LEGAL

Privacy Policy

Last updated: June 30, 2026 / Effective: May 10, 2026

ReTicLab ("we", "us") complies with Japan's Act on the Protection of Personal Information ("APPI") and other applicable laws in handling the personal information of users of our mobile application "Pocovo" (the "Service"), in accordance with this Privacy Policy (this "Policy").

1. Business Operator Information

  • •Business name: ReTicLab
    * Sole proprietorship. The proprietor's name will be disclosed without delay upon request.
  • •Address: Osaka Ekimae Dai-2 Building 12-12, 1-2-2 Umeda, Kita-ku, Osaka-shi, Osaka 530-0001, Japan
  • •Contact: [email protected]
  • •Personal information protection manager: Representative of ReTicLab

2. Personal Information We Collect and Purposes of Use

In providing the Service, we collect the following personal information and use it for the purposes described below.

(1) Account information

  • •Information collected: Email address, the identifier and display name provided by Apple ID or your Google account
  • •Purpose of use: Account authentication, identity verification, responding to inquiries, and preventing fraudulent use

(2) Learning content

  • •Information collected: The content of decks and flashcards you create (terms, meanings, example sentences, etc.), learning/recall status, and reference information for attached images
  • •Regarding sync: Learning content is stored on our servers to sync across multiple devices only for users subscribed to a paid plan (Pro or Max). For users without a subscription, learning content is never sent to our servers and is stored only on the user's device.
  • •Regarding image files themselves: The image files attached to cards are stored only on the user's device, regardless of subscription status.
  • •Purpose of use: Providing the Service's features and syncing across multiple devices

(3) Subscription information

  • •Information collected: Subscription status (Pro / Max), subscription identifier, purchase date, and renewal date
  • •Regarding payment information: Credit card numbers and other payment information are managed by the store from which you purchased (Apple Inc. or Google LLC); we never receive this information.
  • •Purpose of use: Providing subscription features, verifying billing status, and handling cancellations and refund procedures

(4) Photos handled by the automatic card-import feature (Max plan only)

  • •Information collected: Photos you capture or upload using this feature
  • •Regarding cross-border transfer: When you use this feature, the captured photos are sent to an overseas (U.S.) analysis vendor that we engage as a subcontractor, where text is extracted from the photos. We do not persistently store the photo files themselves on our servers.
  • •Purpose of use: Providing the automatic card-import feature

(5) Image search queries

  • •Information collected: Search keywords you enter using the image search feature
  • •Purpose of use: Providing the image search feature and preventing fraudulent use

(6) Technical and diagnostic information

  • •Information collected: Device model, OS version, app version, app crash information, and error logs
  • •Handling: We collect this information in a form that does not include information that identifies you personally (e.g. email address, IP address, screenshots).
  • •Purpose of use: Stable operation of the Service, investigating and fixing defects, and maintaining and improving service quality

(7) Information related to the referral program

  • •Information collected: The referral code issued to each user, the referral relationship (referrer and referee), and a hash (SHA-256) of the requesting IP address at the time a referral code is entered
  • •Handling: IP addresses are stored only after hashing; we do not retain raw addresses. Hash values are retained for a maximum of 30 days and then automatically deleted.
  • •Purpose of use: Providing the referral program and detecting and preventing fraudulent use (self-referrals, multiple accounts, bots, etc.)

3. Provision of Personal Information to Third Parties

We do not provide personal information to third parties without your prior consent, except in the following cases:

  • •Where required by law
  • •Where necessary to protect a person's life, body, or property and it is difficult to obtain the person's consent
  • •Where particularly necessary to improve public health or promote the sound development of children and it is difficult to obtain the person's consent
  • •Where cooperation is necessary for a national or local government agency to perform its legally prescribed duties
  • •Where provided in connection with a business succession, such as a merger

We may outsource part of our operations (cloud hosting, authentication and billing processing, analysis processing, error monitoring, use of the image search API, etc.) to external vendors. Provision of personal information in connection with such outsourcing does not constitute "provision to a third party" under Article 27, paragraph 5, item 1 of the APPI. We enter into appropriate agreements with each subcontractor regarding the handling of personal information and exercise necessary and appropriate supervision.

4. Cross-Border Transfer to Third Parties

Our principal subcontractors are located in the United States, and your personal information may be transferred there. We implement appropriate measures with recipient vendors (such as standard data processing agreements) pursuant to Article 28 of the APPI and its implementation rules. An overview of personal information protection systems in the United States and other countries is available on the website of Japan's Personal Information Protection Commission (https://www.ppc.go.jp/personalinfo/legal/kaiseihogohou/).

5. Retention Period

We retain personal information only for as long as necessary to achieve the purposes of use. If you delete your account, personal information on our servers will be deleted within a reasonable period (typically within 30 days). Additionally, if a paid plan that includes cloud sync is cancelled and the account reverts to the Free plan, learning data (decks/cards) already synced to our servers will be automatically deleted 30 days after the plan change (data on your device is unaffected, and re-subscribing will re-sync it). However, information that we are legally required to retain will continue to be retained for the applicable statutory period.

6. Security Measures

We implement reasonable organizational, human, physical, and technical security measures to prevent the leakage, loss, or damage of personal information. These include, among others: review of handling practices by our personal information protection manager, encryption of communications (HTTPS via TLS), minimization and periodic review of access privileges, storage of authentication credentials in secure on-device storage, and appropriate agreements with subcontractors regarding personal information protection.

7. User Rights and Procedures for Requests

Under the APPI, you may request notification of the purpose of use, disclosure (including records of provision to third parties), correction, addition, or deletion, suspension of use or erasure, and suspension of provision to third parties, of your personal information.

You may delete your account and server-side data at any time yourself via "Settings → Account → Delete Account" within the Service. For other requests, please contact us at the address listed in Section 13.

  • •Identity verification: We verify your identity by confirming that the email address used for the request matches the email address registered to the account. If it does not match, we may ask you to verify your identity by other reasonable means.
  • •Response time: We will respond within a reasonable period (in principle, within 2 weeks) after receiving your request.
  • •Fees: There is no fee for disclosure and related requests.

8. Response to Data Breaches

In the event of a leakage, loss, or damage of personal information, or any other event falling under Article 26, paragraph 1 of the APPI (or a suspicion that such an event has occurred), we will conduct the necessary investigation and, in accordance with applicable laws and guidelines, report to the Personal Information Protection Commission and notify affected individuals.

9. Children's Personal Information

The Service is not directed to individuals under the age of 13, and individuals under 13 may not use the Service. If we become aware that we have inadvertently collected personal information from a person under 13, we will promptly delete such information.

10. Analytics and Advertising

The Service (the app) and our website do not use any third-party advertising networks. We also do not employ behavioral targeting or analytics technologies intended to identify or track you personally.

Our website uses cookie-free, aggregate analytics to understand overall visitor trends across the site. The data collected by this analytics tool is limited to statistical information such as page views, referrers, and device type, and does not include any information tied to an individual user.

11. Complaints and Accredited Personal Information Protection Organizations

Complaints regarding our handling of personal information may be directed to the contact listed in Section 13. We are not currently a member of any accredited personal information protection organization. Complaints regarding this Policy may also be filed with the Personal Information Protection Commission (https://www.ppc.go.jp/).

12. Changes to This Policy

We may change this Policy due to changes in applicable law, changes to the Service, or other reasons. Where a change is material, we will provide reasonable advance notice within the Service or on our website.

13. Contact

For inquiries regarding the handling of personal information, disclosure requests, complaints, or any other matter, please contact us using the details below.