Legal
Privacy Policy
This Privacy Policy explains how Sollo ("Sollo," "we," "us," or "our"), currently operated on a pre-incorporation pilot basis by its founders, collects, uses, shares, and protects personal information when you use the Sollo mobile app, web app, and related features (the "Services"). This Policy is designed to comply with Japan's Act on the Protection of Personal Information (個人情報の保護に関する法律, the "APPI") and other applicable data protection law. Capitalized terms not defined here have the meaning given in our Terms of Service.
Sollo is not yet incorporated. During this pilot, the Services are operated directly by Sollo's founders, who are personally responsible for them. Before any public or commercial launch, Sollo intends to incorporate a registered company in Japan, which will then assume operation of the Services. At that point, this section and the Contact Us section will be updated to reflect that entity.
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 information: name, email address, phone number, password, age confirmation, and preferred language.
- Profile and preference information: interests, solo-friendly activity preferences, and similar settings.
- Region and language preferences: the prefecture and, optionally, the municipality you select from a list, so we can show you locally relevant government information. This region is self-declared by you; we do not use GPS or precise device location to determine it.
- 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.
- Parallel Presence data: your location (only when you opt in), your visibility and engagement choices, and messages exchanged with other users.
- Solo Canvas content: journal entries, posts, photos, and the reactions you give and receive.
- 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, Solo Discovery recommendations, Parallel Presence, and Solo Canvas;
- 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 or for Parallel Presence location sharing, 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: only the information you choose to share, such as your display name and approximate proximity through Parallel Presence, or the content and audience you select for a Solo Canvas post.
- 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:
| Category | Retention period |
|---|---|
| Account information | Kept while your account is active, then deleted within 30 days of account deletion, except for a small set of records (such as those needed to prevent fraud or comply with a legal obligation) that we may keep for up to 1 year. |
| Companion AI conversations and Life Navigator inputs | Kept for 12 months from when you provide them, for safety monitoring, quality, and dispute-resolution purposes, then deleted or de-identified. If a conversation is flagged as part of an active safety or legal matter, we may keep the relevant portion longer, only for as long as that matter is open. |
| Answer feedback (thumbs up / down) | When you tap thumbs-up or thumbs-down on an AI answer, we store a snapshot of that answer, the question that produced it, and any optional reason or comment you add, so we can measure and improve answer quality. We keep these records for as long as needed for that purpose; you can request their deletion as described in Section 9. |
| Parallel Presence location data | Precise location is kept on a rolling basis for 30 days and then deleted; we may keep coarser, de-identified location patterns longer to improve the feature. |
| Solo Canvas content | Kept until you delete the post or your account; removed from backups within 90 days after deletion. |
| Device, log, and security data | Kept for up to 12 months for security and fraud prevention. |
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.
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
Much of the information you share through Life Navigator and the Companion AI relates to difficult, high-stakes, or vulnerable moments, such as job loss, separation, illness, financial hardship, or single parenthood. We design our data practices with this in mind: we restrict internal access to this information, do not use it for advertising or unrelated profiling, and do not share it with Institutional Partners, employers, or government bodies except where you direct us to or where legally required. Where the Companion AI detects signals consistent with a mental health crisis, as described in our Terms of Service, we may surface professional support resources to you; we do not use crisis-related signals for any commercial purpose.
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:
Data Protection Contact
info.sollomy@gmail.com
Supervisory Authority
Personal Information Protection Commission (PPC), Japan
ppc.go.jp
If you are not satisfied with our response, you may file a complaint directly with the PPC.