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)
• Subscription purchases made on iOS are processed by Apple through the App Store, and subscription purchases made on Android are processed by Google through Google Play. For App Store and Google Play transactions, Globify does not receive or store your payment card details; we receive only the transaction confirmations and the subscription status necessary to provide the Premium service.
• 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

We share personal information with the following categories of third parties: cloud hosting providers; analytics providers; payment processors (including Apple In-App Purchase and Google Play Billing for subscription transactions); email delivery services; and customer support tools. Any third party that receives personal information from Globify is contractually bound to provide privacy and security protections substantially equivalent to those described in this Privacy Policy and to use such information only for the purposes for which it was provided.

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.

On iOS devices, where any tracking would link your activity in the Globify app with your activity in other companies' apps and websites, we will request your permission via Apple's App Tracking Transparency ("ATT") framework before doing so. You may grant or decline this permission at any time in your iOS device settings (Settings → Privacy & Security → Tracking). Declining the ATT prompt does not affect your ability to use the Globify Service or your access to Premium features.

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 and Account/Data Deletion

Account and Data Deletion (All Users). All users, regardless of jurisdiction, may request deletion of their account and the personal information associated with it at any time. Account deletion may be initiated within the native app at Settings → Account → Delete Account, from your account settings on our website at globify.com, or by emailing legal@globify.com. Upon deletion, we will delete or de-identify your personal information within a reasonable period, except where retention is required or permitted under applicable law (for example, for tax, accounting, anti-fraud, or legal-compliance purposes), or where the information has been aggregated or anonymized in a manner that does not permit re-identification. Deleting your account does not automatically cancel any auto-renewing subscription purchased through the Apple App Store or Google Play; to cancel such a subscription, you must follow the cancellation procedures of the applicable app store.

Rights of Residents of Japan 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 thirteen (13). Where users between thirteen (13) and the digital-consent age of their jurisdiction use the Service with the consent of a parent or other legal guardian, we collect and process personal information about such users only with that consent and only as necessary to provide the Service. We do not knowingly collect personal information from children below the minimum age permitted in their jurisdiction. If we become aware that we have collected personal information from a child below such age without the required consent, we will delete that information promptly.

14. Changes to This Privacy Policy

We may update this Policy from time to time to reflect service changes or legal requirements. For material changes, we will provide reasonable advance notice — typically at least thirty (30) days before the changes take effect — by posting the updated Policy on our website or in the app, and, where appropriate, by other means such as email. Your continued use of the Service after the effective date of any update constitutes acceptance of the updated Policy.

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:
Globify, Inc.
Address: Moto Azabu 1-2-13-403, Minato-ku, Tokyo, Japan 106-0046
Email: legal@globify.com

‍17. 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.

Updated as of May 2, 2026.