Tokyo Gogaku Gakko inc. ("we," "us," or "our") sets out below our Privacy Policy (this "Policy") regarding the handling of personal information of users of our student application "N campus" (the "App").
If there is any discrepancy between this English version and the Japanese version of this Policy, the Japanese version shall prevail.
1. About the App
The App is a learning application for students enrolled at educational institutions (each, a "Partner Institution") that have licensed N campus, our learning management system (the "Service").
Use of the App requires an account issued by a Partner Institution. Users cannot register accounts on their own.
The App is intended for students aged 18 or older.
2. Information We Collect
(1) Information provided by your Partner Institution
- Name
- Email address
- Enrollment information, such as institution name, class, and student ID number
(2) Information you enter or upload in the App
- Profile photo (an image taken with your camera or selected from your device's photo library)
- Assignment answers (such as responses to multiple-choice questions)
- Audio recordings submitted for pronunciation assignments
- Images of characters you handwrite on screen for writing assignments
(3) Information collected automatically through your use of the App
- Learning records (dates and times of activity, number of sessions, streak counts, progress, and grading results)
- Usage logs, including login times and in-app activity
- Device information (operating system type and version, app version, device identifier)
- IP address
3. How We Use Your Information
We use the information we collect for the following purposes:
- To provide the App and the Service, verify your identity, and manage your account
- To enable teaching staff at your Partner Institution to grade your assignments and provide feedback
- To run automated pronunciation scoring (AI assessment) on submitted audio, which assists teaching staff in grading
- To record, manage, and display your learning progress and history
- To report enrolled students' learning status to the Partner Institution
- To respond to your inquiries
- To fix defects, improve quality, and develop new features
- To address violations of the App's terms of use
We do not use your information beyond the scope of these purposes.
Automated scoring results are provided as a reference to assist teaching staff. Your final grade is always determined by teaching staff at your Partner Institution.
4. Device Permissions
The App may request permission to access the following device features. You can change these permissions at any time in your device settings.
| Feature | Purpose |
|---|---|
| Camera | To take a photo for your profile image |
| Photo library | To select a photo for your profile image |
| Microphone | To record and submit audio for pronunciation assignments |
We use these features only for the purposes stated above. The App does not capture photos or record audio in the background.
5. Disclosure to Third Parties
(1) Disclosure to your Partner Institution
Assignments you submit through the App — including your answers, audio recordings, and handwritten character images — together with your grading results and learning records, are visible to teaching staff at the Partner Institution where you are enrolled.
This is essential to the purpose of the App, which is to allow teachers to grade your work and provide instruction. By using the App, you agree that this information will be shared with teaching staff at your institution.
(2) Other third parties
Except as described in (1) above, we do not disclose personal information to third parties without your prior consent, unless one of the following applies:
- Disclosure is required by law
- Disclosure is necessary to protect a person's life, body, or property, and it is difficult to obtain your consent
- Disclosure is particularly necessary to improve public health or promote the sound development of children, and it is difficult to obtain your consent
- Cooperation is necessary for a national or local government body, or a party commissioned by such a body, to carry out duties prescribed by law
We do not use your information for advertising purposes, and we do not sell or otherwise provide it to advertisers or other third parties for such purposes.
6. Service Providers
We may entrust all or part of the handling of personal information to external service providers to the extent necessary to achieve the purposes described in this Policy. In such cases, we exercise necessary and appropriate supervision over those providers. Our current principal service providers are:
| Provider | Service entrusted | Where data is held |
|---|---|---|
| Amazon Web Services, Inc. | Server hosting and file storage, including audio and images | Hong Kong |
| Microsoft Corporation（Azure AI Speech） | Automated scoring of pronunciation assignment audio | Japan |
| SpeechSuper | Automated scoring of pronunciation assignment audio (fallback when Azure is unavailable) | United States |
Where a provider listed above is located outside Japan, your personal information is transferred to that country. We require appropriate handling by contract so that the protection of personal information continues to be ensured at the destination. If you would like information about the data protection regime of a destination country, please contact us using the details in Section 11 of this Policy.
For automated pronunciation scoring, we send only the audio needed for scoring. It is not accompanied by your name or any other information that directly identifies you. We require by contract that providers do not use this data for any purpose other than scoring, and do not use it to train generative AI.
7. Retention and Deletion
(1) Retention period
Assignment answers, audio recordings, handwritten character images, and learning records are retained only for the period you are enrolled at your Partner Institution and for as long as necessary to achieve the purposes described in this Policy, after which they are deleted on a rolling basis. Where the agreement with your Partner Institution specifies a retention period, that period applies.
(2) When enrollment ends
If you graduate, complete your program, or withdraw from your Partner Institution, or if the agreement between your Partner Institution and us terminates, we will delete or return the relevant information within the period specified in that agreement.
(3) Account deletion
You may request deletion of your account from the "Settings" screen in the App. When we receive such a request:
- Your name, email address, phone number, date of birth, nationality, profile photo, and any other information that directly identifies you is promptly deleted or anonymized.
- Your account can no longer be used to sign in, and all issued access tokens are revoked.
- Grades, attendance, and other learning records may be retained in a form that does not identify you, so that your Partner Institution can keep its academic records.
A deleted account cannot be restored. Because accounts are issued and managed by Partner Institutions, please consult the administrator at your institution before deleting your account while you are still enrolled. You may also request deletion through that administrator or through our contact point in Section 11.
8. Your Rights
You may request that we disclose, correct, add to, delete, suspend the use of, or stop the third-party provision of your personal information.
To make such a request, please contact the administrator at your institution or our contact point in Section 11. We will verify your identity and respond within a reasonable period in accordance with applicable law.
9. Security Measures
We take necessary and appropriate measures to prevent the leakage, loss, or damage of personal information, including:
- Encrypting data in transit using TLS
- Storing passwords as cryptographic hashes
- Managing access permissions to prevent access beyond what is required for legitimate purposes
- Training and supervising our personnel
- Appropriately supervising our service providers
10. Changes to This Policy
We may revise this Policy in response to changes in law or changes to the App's features. If we make a material change, we will notify you in advance through the App or by posting notice on our website.
11. Contact Us
For questions about this Policy or our handling of personal information, please contact:
- Tokyo Gogaku Gakko inc.
-
Address: 5-1-1 Higashi-Ikebukuro, Toshima-ku, Tokyo, Japan
Email: [email protected]
Hours: Weekdays, 9:00 – 17:00 (Japan Standard Time)
End of Policy