Globify Privacy Policy

1. Introduction

This Privacy Policy explains how Globify, Inc. (“Globify”, “we”, “our”, or “us”) collects, uses, stores, shares, and protects personal information of users located in Japan. This Policy complies with the Act on the Protection of Personal Information of Japan (“APPI”) and other applicable Japanese regulations. By using our services, you agree to the practices described in this Privacy Policy.

2. Data Controller

Globify, Inc. is the Personal Information Handling Business Operator (“PIHBO”) under the APPI and is responsible for managing your personal information.

3. Categories of Personal Information We Collect

We may collect the following types of personal information:

• Account information: name, email address, password
• Service usage data: learning activity, device information, access logs
• Payment and billing information: subscription details (processed through third-party payment processors)
• Cookies and tracking data (see Section 10)
• User-generated content: flashcards, notes, preferences
• Communication data: inquiries and support requests
• Infringement notice data: Information provided in copyright or rights infringement notices, such as claimant details or user identifiers.

4. Purpose of Use

We use personal information for the following purposes:

1. To provide and operate the Globify service
2. To customize learning content and user experience
3. To maintain and improve system functionality
4. To process payments and manage subscriptions
5. To respond to inquiries and provide customer support
6. To prevent unauthorized use and maintain service security
7. To comply with Japanese laws and administrative requests
8. To process and respond to legal notices, such as DMCA takedown requests or rights infringement claims, including disclosure where required by law.
   

We will not use your personal information beyond these purposes without obtaining your prior consent, unless permitted by law.

5. Legal Basis Under APPI

Under the APPI, Globify processes personal information based on:

• Your consent
• Necessity for providing contracted services
• Compliance with legal obligations
• Legitimate business necessity where permitted by APPI

6. Provision of Personal Information to Third Parties

We do not provide your personal information to third parties except:

• Where you provide express consent
• Where required by law
• Where outsourcing to service providers within the scope of the stated purposes
• Where necessary to protect life, body, or property and obtaining consent is difficult

7. Outsourcing to Service Providers

We may entrust the handling of personal information to cloud providers, analytics companies, payment processors, email delivery services, and other subcontractors. All service providers are bound by confidentiality and security obligations consistent with APPI.

8. International Data Transfers

Your data may be transferred and stored outside Japan, including servers operated in other jurisdictions. When transferring personal information internationally, we implement appropriate safeguards to ensure equivalent protection, including evaluating foreign privacy regimes and ensuring contractual protections where necessary.

9. Data Retention

We retain personal information only as long as necessary to fulfill the purposes of use, comply with legal obligations, resolve disputes, and maintain business records.

10. Cookies and Tracking Technologies

Globify uses cookies and similar tracking technologies to enable core functionality, analyze usage, and improve the service. Details of how cookies are used are described in our Cookie Policy, which forms part of this Privacy Policy.

11. Security Measures

We implement necessary and appropriate security measures to prevent unauthorized access, loss, destruction, falsification, or leakage of personal information. These measures include:

• Access control
• Encryption
• Monitoring and logging
• Staff training
• Vendor risk management

12. User Rights Under APPI

Residents of Japan have the following rights regarding their personal information:

• Right to request disclosure of retained personal information
• Right to request correction, addition, or deletion of inaccurate information
• Right to request suspension of use or deletion
• Right to request cessation of third-party transfers

Requests will be handled promptly in accordance with APPI

13. Children's Privacy

Globify is not intended for children under 13. We do not knowingly collect personal information from children without appropriate parental consent as required by law.

14. Changes to This Privacy Policy

We may update this Policy from time to time to reflect service changes or legal requirements. Material changes will be notified on our website or app.

15. Application

This Privacy Policy applies to all users located in Japan and to users in all other jurisdictions except those situated within the European Union (“EU”) or the European Economic Area (“EEA”). Users located in the EU/EEA are subject to Globify’s GDPR Privacy Policy, which governs the collection and processing of personal data in accordance with the General Data Protection Regulation. The GDPR Privacy Policy is available at:
GDPR Privacy Policy.

16. Contact Information

For privacy-related inquiries or APPI rights requests, please contact:
legal@globify.com

Transitional EU/EEA Status. 

As of the “Last Updated” date of this Privacy Policy, Globify does not actively market or offer the Services to users located in the EU/EEA. If and when Globify begins offering the Services to users in the EU/EEA, those users will be subject to Globify’s GDPR Privacy Policy, which will include all EU/EEA-specific information and contact details required under applicable law.