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
- We do not use conversation content for "service improvement", "quality monitoring", "marketing analysis", "training data", or any other purpose whatsoever. Our operators and staff do not read conversation content, except where strictly necessary to operate the service (for example, investigating a system fault). We provide no administrative feature that allows operators to read conversation content
- 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
- In addition to conversation content, we transmit to our AI processors the profile information you have provided for the purpose of tailoring responses to you
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 3.2.1 — Advertising Cookies (Meta Pixel)
We use the Meta Pixel, provided by Meta Platforms, Inc., to deliver and measure the performance of our advertising on Instagram and Facebook. Through cookies and similar technologies, information about your browsing of our website and whether you have registered for an account is transmitted to Meta. We do not provide your name, email address, or similar identifying details to Meta through this channel.
- Recipient: Meta Platforms, Inc. (United States)
- Purpose: delivery and performance measurement of our advertising
- When it loads: the tag is loaded only if you have consented to the use of cookies. It is not loaded before you consent, or if you decline.
- Members' screens: the tag is not loaded on screens shown to logged-in members (the learning screens used by children).
You can stop this transmission through your browser's cookie settings or through Meta's own Ad Preferences.
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. Cancelling a paid course does not delete your account; deletion occurs when you delete your account (see Article 7.1), at which point the data is erased immediately — 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; erased immediately when you delete your account.
- 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.
Country of transfer. The AI processing described in Article 3.1 is carried out by processors located in the United States. The United States has no comprehensive data protection law equivalent to Japan's Act on the Protection of Personal Information, and is not designated by Japan's Personal Information Protection Commission as a country with an equivalent level of protection. Our contracts with these processors prohibit use for any purpose other than the commissioned processing, prohibit use for training or improving AI models, and require appropriate security measures. We do not publish the names of these processors, as this constitutes information about our system architecture; you may request them via the contact point in Article 11.
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 transmitting information to Meta Platforms, Inc. through cookies and similar technologies for the delivery and performance measurement of our advertising (as described in Article 3.2.1)
- When required by law
Article 5.1 — Children's Personal Information
Some of our services are used by children.
- Where a child under 18 uses our services, the consent of a parent or guardian is required. Paid subscriptions must be taken out by a parent or guardian.
- Parents and guardians may exercise the rights of disclosure, correction, deletion, and suspension of use on behalf of their child.
- Where a service allows a parent or guardian to view a child's records, the child chooses which items are shared. The content of AI conversations is never shown to the guardian.
- We do not send advertising or marketing communications to children.
- For users in the EEA and the UK, where we rely on consent under Art. 6(1)(a) GDPR and the user is below the applicable age of digital consent, that consent is given or authorised by the holder of parental responsibility (Art. 8 GDPR).
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 7.1 — Account Deletion
You may request deletion of your account at any time from the account settings screen of the relevant service. Deletion is irreversible and erases the following:
- Account information (name, email address, login ID, profile, photo)
- AI conversation history and its summaries
- Records and reports generated from your use of the service
- Any content you have saved within the service, and your usage history
Transaction records that we are legally required to keep (such as payment records) are retained by our payment processor for the period required by law. If you hold an active paid subscription, you must cancel it before deleting your account.
If you are unable to complete this in the app, please contact us using the details in Article 11.
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