Handling of personal data

Privacy Policy

Last updated 28 May 2026

Please note: this is a provisional document for the development stage. It will be reviewed by Japanese legal counsel and updated to a final version when the service formally launches. Where this English text and the Japanese version differ, the Japanese version is the authoritative one.

1. Introduction

Tomorine, Inc. ("we," "us," or "our") regards the protection of your personal information as our highest priority. This Policy sets out how we handle the personal information we collect in connection with our service, "Tomorine" (the "Service").

We comply with Japan's Act on the Protection of Personal Information (APPI), together with its related regulations and the guidelines issued by the Personal Information Protection Commission of Japan (the "PPC"), and we strive at all times to handle your information appropriately.

This Policy applies to the adult family member who registers for and uses the Service (the "family member"), and to the parent or elder with whom Tomorine speaks (the "parent").

2. Information we collect

In providing the Service, we collect the following information.

2.1 Information about the family member

Email address, name (optional), and contact details
Household composition and prefecture of residence
Your history of use of the Service

2.2 Information about the parent

Audio recordings of conversations
Automatic transcripts of those conversations
Use history of the Service (such as conversation length and frequency)

2.3 Technical information

When you visit our website or use the app, we may receive limited technical information automatically, such as device type, operating system, and approximate access times, to keep the Service secure and working correctly. We do not use this information to build advertising profiles.

3. How we use information

We use the personal information we collect only for the following purposes:

To provide and operate the Service
To transcribe conversations and to generate the stories delivered to the family
To send you notices and information about the Service
To analyse and improve the quality of the Service, in a form that does not identify any individual

We will never use your personal information for any purpose beyond those listed above. We do not use your data for advertising, and we never sell or provide it to third parties for their own marketing.

4. Legal basis for handling your information

Under the APPI, we handle personal information on the following bases:

Your consent — for collecting and using conversation recordings, transcripts, and the other information described above
Performance of our agreement with you — where handling your information is necessary to provide the Service you have signed up for
Compliance with law — where we are required to retain or disclose information under applicable law

Where we rely on your consent, you may withdraw it at any time, as described in Section 8 ("Your rights"). Withdrawing consent does not affect the lawfulness of any handling carried out before withdrawal.

5. Cookies and similar technologies

Our website uses only the cookies and similar technologies that are strictly necessary to make the site function and to keep it secure. We do not use advertising cookies, and we do not use third-party tracking technologies that follow you across other websites.

Our website loads web fonts hosted by Google. As part of serving those fonts, your browser's IP address may be processed by Google. If you prefer, you can limit this by configuring your browser or network settings; the site will remain readable with your system's default fonts.

6. Data storage, security, and international transfer

6.1 Encryption

All communications are encrypted using TLS 1.3. Stored audio, transcripts, and other personal information are held in encrypted form using AES-256.

6.2 Where your data is held

Personal information is stored securely using reliable cloud services, including Cloudflare's object storage (R2), Google Cloud Platform, and Vercel. We have entered into appropriate data processing agreements with these service providers. Some of these providers' data centres are located outside Japan, so providing the Service may involve a cross-border transfer of personal information. Where this occurs, we take the measures required under the APPI to ensure your information continues to be protected.

6.3 Access controls

Access to personal information is limited to the personnel who need it to do their work, and is strictly controlled.

7. How long we keep your data

We keep personal information only for as long as it is needed for the purposes set out in this Policy.

While your account is active — conversation recordings, transcripts, and the stories delivered to your family are retained so that you can read and hear them.
After you cancel — the stories already delivered, and the voices within them, remain available in the app; new conversations are no longer recorded.
After a parent passes away — data on our servers is retained for five years and then deleted (see Section 11). You may request earlier deletion.
On request — we will delete personal information at your request, except where we are required by law to keep it.

8. Your rights

You may make the following requests to us regarding the personal information we hold about you:

Access — to confirm and review the information we hold
Correction, addition, or deletion — to ask us to fix or update your information
Suspension of use or erasure — to ask us to stop using, or to fully erase, your personal information
Withdrawal of consent — to withdraw consent you previously gave

When you make a request, we will, as a general rule, respond within 30 days. You also have the right to lodge a complaint with the Personal Information Protection Commission of Japan if you believe your information has been handled improperly.

9. Visibility between the family and the parent

The everyday conversations between a parent and Tomorine are not shared with the family. Only the stories that the parent has expressly agreed are "alright to share with the family" are delivered to the family's app.

The family side can never view raw conversation records, transcripts, emotional analysis, health scores, or anything similar.

10. Providing information to third parties

We will not provide your personal information to any third party, except in the following cases:

Where you have given your consent
Where required by law (for example, a legitimate request from a court or the police)
Where necessary to protect the life, body, or property of a person

Where we use service providers to operate the Service (such as the cloud providers named in Section 6), they handle personal information only on our instructions and under appropriate data processing agreements; this is not a provision of data to third parties for their own purposes.

11. After a farewell

If a user of the Service passes away, we will, free of charge:

Hand over to the family all of the voice recordings and transcripts gathered until then
Present the family with an e-book that gathers all of the stories into one
Retain the data on our servers for five years, and then delete it (we will also honour a request for earlier deletion)

We will never use the voice of someone who has passed away to generate new conversations.

12. Children

The Service is intended for use by adults. It is not directed to children, and we do not knowingly collect personal information from a child as the registering family member. The parent's participation in the Service is always set up and overseen by the registering adult family member. If you believe a child has provided us with personal information without appropriate consent, please contact us and we will delete it.

13. Governing law and jurisdiction

This Policy and the handling of personal information under it are governed by the laws of Japan. Any dispute arising in connection with this Policy shall be subject to the exclusive jurisdiction of the court with jurisdiction over the location of our registered office, as the court of first instance.

14. Contact and data protection

For questions or requests about how we handle personal information, please contact our data protection contact:

Tomorine, Inc. — Personal Information Protection Officer
Email: privacy@tomorine.com

15. Changes to this Policy

We may revise this Policy from time to time as needed. If we make a significant change, we will let you know in advance through a notice within the Service or by contacting you at your registered email address.

← Back to home