Privacy Policy
This policy explains how tepgu consulting K.K. ("we", "us") handles personal information in the app Kage English ("the App"). In Japan the App is published as ペラ英会話 (formerly ペラペラ英語). We collect only what the App needs to work.
1. Who is responsible
tepgu consulting K.K. (tepgu consulting 株式会社), Japan
Address: 3-2-1 Mita, Minato-ku, Tokyo 108-0073, Japan (東京都港区三田3丁目2番1号 弓和三田ビジデンス604号室)
Representative: Ko Kousen
Email: KKousen@tepguconsulting.com
We decide why and how your personal information is used in the App (in the terms of data protection law, we are the "controller").
2. What we collect
Account
- User ID: an identifier created automatically the first time you open the App (a guest account), so that you can use it without signing up. Your learning data and your subscription records are stored under this ID. If you sign in, the ID is also associated with your sign-in details.
- Email address (optional): if you sign in with Apple or Google, or register by email. This may be the forwarding address of Apple's "Hide My Email". If you sign in with Google, we also receive the name and profile picture address of your Google account.
What you enter or create
- Profile (optional): nickname, gender, native language, English level.
- App language: the language you use the App in. It is sent with your requests so that the AI answers in your language.
- Learning data: the English texts you practise, pronunciation scores and feedback, your word list (words, phonetics, meanings, example sentences), your AI conversations and their reports, and your practice history.
- Voice recordings: shadowing recordings stay on your device for playback. Only when you ask for an AI pronunciation check is that recording sent, through our server, to Microsoft Azure for speech recognition. We do not keep recordings on our servers, and we do not use your voice to identify you.
- Voice input in AI conversations: what you say is turned into text by Apple's speech recognition, which may send the audio to Apple's servers. We receive only the text.
Please do not include sensitive information about yourself or other people, such as health details, in the texts you enter or in AI conversations.
Recorded automatically
- Usage counts: how many times you used each feature, to apply the free limits. They do not include content.
- Subscription information: your plan, its expiry date, and purchase, renewal and cancellation status. Payment is handled by Apple. We never receive your card or other payment details.
- Technical data: when the App contacts our servers, the hosting provider processes your IP address, and our servers keep operational logs for a limited time: your user ID, which feature was called, how long it took and the outcome (for example success or failure, a score, or your subscription status). If an error occurs, the log may also contain a short excerpt of the AI provider's response, so that we can find the cause.
What we do not collect
The App contains no advertising software and no software that follows your behaviour across apps or websites. We do not collect the advertising identifier (IDFA), your precise location, your contacts or your photos, and we do not track you across other companies' apps or websites. If you sign in with Google, Google may estimate your approximate location from your IP address to prevent fraud.
3. Why we use it
| Purpose | Information used | Legal basis under the GDPR, where it applies |
|---|---|---|
| Providing the App's features: shadowing, AI pronunciation check, AI conversation, dictionary and word list, native voices, translations | Account, learning data, app language, and a recording only when you ask for a check | Performance of our contract with you (Art. 6(1)(b)) |
| Saving your data and restoring it on another device | Account, profile, learning data | Performance of our contract with you |
| Managing subscriptions | User ID, subscription information | Performance of our contract with you; legal obligations such as accounting (Art. 6(1)(c)) |
| Applying the free limits, preventing abuse, keeping the service secure and fixing faults | Usage counts, technical data | Our legitimate interest in a fair and secure service (Art. 6(1)(f)) |
| Answering your questions | Email address and what you write to us | Performance of our contract with you; our legitimate interest in supporting users |
We do not use your information for advertising. AI scores and feedback are learning aids: we make no decisions about you by automated means that have legal or similarly significant effects.
Access to the microphone and to speech recognition is given through your device's permission settings. You can withdraw it at any time in your device's settings.
4. Who receives it, and transfers abroad
We do not sell personal information. To run the App we use the following providers. They process information on our behalf; Apple and Google also handle sign-in and purchases under their own terms and privacy policies.
| Provider | What for, and what is sent | Location |
|---|---|---|
| Supabase | Sign-in, database for your profile and learning data, running our server functions | Japan (Tokyo region); the company is in the United States |
| Microsoft (Azure AI Speech) | Native voice playback (the English text); speech recognition for pronunciation checks (the recording) | United States |
| Google (Gemini API) | Feedback for pronunciation checks, AI conversation, dictionary, example sentences, translations of practice texts (text only) | United States |
| Google (Sign in with Google) | Signing in with a Google account (account ID, email, name; Google may estimate your approximate location from your IP address to prevent fraud) | United States |
| RevenueCat | Subscription status (user ID, purchase information) | United States |
| Apple | Sign in with Apple, in-app purchases, speech recognition for voice input | United States |
Our company and our main database are in Japan. The European Commission and the United Kingdom recognise Japan as providing an adequate level of data protection. Where a provider processes information in the United States, the transfer relies on the provider's certification under the EU–U.S. Data Privacy Framework, which the European Commission has recognised as adequate, or otherwise on appropriate safeguards such as standard contractual clauses. You can ask us for details.
We use the paid version of the Gemini API. Under its terms, Google does not use the content we send, or the answers, to improve its products; it keeps them for a limited time in order to detect misuse.
Apart from these providers, we disclose personal information only when the law requires it.
5. How long we keep it
- We keep your account and learning data until you delete your account. Deleting the App from your device does not delete the data on our servers.
- You can delete your account and all learning data in the App: Profile → Delete account. This also deletes the record of subscription events that we keep for your account. You can also ask us by email; we act without undue delay, and within 30 days at most.
- You can export your learning data as a file: Profile → Export data.
- Voice recordings are not stored on our servers.
- Purchase records are kept by Apple and by our subscription provider (RevenueCat) under their own policies. We keep records that the law requires us to keep, such as accounting records.
- Operational logs on our servers are kept for a limited time and then deleted.
6. Your rights
Wherever you live, you can ask us to tell you what we hold about you, to correct it, to delete it, or to stop using it. Write to KKousen@tepguconsulting.com. We answer without undue delay, within the time that the law of your country sets and within 30 days at most. We may first ask you to confirm that the request comes from you. You can do much of this yourself in the App: edit your profile, export your data, delete your account.
If you live in the European Economic Area, the United Kingdom or Switzerland
You have the rights given by the GDPR and the equivalent laws: access, rectification, erasure, restriction of processing, data portability, and the right to object to processing based on our legitimate interests. Where processing is based on your consent, you can withdraw it at any time. You also have the right to lodge a complaint with the data protection authority of the country where you live or work.
If you live in the Republic of Korea
You have the rights given by the Personal Information Protection Act: to access your personal information, to have it corrected or deleted, and to have its processing suspended.
Your personal information is processed outside Korea as follows:
| Item | Details |
|---|---|
| Recipients and countries | The providers listed in section 4 (Japan and the United States) and tepgu consulting K.K. (Japan) |
| Information transferred | The information described in section 2 |
| When and how | Sent over encrypted connections when you use the feature concerned |
| Purpose | As described in sections 3 and 4 |
| Retention | Until you delete your account, or until the purpose has been fulfilled |
You may refuse this transfer by not using the App or by deleting your account; the App cannot be provided without it. For questions or complaints about personal information, write to us at the address above. You can also contact the Personal Information Infringement Report Center (privacy.kisa.or.kr, telephone 118) or the Personal Information Dispute Mediation Committee (www.kopico.go.kr, telephone 1833-6972).
If you live in Taiwan
Under the Personal Data Protection Act we inform you that: we collect the categories of personal data in section 2 for the purposes in section 3; we use them for as long as you keep your account, in the places where we and the providers in section 4 operate, by the means described in this policy; you may ask to inquire about or review your data, to receive a copy, to supplement or correct it, to have collection, processing or use stopped, and to have it deleted; and if you do not provide the data, the related features cannot be provided.
If you live in the United States
We do not sell personal information and we do not share it for cross-context behavioural advertising.
7. Security
All communication with our servers is encrypted (HTTPS). Access controls in the database keep other users from reading or changing your data. Authorised staff and the providers listed above can access it only as far as their work requires. Secret keys for the external services are kept on our servers and are not included in the App.
8. Children
The App is intended for people aged 13 and over; children under 13 must not use it. If you are under 18 (under 19 in the Republic of Korea), use the App only with the consent of a parent or guardian. This also applies in countries where the law sets a higher age than 13 for agreeing to the use of personal information (for example 16 in Germany, 15 in France, 14 in Spain and in the Republic of Korea). If we learn that we hold information from a child without the consent that the law requires, we will delete it.
9. Changes to this policy
When we change this policy we publish the new version on this page. We announce important changes in the App as well.
10. Language
This policy is published in several languages. For users in Japan the Japanese version prevails. For all other users the English version prevails if the versions differ, unless the law of your country gives priority to the version in your language.
11. Contact
tepgu consulting K.K.
KKousen@tepguconsulting.com