Privacy Policy

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Pululu Inc. ("we," "us," or "our") establishes this Privacy Policy ("Policy") regarding the handling of user information in connection with the applications, websites, and all other services provided by us (collectively, the "Service"), as follows.

1. Information We Collect

We may collect the following information about users in connection with providing the Service.

1-1. Information Provided by Users

  • Name, nickname, pen name, and other profile-related information
  • Age and date of birth
  • Gender
  • Email address
  • Profile images, posted images, videos, audio, and other content that users transmit or store through the Service
  • Inquiry details and other information included in communications sent to us

1-2. Information Obtained Through Third-Party Service Integration

If a user permits integration with Apple, Google, or other third-party services ("Third-Party Services"), we may obtain the ID used by the user for such Third-Party Services, profile information, and any other information that the user has authorized such Third-Party Services to disclose to integrated services through their privacy settings.

1-3. Information Automatically Collected Through Use of the Service

  • Cookies, advertising identifiers, analytics identifiers, and other similar identifiers
  • OS-generated IDs, device type, device identifiers, OS and device settings, app version, network information, and other information relating to the user's device and operating system
  • Browsing history, time spent, operation history, input history, purchase history, and other behavioral history on our website
  • App launch date and time, usage date and time, operation history, input history, purchase history, crash information, log information, and other usage history within our app
  • Location information (only where the user has granted permission through device settings or otherwise)
  • Call start/end times, call duration, connection status, communication quality, information relating to call counterparties, and other information necessary to provide calling features
  • Audio data, transcription data, source text for translation, translated text, text entered by users into AI-related features, AI-generated outputs, conversation context, and other information necessary to provide AI-related features
  • Payment-related information
    However, payment information itself, such as credit card information, may in principle be collected and managed not by us but by payment processors or platform operators.

2. How We Collect Information

We collect user information through the following methods:

  • When users register for, enter information into, post content to, make calls through, purchase through, or submit inquiries regarding the Service
  • When users authorize integration with Third-Party Services
  • Automatically through devices, browsers, operating systems, SDKs, cookies, advertising identifiers, analytics tools, and similar technologies as users use the Service
  • When users use AI-related features, translation features, transcription features, or similar functions

3. Purposes of Use

We use collected information for the following purposes:

  • To accept registrations for the Service and to verify identity and authenticate users
  • To manage users' usage history of the Service
  • To provide, maintain, protect, improve, and enhance the quality of the Service
  • To provide calling features, transcription features, translation features, AI response features, and other functions within the Service
  • To process payments and manage billing
  • To respond to user inquiries
  • To prevent, investigate, and respond to unauthorized use, unauthorized access, nuisance behavior, violations of our terms, and other improper use
  • To respond to incidents, conduct maintenance, prevent incidents, and take other measures necessary for security management
  • To provide notices regarding the Service, important announcements, maintenance information, changes to terms, changes to the Service, suspension or termination of the Service, and contract termination notices
  • To analyze usage of the Service and prepare statistical data
  • To deliver, display, and measure the effectiveness of advertisements tailored to users' interests and concerns
  • To provide recommendations, content, and targeted advertisements based on users' preferences and usage status
  • For purposes incidental to the foregoing

4. Use of Third-Party AI Services

We may use third-party AI services to provide speech transcription, translation, AI-generated responses, content generation, quality improvement, and other related functions in the Service.

4-1. Information Sent to Third-Party AI Service Providers

To the extent necessary to provide the relevant functions, we may send the following information to third-party AI service providers:

  • Audio data (when a user uses voice input, call translation, or voice-related features)
  • Speech transcription results
  • Source text for translation and translated text
  • Text entered by users into AI-related features
  • Recent conversation context necessary for AI response generation
  • Language settings and other minimum profile information necessary to provide the relevant functions
  • Identifiers or session information necessary for the use of AI features

4-2. Third-Party AI Service Provider

The third-party AI service provider we use is as follows:

  • OpenAI, L.L.C.

4-3. Purposes of Sending Information

We may send the above information to the third-party AI service provider for the following purposes:

  • Speech transcription
  • Translation
  • AI-generated responses
  • Provision of Service functions
  • Prevention of unauthorized use
  • Quality improvement and safety enhancement

4-4. User Consent

Where required under applicable law or under the rules of Apple or other platform operators, before sending users' personal data to a third-party AI service provider, we will clearly disclose the content of the information to be sent, the recipient, and the purpose of use, and obtain the user's consent in advance.

4-5. Management of Contractors and Providers

We require third-party AI service providers, through contracts or other appropriate means, to handle user information safely at a level equivalent to or greater than that required by us, and we provide necessary and appropriate supervision.

5. Provision to Third Parties

We will not provide personal data (as defined in Article 16, Paragraph 3 of the Act on the Protection of Personal Information of Japan) among users' information to any third party (including persons located outside Japan) without obtaining the user's prior consent.
However, this does not apply in the following cases:

  • When handling is outsourced to a contractor to the extent necessary to provide the Service
  • When outsourcing to businesses necessary for operation of the Service, such as payment, authentication, infrastructure, analytics, ad delivery, AI processing, and customer support providers
  • When personal data is provided in connection with business succession, merger, company split, share transfer, or similar events
  • When we jointly use data with business partners (in such cases, details will be separately disclosed in accordance with applicable law)
  • When disclosure is required by a court, administrative agency, regulatory authority, or other public institution pursuant to applicable law
  • When otherwise permitted under applicable law

6. Provision to Third Parties Located Outside Japan

In using cloud services, analytics tools, ad delivery services, third-party AI services, and other services necessary to operate the Service, we may provide user information to businesses located outside Japan or outsource the handling of such information to such businesses.
In such cases, we will provide necessary information and take necessary measures in accordance with applicable law.

7. Retention Period

We retain collected information for as long as necessary to achieve the purposes of use or for such period as required by applicable law.
After the expiration of the retention period, we will handle such information appropriately in accordance with applicable law, including by deletion, anonymization, or other suitable means.

8. Security Measures

We implement organizational, human, physical, and technical security measures to prevent leakage, loss, damage, unauthorized access, and similar risks relating to user information.

If you would like details regarding the specific security measures we have taken, please contact the inquiry desk listed at the end of this Policy, and we will respond individually in accordance with applicable law.

9. Analytics Tools

We may use analytics tools to understand how the Service is used and to improve the Service.
For example, we may use Google Analytics and similar analytics tools. These tools may collect information using cookies, device identifiers, and other technologies.

Such information is managed in accordance with the privacy policies and other terms established by the relevant providers.
Users may be able to restrict or disable the collection of information through cookies and similar technologies by changing browser settings, device settings, or using methods specified by the relevant providers.

10. Advertising

We may use advertising services provided by Google and other advertising providers and their partners.
These providers may use cookies, advertising identifiers, and other technologies to deliver, display, and measure advertisements based on users' past access history and usage information.

Users may be able to disable personalized advertising through their Google account ad settings or other methods specified by the relevant providers. Please refer to the policies and other materials of each provider for details.

11. Users' Rights

In accordance with applicable law, users may request that we disclose, correct, add to, delete, suspend the use of, erase, or stop third-party provision of their retained personal data.

If you wish to make any such request, please contact the inquiry desk listed at the end of this Policy.
We will verify the identity of the requester and respond appropriately in accordance with applicable law.

Please note that a handling fee of JPY 1,000 per request will be charged for requests for disclosure of retained personal data, regardless of whether disclosure is made.

12. Minors

If you are a minor, please use the Service only with the consent of your parent, guardian, or other legal representative.
Where we deem necessary, we may confirm whether such consent has been obtained.

13. Changes to This Policy

We may amend this Policy due to changes in applicable law, changes to the content of the Service, operational needs, or other reasons.
The effective date and content of any amended Policy will be announced or notified through display within the Service, posting on our website, or other methods we deem appropriate.

14. Contact Information

For requests for disclosure, correction, suspension of use, deletion, or other inquiries regarding user information or this Policy, please contact us at:

e-mail: info@pululu.co.jp

Depending on the nature of your request, we may ask you to provide a driver's license or other identification documents designated by us for identity verification.

15. Business Information

Business Name: Pululu Inc.

Representative: Masurao Sakurakichi

Address: PG Links Jinnan 5F, 1-11-4 Jinnan, Shibuya-ku, Tokyo, Japan

Established: January 08, 2025

Revised: March 10, 2026