TERACHA ("we" or "us") establishes this Privacy Policy regarding the handling of users' personal information in connection with the services provided on this website.
Article 1 — Personal Information
Personal information refers to information about a living individual that can identify a specific person, including name, date of birth, address, phone number, email address, and other identifiers as defined under Japan's Act on the Protection of Personal Information.
Article 2 — How We Collect Personal Information
We may collect personal information such as your name, email address, and payment details when you register for our services. For AI chat services, we also collect and store conversation content you input for the purposes of service delivery and quality improvement.
Article 3 — Purposes of Collection and Use
- To provide and operate our services
- To respond to inquiries from users
- To send updates, campaign information, and announcements
- To send maintenance notices and other necessary communications
- To prevent unauthorized use and identify users who violate our Terms of Service
- To allow users to view, update, or delete their own registration information
- To process billing for paid services
- To generate personalized AI responses
- For purposes incidental to the above
Article 3.1 — Data Processing for AI Services
When using our AI services (including Soracha.AI and the AI coaching features of our Online Soccer School), the following data processing takes place:
- Conversation content you input is stored on our servers in encrypted form solely for the purposes of generating responses and personalization for the individual user
- Conversation data is protected by technical measures so that no human — including our staff and operators — can view it. We do not use conversation content for "service improvement", "quality monitoring", "marketing analysis", "training data", or any other purpose whatsoever
- While conversation data is transmitted to third-party AI service providers for AI processing, it is not used by those providers to train, fine-tune, or improve AI models (as guaranteed by our API service agreements). The applicable provider's privacy policy applies
- Conversation data is retained for the periods set out in Article 3.3 and then securely deleted
- We recommend that you do not input sensitive personal information (such as address, financial details, or medical information) into conversations
Article 3.2 — Analytics Tools and Cookies
We may use access analytics tools such as Google Analytics to understand usage patterns and improve our services. These tools use cookies to collect traffic data anonymously and do not identify individuals.
We may use cookies to improve user experience. You can restrict or refuse cookies through your browser settings. For users in the EEA, we request explicit consent for non-essential cookies upon your first visit.
Article 3.3 — Legal Basis for Processing and Data Retention
For users in the European Economic Area (EEA) and the United Kingdom, we process personal data on the following legal bases under the EU GDPR and the UK GDPR:
- Performance of a contract (Art. 6(1)(b)) — to create and operate your account, deliver paid and free services, and provide personalized AI responses you have requested.
- Consent (Art. 6(1)(a)) — for non-essential cookies and analytics, and for optional marketing communications. You may withdraw consent at any time.
- Legitimate interests (Art. 6(1)(f)) — to secure our services, prevent abuse, and maintain and improve the website (not the AI models; see Article 3.1).
- Legal obligation (Art. 6(1)(c)) — to retain transaction and tax records as required by applicable law.
We retain personal data only as long as necessary for the purposes above:
- Account information (name, email, etc.): for the life of your account, and deleted within 6 months after account closure — except billing and tax records, which are retained for the period required by applicable law.
- AI conversation data: for the life of your account for personalization; deletable on request at any time; deleted when your account is closed.
- Analytics data: retained per Google Analytics' standard retention (currently up to 14 months) with IP anonymization enabled.
International transfers. Our servers and third-party AI providers may process data outside the EEA/UK. Where data is transferred internationally, we rely on appropriate safeguards such as the European Commission's Standard Contractual Clauses (and the UK Addendum) or an adequacy decision.
EU representative. Our processing of EEA personal data is occasional and small-scale and does not involve large-scale processing of special-category data; we therefore rely on the exemption in Art. 27(2) GDPR and have not appointed an EU representative. This will be reviewed as our service grows.
Article 4 — Changes to Purpose of Use
We will only change the purpose for which we use personal information when the new purpose is reasonably related to the original purpose. We will notify users or publicly announce any such changes.
Article 5 — Provision to Third Parties
We will not provide personal information to third parties without the user's prior consent, except in the following cases:
- When necessary to protect a person's life, body, or property, and obtaining consent is difficult
- When particularly necessary for public health or the sound development of children, and obtaining consent is difficult
- When cooperating with a government agency carrying out duties prescribed by law
- When transmitting data to third-party AI service providers for AI service delivery (as described in Article 3.1)
- When required by law
Article 6 — Disclosure of Personal Information
Upon request from the individual concerned, we will disclose their personal information without delay, except where disclosure would harm the rights or interests of a third party, significantly impede our business, or violate applicable laws.
Article 7 — Correction and Deletion
Users may request correction, addition, or deletion of their personal information held by us if it is inaccurate. We will respond promptly when we determine the request is justified.
Article 8 — Suspension of Use
If a user requests suspension or deletion of their personal information on the grounds that it is being used beyond the stated purpose, we will promptly investigate and act accordingly if the request is justified.
Article 9 — Rights of EEA and UK Users (GDPR / UK GDPR)
If you are located in the European Economic Area (EEA) or the United Kingdom, you have the following rights under the EU GDPR and the UK GDPR:
- Right of access: to request disclosure of the personal data we hold about you
- Right to rectification: to request correction of inaccurate data
- Right to erasure: to request deletion of your data
- Right to restriction of processing
- Right to data portability
- Right to object to our processing of your data
- Right to withdraw consent at any time, without affecting the lawfulness of processing carried out before withdrawal
- Right to lodge a complaint with a supervisory authority — your local EEA Data Protection Authority, or, in the UK, the Information Commissioner's Office (ICO)
To exercise any of these rights, please contact us at info@teracha.com. We will respond within 30 days.
Article 9.1 — California Privacy Rights (CCPA / CPRA)
If you are a California resident, you have the right to know what categories of personal information we collect (identifiers such as name and email, commercial information such as purchase history, and internet activity such as analytics data), the right to request access to and deletion of that information, the right to correct inaccurate information, and the right not to be discriminated against for exercising these rights.
We do not sell or share your personal information as those terms are defined under the CCPA/CPRA, and we have not done so in the preceding 12 months. To exercise your California rights, contact us at info@teracha.com.
Article 10 — Changes to This Policy
We may update this Privacy Policy from time to time. For significant changes, we will notify users at least 14 days before the changes take effect.
Article 11 — Data Controller and Contact
The data controller responsible for your personal information is:
TERACHA / Operator: Sora Terada (寺田大空)
2F-C Shibuya Dogenzaka Tokyu Bldg., 1-10-8 Dogenzaka, Shibuya-ku, Tokyo 150-0043, Japan
Email: info@teracha.com