Privacy Policy

This Policy sets out how TopCloud Co., Ltd. (the "Company") handles personal information in "リアツウ" (the "App"), the real-time speech translation and meeting-minutes app it provides. Because the App translates meetings and in-person conversations in real time and produces meeting minutes, it handles users' audio and the content of their conversations.

1. Company Information

The Company's address and the name of its representative will be provided without delay upon request to the contact point in Section 13.

2. Categories of Information Collected

2.1 Account and authentication information

Signing in is required in order to use the core features of the App. Where you sign in with Apple, Google or LINE, we collect the user identifier issued by that service and your email address (for Apple and Google, only where that service notifies us that it has been verified there); where you register with an email address and a password, we collect your email address. Where a name hint is sent when signing in with Apple, it is stored as the initial value of the nickname only when the account is first created (it does not overwrite an existing nickname). We also handle the 6-digit verification codes sent for email verification, password reset and change or addition of an email address. The form in which email addresses, user identifiers, passwords and verification codes are stored is described in Section 8.

2.2 Device information

The device identifier (a UUID generated by the Company), the platform type, the dates and times of registration, of last use and of revocation, and information relating to device verification (Apple App Attest). A hash of the requesting IP address is used in device verification requests (the IP address itself is not stored). There is a limit on the number of devices that may be used concurrently on one account; registered devices can be reviewed and de-registered from the settings screen. The device model name and the OS version are also collected.

2.3 Profile information

A nickname and a profile image (both optional). An uploaded image is stored after being regenerated from its pixels on the server, which removes accompanying information (metadata) such as the date, time and location of capture. Instead of uploading an image, a colour may be chosen from a prepared set.

2.4 Translation content and meeting minutes

Source text and translated text, language settings, the time of occurrence, the side of the speaker in a conversation (own side / other side), importance marks, the session title, excerpt, start and end times and seconds used, and the body of the minutes (summary, topics, decisions, to-dos, open items) together with their revision history (up to the most recent 10 revisions per session). The App does not perform speaker identification (identifying individuals by voiceprint or the like) and does not store information for that purpose.

2.5 Usage-time and advertising information

Records of the grant and consumption of available time, records of AI usage, and records of time granted for rewarded advertising (a single-use random identifier newly generated by the Company for each advertisement watched, the ad placement, and the outcome of the grant). The verification signature and key identifier received from Google are not stored.

In addition, the Company collects records of ad delivery status (whether an ad was requested, loaded, unavailable, failed, shown, rewarded or closed early; the ad placement; the ad format; the ad network; the platform type; and the date and time) and records of the revenue for each ad impression as notified by Google's advertising SDK (the amount, the currency, the precision category of the amount, the ad unit ID, the ad placement, the ad format, and the date and time), linked to the account ID and to the device identifier (Section 2.2). These records do not include the advertising identifier (Section 10).

2.6 Communication information

Ordinary access logs are not recorded (HTTP access logging is disabled in the reverse proxy in front of the servers). For the purpose of limiting excessive requests over a short period, IP addresses are counted in the server's memory, and where a request is limited, the warning log recording that fact includes the IP address. The IP addresses and email addresses used for rate limiting of sign-in-related operations are converted into keyed hashes before being stored. The App contains no third-party SDKs for crash reporting, analytics or similar purposes (records of malfunctions are collected directly by the Company as described in Section 2.7).

In addition, to understand the use of older versions of the App (versions earlier than 1.1.0) and to decide when to end compatibility support for them, the Company records, for each day on which an older version communicates with the servers, the account ID (or, where the user is not signed in, the device identifier (Section 2.2)), the date, the times of the first and last communication on that day and the number of communications (daily records of older-version use). These records contain neither IP addresses nor the content of the communications.

2.7 Records of malfunctions

Where a communication failure, an error of the Company's servers or of the translation service, or any other malfunction occurs in the App's translation features, the Company collects its details (the type and code of the error, a summary of the error information returned by the translation service, the usage mode, the session identifier, the platform type, the app version, the device model name, the OS version, the network type, and the date and time of occurrence), linked to the account ID and to the device identifier (Section 2.2). These records do not include audio, source text or translated text.

3. Purposes of Use

1. Account registration, sign-in, identity verification and prevention of improper use
2. Provision of the real-time speech translation feature, and storage, synchronisation and display as history of translation results
3. Generation, editing, revision management of meeting minutes and provision of sharing links
4. Grant and management of the translation time available free of charge, delivery of advertising, verification of time granted for watching advertising, and prevention of improper acquisition of rewards, as well as understanding ad delivery status and advertising revenue
5. Responding to enquiries
6. Stable operation of the App, incident response, security, and understanding usage
7. Responding to conduct that breaches the terms of service, and responding to requirements of law or requests from public authorities

The Company does not use the content of users' translations or minutes to train its artificial intelligence models.

4. Handling of Audio Data

Capture: the microphone operates only while the user has explicitly started a translation session and stops capturing immediately when the session ends. Because iOS background audio mode and an Android foreground service are used, a continuously visible indication is shown on the device during a session.

Destination: the audio captured is sent directly from the native layer of the App to the speech translation service (DashScope) that Alibaba Cloud provides in the People's Republic of China (Beijing region) and does not pass through the Company's servers. The connection uses a temporary token valid for 120 seconds that the Company's servers issue after confirming the user's entitlement. The handling of the data at the destination is described in Section 5.1.

Whether it is stored: the Company does not store the audio itself at all. There is no route by which the Company's servers receive audio and no processing that writes audio to a file, a database or object storage. No audio files are stored on the device either. What the Company's servers receive is only the text after speech recognition and translation have been completed.

Where third parties speak: in the meeting translation feature, the speech of participants other than the user is also captured and sent by the route described above. Responsibility for explaining in advance to those participants how their audio and statements are handled, and for obtaining any necessary consent, rests with the user. Please use the App in compliance with the laws and regulations, the rules of your organisation and the rules of the meeting body that apply to recording and to the preparation of minutes.

5. Provision to Third Parties and to Third Parties in Foreign Countries

5.1 Provision to a third party in a foreign country (Article 28 of the Act on the Protection of Personal Information)

The Company provides personal data to a third party in a foreign country as follows. This provision is indispensable to the translation features of the App and, without consent to it, the core features of the App cannot be used. This consent is stored as an independent consent record, separate from agreement to the terms of service and this Policy.

The Company cannot determine from its own implementation whether, or for how long, the recipient retains audio or other information.

5.2 Other transmissions of information to third parties

In order to deliver and display advertising, the information needed for that delivery is sent to Google (AdMob). For rewarded advertising, a single-use random identifier newly generated by the Company for each advertisement watched and the internal ID identifying that viewing are sent in order to verify the grant. That identifier differs from the Company's account ID, device ID and email address. Google may, as an advertising provider, independently obtain advertising identifiers and other information through its advertising SDK. Please see Google's privacy policy for details.

In addition, where social sign-in is chosen, the Company makes ID token verification requests to the public keys and verification endpoints of Apple, Google or LINE in order to confirm the validity of the sign-in.

5.3 Provision under laws and regulations

The Company does not provide personal data to third parties without the prior consent of the individual, except where required by law or where another exception provided for in the Act on the Protection of Personal Information applies.

6. Subcontractors

To the extent necessary to provide the App, the Company entrusts servers (ECS) and storage of database backups (OSS) to Alibaba Cloud, both of which are provided in Japan (Tokyo region ap-northeast-1). The Company exercises the necessary and appropriate supervision of its subcontractor in accordance with law.

7. Storage Location and Retention Periods

The App's servers and database are located in Alibaba Cloud's Japan (Tokyo) region. Database backups are stored in private object storage in the same Tokyo region with server-side encryption enabled.

Even where a user deletes records or withdraws, that information remains in backups taken before that point for as long as those backups are retained.

8. Security Measures

• The employees who handle personal data and the scope of their handling are limited. In order for the Company's operations personnel to view the content of a user's translations or minutes in plaintext, an individual viewing permission valid for 48 hours must be granted for each session concerned with a stated reason, and grant, exercise and expiry are all recorded in the audit log.
• Communications between devices and the Company's servers are encrypted with TLS 1.2 or TLS 1.3. The database is not exposed to the public network, and the configuration is such that only the necessary functions are reachable from outside over HTTPS. The servers and backups are managed in Alibaba Cloud data centres (Tokyo region).
• Email addresses and social sign-in identifiers are not stored in plaintext; they are stored only as a keyed hash used for equality lookups and as AES-256-GCM ciphertext. Nicknames are stored only as such ciphertext. Translated text, session titles and excerpts, and the body of minutes are stored encrypted field by field with AES-256-GCM using a per-session key, and that key is stored only in a state encrypted by a higher-level key. The servers do not start unless the encryption keys are configured, which closes off any route by which such data could be stored in plaintext.
• Passwords are not stored in plaintext; only a value derived by scrypt after pre-processing with a server-side secret is stored, and progressively longer account lockouts are applied to repeated incorrect entry. Only a keyed hash of each verification code and only a hash of each refresh token are stored, and where improper reuse of a token is detected the related tokens are revoked together.
• Credentials, encryption keys and the fields corresponding to the body of translations and minutes are automatically redacted when logs are written. Translation history stored on the device has the file protection features provided by the operating system applied to it and is excluded from operating-system backups.

9. Requests for Disclosure, Correction, Suspension of Use and the Like

9.1 Operations you can perform yourself in the App

Changing your nickname and profile image, changing your email address (using the current password and a verification code sent to the new address), de-registering a device, deleting translation records and minutes individually or in bulk, exporting minutes in PDF or DOCX format, and withdrawing (deleting the account) can all be done from the settings screen.

9.2 Requests to the Company

You may request notification of the purpose of use of retained personal data, disclosure (including provision by electromagnetic record), correction, addition or deletion of its content, suspension of its use or its erasure, cessation of provision to third parties, and disclosure of records of provision to third parties. Please contact dev@topcloud-japan.co.jp by email from the email address registered to your account. The Company treats the fact that the contact comes from the registered email address as verification of identity, and where a request is made by an agent we ask for a document evidencing the authority to act. There is no fee. The Company will respond without undue delay after receiving a request and will reply with the outcome to the registered email address. There is no feature for exporting your complete registered information in a single operation, so requests for disclosure are handled individually through the point of contact above.

9.3 Withdrawal (deletion of the account)

At the point a request is made, the Company immediately places the account in a suspended state, revokes all registered devices and sign-in states, and deletes any sharing links for minutes that have been issued. After 30 days have passed from the request, automated processing erases the account, registered devices, credentials, encryption keys, translated text, minutes and their revision history. Records of the grant and consumption of available time, records of AI usage, records of advertising rewards, records of ad delivery status, records of advertising revenue, the Company's internal operation records and audit logs of administrative operations are retained, with information identifying the user (account ID, device ID, session ID and the like) removed, because they are necessary for accounting and audit purposes.

Before the 30 days have passed, you may contact dev@topcloud-japan.co.jp to discuss restoring the account. Sharing links that have been deleted are not restored, however.

10. Cookies and Advertising Identifiers

• The App does not track users using cookies. Settings such as display language and advertising intervals are kept in on-device storage and are not sent to the Company's servers.
• In order to deliver advertising, Google's advertising SDK may use the device's advertising identifier (IDFA on iOS, advertising ID on Android). Resetting the advertising identifier and opting out of personalised advertising can be done in the device settings.
• In regions where consent is required, a consent screen provided by Google's User Messaging Platform (UMP) is displayed. Advertising is personalised only where the user consents on that screen, and the partner advertising networks are those shown on that screen. Where the consent needed to deliver advertising is not obtained on that screen, the App displays no advertising.
• The App does not make an App Tracking Transparency (ATT) permission request on iOS. The iOS privacy manifest (PrivacyInfo.xcprivacy) declares that no tracking is performed (NSPrivacyTracking=false).

11. Use by Minors

The App is intended primarily for business use and does not verify the age of users. Minors must obtain the prior consent of a parent or other legal representative before using the App and providing personal information.

12. Revision of this Policy

The Company may revise this Policy in response to amendments to laws and regulations, changes to the features of the App or other reasons, and in that case will publish the revised content and the effective date on this page. Where a change has a material effect on users, the Company will give notice within the App or by another appropriate method and may ask for consent again. The Company records the version of this Policy that the user has agreed to and the date and time of that consent.

13. Enquiries and Complaints

Enquiries about this Policy, requests concerning retained personal data, and complaints about the handling of personal information should be submitted by email to the Personal Information Enquiries Desk of TopCloud Co., Ltd. (dev@topcloud-japan.co.jp). The Company's address and the name of its representative will be provided without delay upon request to that contact point.

14. Effective Date and Revision Information

• This version: privacy-v3
• Date of enactment: 2026-09-16
• Date of revision: 2026-10-10
• Effective date: 2026-10-10

"This version" is the same value as the version identifier the Company uses to record consent to this Policy. When the body of this Policy is revised, both are updated to a new value at the same time, and in that case users are asked to consent to this Policy again at their next sign-in.