Privacy Policy

JapanesePal is operated by Windvale LLC, a limited liability company registered in Wyoming, United States. Windvale LLC is responsible for the personal information we process as a data controller or equivalent responsible business under applicable law.

This Policy covers personal information processed by Windvale LLC in connection with JapanesePal, including website visits, account use, learning activities, customer support and the purchase or administration of paid services.

It does not automatically cover other websites or brands, even where they have similar features. Third parties that independently determine how they use personal information, including certain payment and sign-in providers, explain their own processing in their privacy notices. Our responsibilities for processing personal information remain subject to applicable law.

Company: Windvale LLC
Place of registration: Wyoming, United States
Privacy contact: [email protected]

This Policy explains our practices. It does not replace any consent that applicable law requires us to obtain separately.

The information involved depends on the features you use and the information you choose to provide.

If you choose a third-party sign-in option, the information we receive depends on that provider and the permissions you authorize. We receive transaction information from payment providers and technical information from infrastructure providers where needed to operate JapanesePal.

You do not need to include sensitive personal information about yourself or others in practice conversations. Please avoid submitting government identification numbers, payment credentials, medical records or confidential information that is unnecessary for learning. If you provide another person's information, you must have an appropriate basis for doing so.

We use personal information for the purposes described below. Where the EEA GDPR or UK GDPR applies, we rely on a legal basis appropriate to the particular processing activity.

Where we rely on legitimate interests, we assess the necessity of the processing and balance those interests against your rights and reasonable expectations, taking particular care where minors are involved. A legal obligation in one country does not automatically provide a legal basis in every other jurisdiction.

Where we rely on consent, you may withdraw it through the relevant controls or by contacting us. Withdrawal does not affect processing lawfully carried out before withdrawal. If information is necessary to provide a requested feature and you do not provide it, that feature may not be available.

We will provide appropriate notice before using personal information for a materially different purpose and obtain additional consent where required.

JapanesePal uses automated systems to generate conversation responses and learning feedback. Processing may involve the message or audio you submit, relevant conversation context, your selected tutor or learning preferences, and the resulting transcript or feedback.

AI and speech providers may process the information needed to supply their part of the service. Their involvement, data access and retention must be considered separately from the conversation history shown in your account.

When you choose voice input, your device or browser may ask for microphone permission. You can manage that permission in your device or browser settings and use text-based practice where available. Microphone permission allows the feature to access your microphone; it is not blanket consent to unrelated uses of your information.

Some website examples use your browser or operating system's speech synthesis to read prewritten Japanese text aloud. Whether that playback uses an on-device or network-based voice depends on the technology and voice selected by your browser or device.

Learning scores, suggestions and assessments are automated learning outputs and may be inaccurate. They are intended to support practice. Contact us if you believe an output or the personal information associated with it needs attention.

Generating an AI response is distinct from training or fine-tuning a model. Any additional use of personal information for model development requires an appropriate legal basis and the notice or consent required by applicable law. You may contact us with questions about AI processing or to exercise your applicable privacy rights.

We disclose personal information only where there is an appropriate purpose and legal basis. The relevant recipients can include:

• Hosting, storage, delivery, authentication and security providers that support operation of JapanesePal.
• AI and speech providers that process content needed for the conversation or voice feature you use.
• Customer support and communications providers that help us respond to you and send service messages.
• Payment providers, banks or merchants of record involved in processing and administering your purchase.
• Professional advisers, courts, regulators or other recipients where disclosure is necessary and lawful for compliance, security or legal claims.
• Parties to a proposed or completed business transaction, such as a merger or sale, where appropriate safeguards and applicable notice requirements are met.

We require providers processing information on our behalf to use appropriate contractual restrictions and safeguards, including limits on their use of the information. Independently acting providers may also have their own legal obligations and privacy notices.

If you request a feature that makes information available to others, such as sharing a certificate, the visibility and information involved should be explained when you use that feature.

When you purchase a paid service, payment-related information is handled by the provider identified at checkout. Depending on the transaction, that provider may act as a payment processor or a merchant of record and may independently process information for fraud prevention, tax, accounting and other legal obligations.

We use the transaction information available to us to provide paid access, manage your subscription, match payments to your account and handle billing questions or disputes. Details about how payment credentials are collected and stored depend on the checkout method you use.

Deleting a JapanesePal account does not require a payment provider to erase records it must lawfully retain. You may contact us for help identifying the relevant provider. Please do not email us your full card number, card security code or account password.

Refund eligibility and subscription terms are explained in our Refund Policy and Terms of Service. This Privacy Policy does not change mandatory consumer rights.

Cookies, local storage and similar technologies can support login sessions, security and preferences. Depending on the tools deployed, they can also support analytics or advertising. For information about technologies used in connection with your account or a particular feature, contact [email protected].

Where prior consent is required, optional technologies remain inactive until you choose to enable them. You may refuse or withdraw that consent through the controls provided for that technology, or contact us for assistance. Where a lawful exemption applies, we provide the information and any opt-out required for that use.

You can also control storage through your browser settings. Blocking technologies necessary for a requested service may affect sign-in or other features. Browser settings do not replace any consent or opt-out controls we are required to provide.

Where applicable law requires us to recognize an opt-out preference signal, such as Global Privacy Control, we must give effect to it for the relevant processing. A Do Not Track signal is separate from these legally recognized opt-out signals.

We retain personal information for no longer than reasonably necessary for the stated purposes, subject to applicable legal requirements. Different categories have different retention needs.

Retention decisions take account of the service purpose, the sensitivity of the information, account status, legal recordkeeping requirements and relevant limitation periods. We do not retain information indefinitely simply because it might be useful later.

Information that must remain after a deletion request is limited to what is necessary for a lawful retention purpose. It must not be reused for unrelated purposes. Where deletion from a backup cannot occur immediately, the information must remain protected and excluded from ordinary use until deletion or expiry under the applicable cycle.

You can manage your data through the controls provided in JapanesePal:

Clearing conversation history applies to the history covered by that feature. It is not the same as deleting your account or deleting all payment, security and legal records held by us or an independently responsible payment provider.

Account deletion can remove access to your saved practice and other account-linked information. Before confirming deletion, save anything you wish to keep. Information retained for a necessary legal purpose or remaining in restricted backups is handled as described in Section 8.

Clearing history does not cancel a paid subscription or submit a refund request. When closing your account, review any active subscription and use the available cancellation controls, or contact [email protected] so we can help ensure future billing is addressed. We will handle data deletion and billing matters without requiring you to give up a statutory privacy right.

If a control is unavailable or you need help with a broader deletion request, email [email protected]. We may request proportionate information to verify your identity and identify the relevant account.

Depending on your location and the law that applies, you may have rights to:

• Obtain confirmation of processing, information about our practices and access to your personal information.
• Correct inaccurate or incomplete information.
• Request deletion, subject to lawful exceptions.
• Obtain an applicable portable copy of information.
• Restrict or object to certain processing, including processing based on legitimate interests where the relevant conditions apply.
• Withdraw consent for processing that relies on your consent.
• Object to direct marketing or use an available unsubscribe option.
• Exercise applicable rights concerning solely automated decisions with legal or similarly significant effects.
• Exercise applicable sale, advertising-sharing, sensitive-information and targeted-advertising opt-out rights.
• Complain to a competent regulator or seek other remedies available under applicable law.

You can use the self-service controls described above or contact [email protected]. Include the email associated with your account, the request you want us to consider and your country or state if relevant. You do not have to use a particular legal phrase to make a request.

We use reasonable and proportionate verification where needed to protect your information. Where an authorized representative makes a request, we may need evidence of their authority. We do not require unnecessary information or require someone to create an account simply to submit a privacy request.

We respond without undue delay and within the deadlines required by applicable law. Where a lawful extension, restriction or refusal applies, we explain it and provide the information about review or complaint rights that the law requires. We do not unlawfully discriminate against people for exercising privacy rights.

EEA and United Kingdom

Where the GDPR or UK GDPR applies, you have the applicable rights described above and may contact the competent data protection authority. Rights requests are generally addressed within one month, with extensions only where permitted and with the required notice. You may request information about the legal basis for a particular activity and any applicable international transfer safeguards. Additional requirements for sensitive information and children's consent apply where relevant.

United States

Where a state privacy law applies to our processing, residents may have additional rights, including rights to know the categories and specific information collected, correct or delete information, obtain a copy, and opt out of specified processing. Covered US state-law requests are commonly subject to a 45-day response period; the deadline and any permitted extension depend on the applicable law and type of request. If a right of appeal applies, contact [email protected] to ask for an appeal of our decision; we will provide any further instructions and information about regulatory review required by that law.

California rights may include the right to opt out of a sale or sharing for cross-context behavioral advertising and, in applicable circumstances, to limit the use or disclosure of sensitive personal information. Our data categories, sources, purposes, recipients and retention practices are described in the relevant sections above.

Switzerland

Where Swiss data protection law applies, you may exercise applicable access, correction, deletion, portability and objection rights and contact the Federal Data Protection and Information Commissioner. You may contact us for information about the destination countries and relevant protection arrangements for disclosures abroad.

Japan and other locations

Where local privacy laws apply, we will respect the rights those laws provide, which may include information about purposes of use, disclosure or access, correction, and suspension of use or third-party provision in the circumstances specified by law. The rights and conditions are not identical in every country. Nothing in this Policy excludes mandatory rights under applicable local law.

Users aged 13 or older must also meet any higher age, legal-capacity or parental authorization requirements that apply in their location. Where parental or guardian authorization is legally required, the relevant processing or access must not take place unless those requirements have been met. Parental permission does not make the service available to children under 13.

In particular, where we rely on consent to offer an online service directly to a child in the EEA, the age at which the child may independently give that consent depends on national law and may be between 13 and 16. We must take the legally required reasonable steps to verify any necessary parental authorization. Other protections for teenagers may apply regardless of the legal basis used.

If we learn that we have collected personal information from a child under 13, or without parental authorization where it was legally required, we will take appropriate steps to stop the relevant processing, restrict or close the account as appropriate, and delete the information in accordance with applicable law.

A parent or guardian who believes a child has submitted information contrary to these requirements should contact [email protected] so we can investigate and take appropriate action.

Windvale LLC is registered in the United States. Providing JapanesePal can involve processing by service providers or authorized personnel in countries other than the country where you live. Registration in the United States does not mean all information is stored or accessed only in the United States.

Where required, an international transfer must be supported by an appropriate legal mechanism and any additional protections necessary under the relevant law. Privacy laws in a destination country may differ from those where you live. You may contact [email protected] for information about the applicable safeguards and a copy where the law provides that right, subject to lawful redactions.

We do not treat your mere use of JapanesePal as blanket consent to international transfers that require a separate legal basis or authorization.

We maintain technical and organizational safeguards appropriate to the information processed and the risks involved. These measures must address authorized access, confidentiality, service integrity and the handling of security incidents.

No method of electronic transmission or storage is completely secure. Please protect your account credentials and contact us if you suspect unauthorized access. Where a personal information breach requires notification, we will notify the relevant individuals or authorities as required by applicable law.

We may update this Policy to reflect changes in the service, our practices or applicable requirements. We will display the updated revision date and provide any applicable effective-date information. Where a change requires additional notice or consent, we will provide that notice or request consent as required before applying the relevant change.

If you have a privacy question, request or complaint, please contact [email protected]. Explain what happened and the outcome you are seeking so we can investigate and respond. We may ask for relevant information needed to understand the issue or protect your account.

Where the UK data protection complaints requirements apply, we will acknowledge receipt of a privacy complaint within 30 days and investigate, keep you appropriately informed, and communicate the outcome without undue delay. Other applicable statutory deadlines remain unaffected.

We encourage you to contact us so we can address your concern. This does not restrict any right you have to contact a competent regulator or seek a remedy under applicable law.