Last Updated: January 9, 2025 Article 1 (Introduction) ReFlow Inc. (hereinafter referred to as "the Company") respects the privacy of users of Capsule (hereinafter referred to as "this App") and complies with the Act on the Protection of Personal Information (Personal Information Protection Act) and other relevant regulations. This Privacy Policy (hereinafter referred to as "this Policy") establishes how user personal information is handled in this App. By using this App, users are deemed to have agreed to this Policy. Article 2 (Information Collected) The Company collects the following information to provide the functions of this App: (1) Audio Data Audio files recorded by the user within this App. These form the core of the diary function. (2) Text Data Transcribed text from audio, AI-generated summaries, sentiment analysis results, tags, and text input by the user. (3) Settings Information User settings such as display settings, notification settings, and theme settings. (4) Purchase Information Information regarding subscription purchases via the App Store. Payment information is processed by Apple Inc., and the Company does not directly acquire it. (5) Device Identifiers This App does not collect device identifiers such as IDFA (Identifier for Advertisers) or IDFV (Identifier for Vendor). (6) Analytics Data This App collects only aggregated data to analyze usage. Collected data is non-personally identifiable aggregated data and does not identify individual users. Article 3 (Purpose of Use of Information) The Company uses collected information for the following purposes: • To provide and improve the functions of this App • For audio transcription and AI summary generation • To provide user support • To analyze service usage (for app improvement and user experience enhancement) • To respond to bugs or security issues in this App • To comply with laws and regulations Article 4 (Data Storage) User data is stored in one of the following ways: (1) Local Storage All data is stored only on the user's device. It is not sent to the Company's servers. (2) iCloud Sync If the user enables iCloud sync, data is synchronized via Apple Inc.'s iCloud service. Apple's privacy policy applies to data handling in iCloud. Article 5 (Provision to Third Parties) The Company will not provide user personal information to third parties except in the following cases: • With user consent • Based on laws and regulations • When necessary for the protection of human life, body, or property, and obtaining user consent is difficult However, data may be sent to the following external services to provide the functions of this App: (1) OpenAI API Audio data and text data are sent to OpenAI, Inc. for audio transcription and AI summary generation. The Company manages the credentials required for OpenAI API use and transmits user data securely. - Transmitted Data: Audio files, transcribed text, text for analysis - OpenAI Privacy Policy: https://openai.com/privacy/ - OpenAI Data Retention Policy: https://openai.com/policies/ (2) Apple iCloud If the user enables iCloud sync, data is synchronized via Apple Inc.'s iCloud service. - Apple Privacy Policy: https://www.apple.com/jp/privacy/ - iCloud Data Protection: Protected by Apple's end-to-end encryption technology. (3) Other Third-Party Services If utilizing other third-party services linked with this App (e.g., Todoist, Google Tasks, etc.), the privacy policies of those services apply. Article 6 (Data Security Management) The Company takes the following measures to ensure the security management of user personal information: • Local data is encrypted by iOS data protection features • iCloud sync data is protected by Apple's encryption technology • App lock function using passcode and biometric authentication is provided Article 7 (User Rights) Users have the following rights regarding their personal information: (1) Right to Request Disclosure Users may request disclosure of personal information held by the Company. For disclosure requests, please contact us via the "Support" screen in the App or using the contact information below. The Company will respond within 30 days of receiving a request. (2) Right to Request Correction If the content of personal information is incorrect, users may request correction. (3) Right to Request Deletion Users may request deletion of personal information. However, this does not apply if there is a legal obligation to retain it. (4) Right to Request Suspension of Use Users may request suspension of use of personal information. (5) Right to File Objection If notified of the purpose of use of personal information, users may object to usage based on said purpose. Note that since data in this App is stored on the user's device, users can delete it themselves via the settings screen. However, if iCloud sync is enabled, data on iCloud must be deleted separately from iOS settings. For inquiries regarding the exercise of rights based on this Privacy Protection Policy, please contact: ReFlow Inc. 302, 3-35-13 Jingumae, Shibuya-ku, Tokyo 150-0001 Representative Director: Sho Hokibara Email: admin@reflow-group.com Phone: 03-6824-0828 Website: https://reflow-japan.com Article 8 (Data Deletion) • Users can delete all data stored in this App by selecting "Delete All Data" from the settings screen • Uninstalling the App deletes all data on the device • If iCloud sync is enabled, data on iCloud must be deleted separately from iOS settings Article 9 (Children's Privacy) (1) Target Age This App is not intended for children under 13 years of age. (2) Parental Consent If a child under 15 uses this App, parental consent is required. Please refrain from using this App without parental consent. (3) Deletion of Personal Information If it is discovered that personal information has been intentionally collected from a child under 13, the Company will promptly delete such information. (4) Parental Inquiries If you have questions or concerns about your child using this App, please contact us via the "Support" screen in the App. Article 10 (Cookies and Tracking) This App does not use cookies. Furthermore, it does not use tracking technology to track user behavior. It does not request tracking permission via App Tracking Transparency (ATT). Article 11 (Policy Changes) The Company may modify this Policy as necessary. (1) Significant Changes If changes significantly affect user rights, advance notice will be provided via: - Notification function within the App - Pop-up display upon App launch - Email notification (if registered) (2) Minor Changes Minor changes (typo corrections, link updates, etc.) are effective immediately upon posting in the App. (3) Use After Changes The revised Policy becomes effective upon posting in the App. Continued use of the App after changes implies user agreement to the revised Policy. Article 12 (Governing Law and Jurisdiction) The interpretation and application of this Policy shall be governed by Japanese law. The Tokyo District Court shall have exclusive jurisdiction as the court of first instance for any disputes regarding this Policy. Article 13 (Personal Information Protection Principles) In addition to the Personal Information Protection Policy (Privacy Policy), the Company appropriately handles user personal information according to the following principles: (1) Transparency We provide clear and easy-to-understand information to users regarding the handling of personal information. (2) Purpose Limitation Personal information is used only within the scope of the purposes specified in advance. (3) Minimization We respect user privacy and collect only the minimum necessary personal information. (4) Security Management We implement appropriate security measures to prevent leakage, falsification, or loss of personal information. (5) Accountability We clarify the Company's responsibility regarding the appropriate handling of personal information. Article 14 (Consultation with Personal Information Protection Commission) If questions or concerns regarding this Policy are not resolved by inquiring with the Company, users may consult the following Personal Information Protection Commission. Personal Information Protection Commission Sangiin Giin Kaikan, 2-1-1 Nagata-cho, Chiyoda-ku, Tokyo 100-8974 Phone: 03-6831-7890 Website: https://www.ppc.go.jp/ Article 15 (Contact Us) For inquiries regarding this Policy, please contact us by the following methods: (1) In-App Inquiry Please contact us from the "Support" screen in the App. We typically respond within 2-3 business days. (2) Direct Inquiry Please contact the following: ReFlow Inc. 302, 3-35-13 Jingumae, Shibuya-ku, Tokyo 150-0001 Representative Director: Sho Hokibara Email: admin@reflow-group.com Phone: 03-6824-0828 Website: https://reflow-japan.com Operator: ReFlow Inc. Address: 302, 3-35-13 Jingumae, Shibuya-ku, Tokyo 150-0001 Representative Director: Sho Hokibara © 2025 ReFlow Inc. All rights reserved.