SomniQ KK (hereinafter referred to as the “Company”) hereby establishes this Privacy Policy (hereinafter referred to as the “Policy”) regarding the handling of Participant Information, including Personal Information concerning Participants, in connection with the projects operated by the Company (hereinafter referred to as the “Project”).
1. Basic Policy
With respect to the handling of Personal Information obtained by the Company, the Company shall comply with the Act on the Protection of Personal Information, guidelines and other indices relating to the protection of Personal Information, and other relevant laws and regulations concerning the protection of Personal Information.
2. Participant Information Collected and Method of Collection
For the purposes of this Policy, “Participant Information” shall mean information relating to the identification of a Participant, behavioral history on the communication service, and other information generated or accumulated in relation to a Participant or a Participant’s device on a Participant’s smartphone, PC, or other device, which the Company collects pursuant to this Policy.
The Participant Information collected by the Company in connection with the Project shall be as follows, depending on the method of collection.
(1) Information Provided by the Participant
The information provided by a Participant in order to participate in the Project is as follows:
- Name
- Email address
- Nickname
- Other information entered by the Participant into input forms designated by the Company.
(2) Information Collected by the Company in Connection with the Participant’s Participation in the Project
- Empatheme Information (Practice Data recorded and transmitted through the Project)
The Company may collect information regarding access to, and the manner of use of, the website introducing the Project. This includes the following information:
- Device Information
- Log Information
- Cookies and Anonymous IDs
- Location Information
3. Purpose of Use
3-1. Participant Information is used for the operation of the Project as set forth in 3-2, and may also be used for other purposes as set forth in 3-3.
3-2. The specific purposes of use of Participant Information relating to the operation of the Project are as follows:
(1) To provide accompanying support, advice, guidance, and responses to inquiries relating to the Project;
(2) To respond to conduct that violates the Company’s Terms of Participation, Privacy Policy, and other rules relating to the Project (hereinafter referred to as the “Terms, etc.”);
(3) To notify Participants of changes to the Terms, etc. relating to the Project; and
(4) For purposes incidental to the above purposes of use.
3-3. Purposes of use other than those set forth in 3-2 above are as follows:
Purpose of Use
(1) To create statistical data processed into a form that does not identify individuals, in connection with the Company’s Project.
- Practice Data
- Device Information
- Log Information
- Cookies and Anonymous IDs
- Location Information
4. Management of Personal Information
The Company thoroughly implements the following with respect to the management of Personal Information obtained from users.
(1) Ensuring Accuracy of Information
The Company strives to ensure that Personal Information obtained remains accurate and up to date at all times.
(2) Security Control Measures
With respect to the organizational management of Personal Information, the Company establishes strict handling methods under its internal regulations and ensures their strict application.
(3) Supervision of Outsourcing Contractors for Personal Information Management
Where the Company outsources the management of Personal Information to an outside party, it shall do so only to contractors selected in accordance with the Company’s regulations and shall manage such outsourcing appropriately.
5. Method of Notification, Publication, or Obtaining Consent, and Method of Requesting Discontinuation of Use
5-1. With respect to the following Participant Information, the Company shall obtain the consent of the Participant before such information is collected:
- Voice data in Practice
5-2. A Participant may, by performing the prescribed settings of the Project, request that the use of all or part of their Participant Information be discontinued, in which case the Company shall promptly discontinue such use in accordance with the Company’s prescribed procedures. However, with respect to certain items of Participant Information, the collection or use thereof is a prerequisite for the Project; accordingly, the Company shall discontinue collection of such information only where the Participant has withdrawn from the Project by the method prescribed by the Company.
6. Provision to Third Parties
With respect to Personal Information among Participant Information, the Company shall not provide such information to any third party without first obtaining the Participant’s consent, except where disclosure is permitted under the Act on the Protection of Personal Information or other laws and regulations. Provided, however, that this shall not apply in the following cases:
(1) Where the Company outsources the handling of Personal Information, in whole or in part, within the scope necessary to achieve the purpose of use;
(2) Where Personal Information is provided in connection with the succession of business due to a merger or other reason;
(3) Where it is necessary to cooperate with a national government agency, a local government, or a person entrusted by such agency or government in executing affairs prescribed by laws and regulations, and obtaining the Participant’s consent is likely to impede the execution of such affairs; or
(4) Other cases permitted under the Act on the Protection of Personal Information or other laws and regulations.
7. Disclosure of Personal Information
Where a Participant requests disclosure of Personal Information pursuant to the provisions of the Act on the Protection of Personal Information, the Company shall, after confirming that the request is made by the Participant themselves, disclose such information to the Participant (if such Personal Information does not exist, the Company shall notify the Participant to that effect). Provided, however, that this shall not apply where the Company is not obligated to make such disclosure under the Act on the Protection of Personal Information or other laws and regulations.
8. Correction and Discontinuation of Use, etc. of Personal Information
8-1. Where a Participant requests:
(1) correction of the content of their Personal Information, pursuant to the provisions of the Act on the Protection of Personal Information, on the grounds that such Personal Information is not true; or
(2) discontinuation of the use of their Personal Information, pursuant to the provisions of the Act on the Protection of Personal Information, on the grounds that it is being handled beyond the scope of the previously announced purpose of use, or on the grounds that it was collected by deception or other improper means,
the Company shall, after confirming that the request is made by the Participant themselves, conduct the necessary investigation without delay, and based on the results thereof, correct the content of the Personal Information or discontinue its use, and notify the Participant to that effect. Where the Company decides not to make such correction or discontinuation of use based on reasonable grounds, it shall notify the Participant to that effect.
8-2. Where a Participant requests the erasure of their Personal Information, and the Company determines that it is necessary to comply with such request, the Company shall, after confirming that the request is made by the Participant themselves, erase the Personal Information and notify the Participant to that effect.
8-3. The provisions of the preceding two paragraphs shall not apply where the Company is not obligated to make such correction, etc. or discontinuation of use, etc. under the Act on the Protection of Personal Information or other laws and regulations.
9. Contact
Please direct any opinions, questions, complaints, or other inquiries regarding the handling of Participant Information to the following contact:
Address: Fuzanbo Building 7F, 1-3 Kanda Jimbocho, Chiyoda-ku, Tokyo 101-0051
SomniQ KK, Contact Desk
Email: info@empatheme.org
10. Procedure for Amending the Privacy Policy
The Company shall periodically review the operational status of its handling of Participant Information and strive for continuous improvement, and may amend this Policy as necessary. In the event of any amendment, the Company shall notify Participants thereof. Provided, however, that where the content of an amendment requires the consent of Participants under applicable laws and regulations, the Company shall obtain such consent by the method prescribed by the Company.
11. Additional Provisions for EU/EEA, UK, and Swiss Users
This section applies if you are located in the European Economic Area, the United Kingdom, or Switzerland.
11-1. Data Controller
For the purposes of applicable data protection laws, including the General Data Protection Regulation (GDPR), SomniQ KK is the data controller responsible for the processing of Personal Information described in this Policy.
Contact:
SomniQ KK
Fuzanbo Building 7F, 1-3 Kanda Jimbocho, Chiyoda-ku, Tokyo 101-0051, Japan
Email: info@empatheme.org
We do not currently offer the Project on a targeted basis to individuals in the EEA or UK (for example, through region-specific marketing, local-language versions, or local pricing), and have therefore not appointed a representative under Article 27 GDPR or Article 27 UK GDPR at this time; if this changes, we will appoint a representative and update this Policy accordingly.
Based on the current scale and nature of our processing, we have determined that we are not required to appoint a Data Protection Officer under Article 37 GDPR; we will keep this assessment under review as the Project develops.
11-2. Legal Basis for Processing
We process Participant Information, including Personal Information, based on the following legal bases:
| Processing Activity | Legal Basis |
|---|---|
| Account creation and operation of the Project | Performance of a contract |
| Provision of learning, practice, support, advice, and guidance | Performance of a contract |
| Storage of practice history, learning progress, reviews, and related records | Performance of a contract |
| Voice data collection and speech analysis in Practice | Performance of a contract or consent, where required |
| Responding to inquiries and providing important notices | Performance of a contract or legitimate interests |
| Security, fraud prevention, troubleshooting, and enforcement of Terms, etc. | Legitimate interests |
| Creation of statistical data in a form that does not identify individuals | Legitimate interests |
| Marketing communications, where applicable | Consent |
| Compliance with legal obligations | Legal obligation |
Where processing is based on consent, you may withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before withdrawal.
11-3. Voice Data and Speech Analysis
The Project includes learning and speech practice features. In order to provide these features, we may collect and process voice data recorded during Practice, as well as pronunciation, rhythm, speech analysis, learning progress, and related feedback data.
Voice data and analysis results may be used to:
– provide pronunciation, rhythm, and learning feedback;
– visualize practice patterns and progress;
– support review, advice, and guidance;
– improve the quality, safety, and reliability of the Project; and
– create statistical data in a form that does not identify individuals.
We do not make decisions that produce legal or similarly significant effects on you solely by automated processing.
11-4. Service Providers and International Data Transfers
We may use service providers to operate, maintain, analyze, and improve the Project. These providers may process Participant Information on our behalf.
Such providers may include cloud hosting, storage, authentication, analytics, crash reporting, push notification, speech analysis, and customer support providers, including services such as Google Cloud, Firebase, and speech analysis service providers such as SpeechAce, where applicable.
Your Personal Information may be transferred to and processed in countries outside your country or region, including Japan and the United States. Where required by applicable law, we rely on appropriate safeguards, such as adequacy decisions, Standard Contractual Clauses, or other lawful transfer mechanisms.
11-5. Data Retention
We retain Participant Information only for as long as reasonably necessary for the purposes described in this Policy, unless a longer retention period is required or permitted by law.
Retention periods may vary depending on the type of information:
– Account information is retained while your account or participation in the Project remains active.
– Practice Data, learning progress, review records, and related records are retained while necessary to provide learning history, support, advice, and Project features.
– Voice data and speech analysis data are retained while necessary to provide Practice, feedback, review, and support features, unless deletion is requested and we are legally able to comply.
– Log information and diagnostic data are retained for a limited period for security, troubleshooting, and service improvement.
– Records required for legal, tax, accounting, dispute resolution, or compliance purposes may be retained for the period required or permitted by applicable law.
When Participant Information is no longer necessary, we will delete, anonymize, or aggregate it in accordance with our procedures.
11-6. Your Rights
Subject to applicable law, you may have the following rights regarding your Personal Information:
– the right to access your Personal Information;
– the right to rectify inaccurate or incomplete Personal Information;
– the right to request erasure of your Personal Information;
– the right to restrict processing of your Personal Information;
– the right to object to certain processing;
– the right to data portability;
– the right to withdraw consent where processing is based on consent; and
– the right to lodge a complaint with your local data protection supervisory authority.
To exercise these rights, please contact us using the contact information in Section 9 or Section 11-1. We may need to verify your identity before responding to your request.
11-7. Account Deletion and Data Deletion
You may request deletion of your account or Personal Information through the method prescribed by the Company or by contacting us.
Please note that some information may be retained where necessary for legal compliance, security, fraud prevention, dispute resolution, backup management, or legitimate business records.
11-8. Children
If you are under the age at which parental consent is required under the laws of your country or region, you may use the Project only with the consent of a parent or legal guardian.
If we learn that we have collected Personal Information from a child without required consent, we will take appropriate steps to delete or restrict such information.
11-9. Cookies and Similar Technologies
The Company may use cookies, anonymous IDs, or similar technologies to operate the website introducing the Project, analyze usage, improve user experience, and maintain security.
Where required by applicable law, we will obtain consent before using non-essential cookies or similar technologies.
11-10. Privacy Contact
For privacy-related inquiries, requests, or complaints, please contact:
SomniQ KK, Contact Desk
Email: info@empatheme.org
Last updated: July 31, 2026