account, voluntarily deletes their personal information, or exceeds the necessary retention period, this service will delete or anonymize the user's personal information. However, this does not apply in the following situations:
That is, when complying with legal and regulatory requirements for information retention, or when there is a reasonable need to extend the retention period for purposes such as finance, auditing, or dispute resolution. Personal information of children under the age of 14 is considered sensitive personal information, and this service will retain such information to ensure its safety in accordance with Article 4. This service will not retain children's personal information beyond the minimum period necessary to achieve the purpose of collecting and using it. If a user withdraws, deletes, or deactivates their account, this service will delete the children's personal information, unless otherwise stipulated by laws and regulations.
5.2 Storage Location
This service will store users' personal information collected and generated in the country or region where it operates in accordance with laws and regulations, within Japan. Currently, this service does not transfer the above information overseas and strictly adheres to relevant Japanese laws and regulatory systems, complying with national provisions or obtaining user consent.
Article 6: Use of Cookies and Similar Technologies
Cookies and similar technologies, such as device information identifiers, are widely used on the internet. When users utilize E-MANABU and related services, this service may use these technologies to send one or more cookies or anonymous identifiers to the user's device, collecting and identifying information about the user's visits and usage of this service. This service promises not to use cookies for purposes other than those described in this privacy policy. The main purposes for which this service uses cookies and similar technologies are as follows:
6.1 To Enhance User Access Experience
By using such technologies, users can avoid repetitive steps such as re-entering personal information or search queries (recording search history and form entries).
6.2 To Ensure Safe and Efficient Operation of Products and Services
This service may set authentication cookies and anonymous identifiers to verify safety, ensuring that users are securely logged into the service and are not encountering unauthorized access, fraud, or other illegal activities. These technologies also help improve the efficiency of this service, enhancing login and response speeds.
6.3 To Provide Content and Accounts That Users Need
6.3.1 This service utilizes cookies and similar technologies to understand users' preferences and usage habits, conduct data analysis, improve product services, push information and features that users may be interested in, and optimize advertising choices.
6.3.2 On the sharing pages of the E-MANABU app, this service uses cookies to record browsing activities, push information to users, investigate related anomalies such as crashes or delays, and explore better service methods.
6.4 Deleting Cookies
Most browsers provide users with the ability to delete browser cache data. Users can perform the appropriate data deletion operations through their browser settings. If users choose to delete cookies, these changes may result in the inability to use services or features that depend on cookies.
Article 7: Protection of Personal Information
7.1This service employs encryption technologies, anonymization processes, and other reasonable and feasible measures that exceed industry standards to protect users' personal information and implement security measures to guard against malicious attacks.
7.2This service places a high priority on the safety of users' personal information and will make efforts to implement reasonable security measures (including technical and managerial aspects) to prevent improper use, unauthorized access, disclosure, use, alteration, damage, loss, or leakage of personal information provided by users.
7.3This service will establish specialized security departments, safety management systems, and data security processes to ensure the safety of users' personal information. It will adopt strict data usage and access systems, allowing only authorized individuals to access users' personal information, and will conduct timely security audits of data and technology.
7.4Despite implementing the above reasonable and effective measures and complying with relevant legal standards, it is acknowledged that due to technical constraints and various malicious means, it is impossible to guarantee 100% safety of information in the internet industry, regardless of how much security measures are enhanced. This service will do its utmost to ensure the safety of personal information provided by users.
7.5Users understand that problems may arise from systems or communication networks they use to access this service due to factors beyond this service's control. Therefore, this service strongly recommends that users take proactive measures to protect their personal information's safety. This includes using complex passwords, changing passwords regularly, and not disclosing account passwords or related personal information to others.
7.6This service has developed an emergency response plan and will activate this plan immediately in the event of safety issues concerning user information, making efforts to prevent the escalation of the impact or consequences of such safety issues. In the event of a safety issue (such as leakage or loss) of user information, this service will promptly notify users of the following information in accordance with legal and regulatory requirements: the basic situation of the safety issue and possible impacts, the measures already taken or planned by this service, suggestions for users to voluntarily prevent or mitigate risks, and remedies for users. This service will notify users of information related to the incident via push notifications, emails, letters, SMS, and other methods, and if individual notifications are difficult, will make announcements in a reasonable and effective manner. Additionally, this service will report to relevant supervisory authorities on the handling of safety issues concerning user information.
7.7When users leave E-MANABU and related services to browse or use other websites, services, and content resources, this service does not have the ability or direct obligation to protect personal information submitted to software or websites other than E-MANABU and related services. This applies even when users log in, browse, or use the aforementioned software or websites based on links or guidance from E-MANABU.
Article 8: Management of Personal Information
This service places great importance on allowing users to manage their personal information and will do its utmost to protect users' rights to view, copy, modify, supplement, delete, withdraw consent, cancel accounts, file complaints, and set privacy features. This ensures that users can guarantee their privacy and the safety of their information.
8.1 Changes or Withdrawal of Permissions
8.1.1 Changes or Withdrawal of Permission Settings
Users can change the scope of their consent or withdraw their authorization by turning off the relevant permissions in their device's operating system. After withdrawing authorization, this service will no longer collect information related to those permissions.
8.1.2 Changes in Information Processing After Withdrawal of Authorization
Certain business functions or services require user information. If users withdraw their consent or authorization, this service will be unable to provide those functions or services and will cease processing the relevant personal information. However, the decision to withdraw consent or authorization will not affect previous processing of personal information conducted by this service based on the user's consent.
8.2 User Rights Regarding Personal Information
8.2.1 Viewing, Modifying, and Deleting Personal Information
Users can check the types and specific content of personal information collected by E-MANABU from their 【My Page】 in the E-MANABU APP. For specific details, please refer to the personal information collection list. If users find any errors in their personal information, they have the right to request corrections or supplements. Users can provide feedback according to Article 12 of this privacy policy.
Users can view, modify, and delete their personal information through various methods via E-MANABU. They can view, copy, modify, and delete account information. Users can access and manage their profile picture, nickname, and self-introduction from 【My Page】 - 【Profile Picture】 in the E-MANABU APP. For viewing, copying, or deleting other related accounts or information, users can click on 【My Page】 to access third-party accounts. Users can clear the cache by clicking on 【My Page】 - 【Settings】 - 【Clear Cache】 in the E-MANABU APP. To delete posted comments, users can access individual comment content in the E-MANABU APP and delete comments through the page.
Additionally, if users or others with relevant authority have claims, requests, or questions regarding the exercise of personal information rights based on relevant laws, they can contact this service. This service will promptly review the issue and respond within 15 business days after verifying the user's identity.
It is particularly important to note that, for security and identity verification reasons, users may not be able to change some initial registration information submitted during registration. If users need to change such registration information, they should contact the contact information provided in this privacy policy.
8.2.2 Protection of Personal Information of Deceased Individuals
This service will continue to ensure the safety of user information. In the event of a user's death, their close relatives (hereinafter referred to as "close relatives of the deceased") can contact this service through the methods outlined in this privacy policy to exercise rights such as viewing, copying, modifying, or deleting the deceased's relevant personal information for their lawful interests. However, if the deceased had made special arrangements during their lifetime, those arrangements will be followed. To adequately protect the rights of the deceased's personal information, the close relatives exercising these rights must complete identity verification procedures and guarantee that the exercise of rights does not conflict with the deceased's arrangements made during their lifetime, ensuring that the purpose of exercising rights is lawful and legitimate.
8.3 Account Cancellation
Users can contact this service through 【Settings - Account and Security】 to apply for account cancellation. Upon receiving the user's application, this service will process it promptly and respond to the user's request within 15 business days or within the legally required timeframe. Before canceling the account, this service will verify the user's identity, security status, device information, etc. Users understand that account cancellation is an irreversible action, and after cancellation, this service will delete or anonymize the user's related information. However, this will be done in accordance with any separate legal provisions. For specific procedures and details regarding cancellation, please refer to the notes on account cancellation for E-MANABU.
8.4 Feedback and Complaints
Users can file complaints or reports following the procedures announced by this service. If users have any opinions, feel their personal information rights are at risk of being violated, or discover clues regarding violations of personal information rights, they can access the user feedback screen from 【My Page】 - 【Online Customer Service】 to contact this service. This service will provide feedback on the user's complaints or reports within 15 business days after investigation.
8.5 Review of Privacy Policy
Users can review the full content of this privacy policy from the registration page or after logging into their personal account in 【My Page】 - 【Settings】.
Users understand that the "E-MANABU" and related services may vary based on the user's location, the model of the mobile phone used, system version, software application version, mobile client, and other circumstances. The final products and services are based on the "E-MANABU" software and related services used by the user.
8.6 Notice of Service Suspension
If this service suspends operations, it will immediately cease the collection of users' personal information and notify users of the operational suspension either individually or through announcements, and will delete or anonymize the personal information it holds.
Article 9: Recommendations
To display and recommend information and advertisements relevant to users, and to provide services that meet user demands, E-MANABU offers recommended services to users. Below, we detail how this service operates its recommendation system and how users can control it.
9.1 Recommendation Algorithm Mechanism
The scope of the recommended services provided by this service includes recommending courses and other content based on users' browsing history, learning status, and selected preferences.
To provide recommended services to users, this service may collect and use users' device information (hardware model, operating system version, device identifiers, hardware addresses of network devices, device sensor information, etc.), behavioral information during product usage (clicks, saves, searches, browsing, transaction operation records, etc.), personal information entered by users (nickname, profile picture, etc.), and information provided by other collaborators based on user consent. The system automatically analyzes and calculates this information to predict users' preference characteristics and automatically provides recommended content and services based on the calculation results.
This service continuously trains and feeds back the recommendation model in real-time based on users' browsing behavior during product usage, adjusting and optimizing the recommendation results. To meet users' diverse needs and prevent excessive concentration of similar types of content, various technologies are employed to automatically process content, providing users with high-quality content and services.
9.2 Control and Management of Recommendations
Stopping Recommendations: Users can turn the recommendation feature on or off from 【My Page】 - 【Settings】 - 【Recommendations】. Users can choose to turn off recommendations, which will stop them from receiving recommended services on the homepage.
Users can withdraw the features used for recommendations. Users can turn off system permissions as described in Article 8 of this privacy policy. When permissions are turned off, this service will no longer collect information related to those permissions and will not use it for recommendations.
Users can also exercise other controls and provide feedback. If users believe that some decisions made by this service's recommendation system are based solely on automated decisions and that these decisions significantly affect their legal rights, they can contact this service as described in Article 12 of this privacy policy to request an explanation. Users have the right to refuse decisions made solely based on automated determinations.
Article 10: Minor Provisions
10.1 General Provisions Regarding Minors
If the user is a minor, they must read and agree to this privacy policy jointly with their parent or other guardian before using E-MANABU and related services.
If the user is the guardian of a minor under the age of 14, they must read and agree to this privacy policy on behalf of the minor before using E-MANABU and related services.
This service will protect the personal information of minors in accordance with relevant national laws and regulations. Personal information of minors will only be collected, used, or disclosed when permitted by law, with explicit consent from a parent or other guardian, or when necessary to protect the minor. If this service discovers that it has collected personal information from a minor without prior verifiable consent from a parent or other guardian, it will make efforts to promptly delete the relevant information. This service has strict rules regarding the collection and use of minors' information to ensure the safety of children's and young people's personal information.
If the user is the guardian of a minor and has questions regarding the personal information of the minor being protected, they can contact this service through the contact information provided in this privacy policy.
Article 11: Revisions and Notifications of the Privacy Policy
To provide users with better services, E-MANABU and related services will be updated and changed from time to time. This service may revise this privacy policy as appropriate, and these revisions will constitute part of this privacy policy and have the same effect as this privacy policy. Without the explicit consent of users, this service will not restrict users' rights based on the currently effective privacy policy.
When this privacy policy is updated, this service will announce the updated version in E-MANABU and notify users of the updates through appropriate means before the updated provisions take effect, ensuring that users are aware of the latest privacy policy.
Article 12: Contact Information
12.1 E-MANABU products are provided by Rakkki Japan Co., Ltd. If users have complaints, suggestions, or questions regarding personal information protection, they can contact this service through 【My Page - Online Customer Service】. This service will promptly respond to complaints or reports after verifying the user's identity.
12.2 For questions, opinions, or suggestions regarding personal information protection issues or the contents of this privacy policy, users can contact this service through the "Online Customer Service" in the "E-MANABU" app or the "Feedback" section in the PC version of the online classroom.
Rakkki Japan Co., Ltd.
167 Ihohara, Jyousui-cho, Toyota City, Aichi Prefecture
Phone: 050-1299-8040
Email: [email protected]
