Privacy Policy

1. Scope of This Policy

This Policy applies to everyone who uses the Services, including Japanese nationals and foreign residents living in Japan, and users who access the Services from outside Japan. If you access the Services through an Institutional Partner (such as an employer, municipality, or university), that organization's own privacy practices may also apply to information it separately collects from you; please refer to your Institutional Partner's own policies for details about that relationship.

2. Information We Collect

2.1 Information You Provide to Us

• Account and profile information: your name, email address, date of birth, gender, and preferred display language. Your name and email address come from the Google or Apple account you use to sign in; your name can be edited, and your date of birth and gender are entered by you during onboarding.
• Region: the prefecture and, optionally, the municipality or postal code you enter, so we can show you locally relevant government information. You can also choose to let the app fill these in using your device's approximate (coarse) location; that lookup is processed on your device, only the resulting prefecture and municipality are stored, and we never collect GPS coordinates or precise device location.
• Life Navigator inputs: details about your situation that you choose to share to receive guidance, which may include employment status, household and family composition (for example, single-parent status), residency or visa status, income range, and similar life-event details.
• Companion AI data: your conversations, prompts, and feedback to the AI Features.
• Payment information: none at this time. The Services are free during this pilot phase, so we do not collect billing details, card numbers, or other payment information. If we introduce paid plans in the future, this Policy will be updated before any payment information is collected.
• Communications you send us: support requests, surveys, and feedback.

2.2 Information Collected Automatically

• Device and log data: device type, operating system, app version, IP address, and crash or diagnostic logs.
• Usage data: features used, session length, and interaction patterns.
• Your device's language setting, used to select a default display language for the app. We localize Life Navigator content to your area using the region you select yourself (see Section 2.1), not your IP address, and we do not use GPS or precise device location. On the web app, our analytics providers may infer an approximate, city- or country-level location from your IP address (see Section 12).
• Cookies and similar technologies on the web app, described further in Section 12.

2.3 Information From Other Sources

If you access the Services through an Institutional Partner, we may receive limited information confirming your eligibility for sponsored access. We also draw on publicly available government and municipal sources to build Life Navigator content; this source material is generally not personal information about you.

2.4 Special Care-Required Information (要配慮個人情報)

Some information you choose to share with Life Navigator or the Companion AI, for example details about a disability, health condition, or past criminal record relevant to a benefits inquiry, may constitute "Special Care-Required Information" under Article 2(3) of the APPI. We collect this category of information only based on your explicit, opt-in action (such as choosing to share it in a chat or form), and we apply additional internal access restrictions to it.

3. How We Use Your Information

We use the information described above to:

• Provide and personalize Life Navigator guidance and the Companion AI;
• Operate the Companion AI and monitor and improve its accuracy and safety;
• Detect, investigate, and prevent fraud, abuse, and violations of our Terms of Service, including attempts to bypass AI safeguards;
• Communicate with you about the Services, including updates, security notices, and, where you have consented or as otherwise permitted by law, marketing;
• Comply with our legal obligations and respond to lawful requests from public authorities; and
• Conduct aggregated, de-identified analysis to improve the Services, including ward-level or institutional insights that do not identify you individually.

4. AI Processing and Personalization

When you ask the Companion AI a question or generate a Life Navigator journey, the text you provide — which may include personal details you choose to share — is first sent to Sollo's own servers and then forwarded to a third-party large-language-model ("LLM") API provider, which generates the response. We currently use the Alibaba Cloud Model Studio (DashScope) API, running a Qwen model, for this purpose. Your input is transmitted to that provider and processed there to produce your answer, under the provider's API terms. We may change which LLM API provider or model we use as the product evolves; if we do, we will update this Policy to name the new provider.

Our own servers — which run the search and orchestration around the AI — are hosted by a cloud infrastructure provider that acts as our service provider for hosting and computing (an "entrustment" under Article 27, paragraph 5(i) of the APPI); that provider processes data on our behalf and does not use it for its own purposes. The LLM API provider described above is a separate company that processes your input to generate the AI Output. We retain certain prompts and AI Output for safety monitoring, misuse detection, and quality assurance, for the retention periods described in Section 8.

4.1 Your Companion AI Memory and Personalization

To make the Companion AI more helpful over time, a background step reviews your conversations and saves a short, personal "memory" about you on our servers. This memory can include details you have mentioned, such as your general situation, your residency or visa status, your household, the language you prefer to read in, and the topics you have explored, together with a brief one-line summary. This memory is generated using the same LLM API provider described above, is private to your account, and is re-used to personalize future answers. You can view and clear your Companion AI memory at any time in the app's settings; clearing it removes the stored details and summary, though it may make future answers less tailored to you.

5. Purpose Specification and Your Consent

Consistent with the APPI, we specify the purposes for which we use your personal information, as described in Section 3, and we do not use it beyond those purposes without appropriate notice or consent. Where we rely on your consent, for example for Special Care-Required Information, you may withdraw that consent at any time through your account settings, though doing so may limit your ability to use the related feature.

6. How We Share Your Information

We share personal information only as described below. We do not sell your personal information.

• Service providers (entrustees): cloud hosting and computing providers, the third-party large-language-model API provider that generates AI responses (described in Section 4), and customer-support tools, each bound by contractual confidentiality and security obligations, or by the provider's API terms, consistent with the APPI. We do not currently use payment processors, since the Services are free during this pilot; this category will be added if we introduce paid plans.
• Institutional Partners: limited, aggregated, de-identified usage statistics about their sponsored population, unless you separately and explicitly consent to share more.
• Other users: none. The Services do not currently include messaging, posts, or any other user-to-user features, and we do not share your personal information with other users.
• Legal and safety purposes: to comply with applicable law, respond to valid legal process, or protect the rights, safety, or property of Sollo, our users, or the public.
• Business transfers: in connection with a merger, acquisition, financing, or sale of assets, subject to continued protection of your information consistent with this Policy.

7. Cross-Border Data Transfers

Our cloud hosting and AI infrastructure may run on servers located outside Japan. Where this is the case, we rely on one of the mechanisms recognized under Article 28 of the APPI: your consent, given after we disclose the destination country and the protections in place; confirmation that the recipient maintains a personal information protection system equivalent to the APPI, which we monitor at least once a year; or transfer to a country or region recognized by Japan's Personal Information Protection Commission as offering an adequate level of protection. You can ask us at any time, using the contact details in Section 16, which countries our current infrastructure providers operate in and which of these mechanisms applies.

8. Data Retention

We keep different categories of information for different lengths of time, depending on why we collected it:

Where this Policy or applicable law requires longer retention for a specific purpose, we keep the relevant information only for as long as that purpose requires.

9. Your Rights Under the APPI

Subject to identity verification and any applicable legal exceptions, you have the right to:

• Request disclosure of the personal information we hold about you and the purposes for which we use it;
• Request correction, addition, or deletion of inaccurate personal information;
• Request that we stop using or delete personal information used beyond the stated purposes, obtained unlawfully, or no longer needed for the purposes for which it was collected;
• Request that we stop providing your personal information to third parties;
• Be informed, on request, of the categories of cross-border recipients of your information and the protections in place; and
• File a complaint with us or with Japan's Personal Information Protection Commission (PPC).

If you reside outside Japan, you may have additional rights under your local law (for example, the GDPR if you are in the EEA or UK), which we will honor to the extent applicable to our processing of your information. To exercise any of these rights, contact us using the details in Section 16. To delete your account, see sollo.my/delete-account.

10. Data Security

We use technical and organizational measures, including encryption in transit, access controls, and restricted internal access to sensitive categories of information such as Special Care-Required Information, designed to protect your personal information. No system is completely secure, and we cannot guarantee absolute security. If we become aware of a data breach affecting your rights or interests, we will notify you and the PPC as required by applicable law.

11. Children's Privacy

The Services are intended for users aged 18 and older, consistent with our Terms of Service. We do not knowingly collect personal information from anyone under 18. If we learn that we have collected personal information from a user under 18, we will take steps to delete it.

12. Cookies and Similar Technologies

Our website uses essential browser storage for choices you make on the site, such as remembering whether you accepted or rejected analytics cookies. We also use Google Analytics only if you choose to accept optional analytics cookies in the cookie banner. These analytics help us understand broad usage patterns, such as which pages are visited and how people move through the site.

You can reject analytics cookies from the banner and continue using the site. We do not use third-party advertising cookies to build cross-site advertising profiles of you.

13. International Users

The Services are designed primarily for residents of Japan, both Japanese nationals and foreign residents living in Japan, and are operated from Japan. If you access the Services from outside Japan, your information will be processed in Japan and, as described in Section 7, potentially in other countries where our service providers operate.

14. Sensitive Life-Event Data: Our Commitment

15. Changes to This Policy

We may update this Policy from time to time. If we make a material change, we will provide notice through the Services or by other reasonable means before the change takes effect.

16. Contact Us

Questions, requests, or complaints about this Policy or our handling of your personal information can be directed to: