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Consolidated Privacy Policy – KOMODO Station

Introduction

KOMODO Co., Ltd. and its subsidiaries and affiliates, including KOMODO HAWAII LLC (collectively, “we,” “Komodo,” or “the Company”), have issued this Privacy Policy (the “Policy”). Komodo respects your privacy and is committed to protecting it. We may collect your personal information in order to provide our services, including e-commerce site operation, digital content sales, language learning platforms, and international promotion support. We fully understand the importance of safeguarding your privacy and endeavor to handle your personal information appropriately so that you can do business with us with peace of mind.

In addition to this Policy, which applies to all of our customers who use our products and services, we have prepared exhibits that may also apply to you depending on the area in which you reside or are located, so please refer to the applicable exhibits.  If this Policy conflicts with the country-specific exhibits, such exhibits will prevail.

  1. Definitions

1.1 “Personal Data” (also referred to as “personal information”) means any information that can be used to directly or indirectly identify you as an individual.

1.2 “Anonymous Data,” which may or may not be aggregated, is data that cannot readily be used to identify the user who generated the data. This Policy does not apply to Anonymous Data, and the Company reserves the right to share Anonymous Data with third parties in accordance with applicable laws and regulations. Aggregated Personal Data that cannot be used to identify you shall be considered Anonymous Data for the purposes of this Policy.

1.3 “Platform” refers to KOMODO Station and all services accessible through it, including the online store and digital content services.

  1. Scope

2.1 This Policy shall apply to all Personal Data you provide to us via our websites, applications, phone, email, or in writing, in connection with all of our products and services, including but not limited to access to the KOMODO Station website and use of the Platform.

2.2 If provisions differing from this Policy are specified when providing personal information (for example, in connection with a specific service or promotion), such provisions shall apply preferentially.

2.3 This Policy does not apply to personal information obtained separately by advertisers that place advertisements on our websites or the Platform.

  1. Consent

3.1 Agreeing to the terms of this Policy and consenting to the Company’s collection of your Personal Data is required to access any service or program operated or developed by the Company. By agreeing to this Policy, you hereby accept and acknowledge that the ongoing collection of Personal Data is necessary for the Company’s provision of certain products and services to you, and that the Company shall not require any additional consent or authorization to collect or process your Personal Data through your use of the Company’s products or services.

3.2 By agreeing to this Policy, you hereby consent to the Company’s use of your Personal Data for the purposes detailed in Section 6 below.

3.3 You may withdraw your consent to this Policy at any time by written request, but if you withdraw your consent to this Policy then you will be unable to access any of the Company’s products or services.

  1. Collection of Information

4.1 Information Provided by You. The Personal Data we collect may include, without limitation:

(a) Identity information: your full name, birth date, age, gender, and copies of identity verification documents (such as driver’s licenses or health insurance cards) where required.

(b) Contact information: mailing address, telephone number, email address, and company name (where applicable).

(c) Account information: account name (user ID) and password.

(d) Payment information: credit card details, bank account information, electronic money details, and other payment method data.

(e) Communication data: information you provide when contacting us, submitting inquiries, or participating in surveys.

 

4.2 Information Collected Automatically. When you visit or use the Platform, we may automatically collect:

(a) IP address.

(b) Referring URL (address of the webpage linked from).

(c) Device information (browser type and version, time zone settings, operating system, mobile device identifiers, etc.).

(d) Application usage data, including information on products and services displayed, searched, or interacted with.

(e) Location data (where permitted by your device settings).

4.4 We take efforts to collect the minimum Personal Data necessary for the purposes described in this Policy.

  1. Cookies

5.1 Cookies are small text files placed on your device to collect standard Internet log information and visitor behavior information. When you visit our websites or use the Platform, we may collect information from you automatically through cookies or similar technology to help us provide functionality that is useful to you.

5.2 You can set your browser not to accept cookies or disable cookies by changing your browser’s settings. However, by disabling cookies, some features of the Platform may not properly function.

5.3 Information gathered from cookies may be provided to third-party services such as Google Analytics to help us understand user engagement and better interact with our users. Google Analytics uses cookies to collect user information. User information is collected anonymously and does not identify an individual. Information collected through the use of Google Analytics is managed in accordance with Google’s policies. For more information about how Google Analytics collects and uses data when you use our website, visit www.google.com/policies/privacy/partners. You may opt out of Google Analytics tracking by visiting Google’s opt-out page: https://tools.google.com/dlpage/gaoptout.

  1. Purpose of Use

6.1 We may use your Personal Data for the following purposes. We shall not use it for any purposes other than those listed below:

(a) To enable logging in to your Account, forums, message boards, and other Platform features.

(b) To ship products, provide downloads, and deliver other services.

(c) To process payments and bill fees for products and services.

(d) To verify your identity.

(e) To process refunds when applicable.

(f) To transfer collected fees on behalf of contractors of our services.

(g) To respond appropriately to your inquiries about our services.

(h) To send you information and advertisements such as direct mailings or email newsletters, and to communicate with you about our products and services.

(i) To notify you of updates, changes, or discontinuation of our services.

(j) To improve existing services, conduct research and development for new services, and facilitate the teaching and learning of languages.

(k) To utilize information for analysis, marketing, and information dissemination as statistical data in which individuals or corporations are anonymized.

(l) To prevent, investigate, and identify fraud, cyber-attacks, and other illegal activities or violations of our Terms of Use, and to protect our legal rights.

(m) To comply with applicable laws, regulations, and legal processes.

6.2 We may retain information about you for as long as it is reasonably necessary to fulfill the purposes described above, in accordance with applicable law. However, we do not represent or warrant that your Personal Data will be protected from loss, damage, or deletion without notice. In order to secure your information, we take all the security measures described in Section 7.

  1. Security Control Measures and Retention of Information

7.1 To prevent unauthorized access or leaking of your Personal Data, maintain the accuracy of information, and dispose of it properly, we shall comply with all applicable laws and make efforts to handle Personal Data with a high level of security.

7.2 We use a combination of security technologies, procedures, and safeguards to protect against unauthorized access, use, and/or disclosure of Personal Data. Your information shall be protected by passwords. Additionally, we use industry-standard SSL/TLS encryption to protect data transmissions when necessary.

7.3 We train our employees on privacy practices and on the Company’s privacy and information security policies.

7.4 An internal system with clearly defined roles and responsibilities has been established under the supervision of a Personal Information Protection Manager appointed by a representative of the Company.

7.5 We conduct regular audits of the handling of Personal Data and constantly strive to improve our internal system.

7.6 We will continuously review and improve our Personal Information Protection Management System in response to changes in our business activities, as well as changes in the legal, social, and IT environments surrounding our business.

7.7 When we outsource duties to a third party for the purpose of providing services to you, a contract will be signed to ensure proper management by the outsourcer. We conduct regular reviews to confirm that these activities are being properly performed and at a suitable level.

7.8 We work to retain information related to you only as long as reasonably necessary for business and/or legal purposes. The Company reserves the right to terminate the registration of any User that has not used the Platform for a period of more than one year, and in such cases may delete the Personal Data of such Users that the Company has in its possession.

7.9 Our service may provide links to third-party websites or apps to you. We do not control the Personal Data handling of those websites or apps, and they are not covered by this Policy. You should confirm the privacy policies of other websites or apps that you use to learn about how they handle personal information.

  1. Sharing and Provision of Your Information to Third Parties

8.1 We share your Personal Data with companies affiliated with the Company and to partners to perform outsourced duties, as permitted by law. The Company’s provision of your Personal Data is solely for those purposes identified in Section 6 above.

8.2 We may share your information with our partners or provide it to a third party in the following circumstances:

(a) When you have provided consent in advance.

(b) When necessary for our partners to perform outsourced duties (including but not limited to transmitting email, processing payments, delivering SMS verification messages, shipping products, and providing analytics services such as Google Analytics).

(c) When necessary to provide statistical data in which individuals or corporations are anonymized.

(d) When necessary to sell our business in whole or in part, or in the event of a merger, acquisition, reorganization, bankruptcy proceeding, or sale of assets.

(e) When required by law or legal order.

(f) Cases of urgent necessity in which there is imminent danger to the life, body, or property of an individual, and in which it is difficult to obtain the consent of the person.

(g) Cases of cooperation with legal demands by public institutions such as judiciary agencies or the police.

(h) Cases in which there is reasonable suspicion that the individual has violated the law or our Terms of Use in connection with the use of our services, and it has been recognized as necessary to protect our or a third party’s rights, assets, or services.

(i) If it becomes necessary by legal ordinance to cooperate with a government agency, public authorities, or parties authorized by them, and, as determined by the Company in good faith, there is concern that seeking permission of the individual may hinder the execution of the relevant duties.

  1. Overseas Transfer

9.1 As a result of the above sharing and disclosure, your Personal Data may be transferred to the following countries. 

  • Japan
  • United States of America

If Personal Data is transferred to the above countries or territories, we will take proper protection measures required by the personal information protection regulations of each country.

9.2 Provision of information pursuant to the Act on the Protection of Personal Information of Japan

We may provide your Personal Data to third parties in foreign countries for the purposes set out above, with your consent to this Policy. In addition, the third parties to whom we provide your Personal Data comply and handle your Personal Data in accordance with the legal restrictions related to personal information protection in the country in which they are located.

  1. Your Rights

10.1 You have the right to request disclosure of, correction to, amendment of, deletion of, erasure of, or suspension of use of your Personal Data. You have the right to request notification of the purposes of use of your Personal Data.

10.2 You have the right to withdraw your consent at any time by the method separately specified at the time we obtain your consent. However, your withdrawal of consent will not affect the legality of processing conducted based on your consent before its withdrawal. Please note that a withdrawal of your consent may prevent you from further accessing our products and services.

10.3 You have the right to request copies of your Personal Data. We may charge a reasonable fee for this service.

10.4 You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete information you believe is incomplete.

10.5 You have the right to request that we erase your Personal Data, under certain conditions.

10.6 You have the right to request that we restrict the processing of your Personal Data, under certain conditions.

10.7 You have the right to object to our processing of your Personal Data, under certain conditions.

10.8 You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions (data portability).

10.9  When we receive your request, we shall respond promptly within a reasonable scope after confirming your identity through prescribed forms and identification documents.

10.10 To exercise any of the rights described above, please submit your request to us in writing using the contact information specified in Section 11.

  1. Contact

If you have any questions or concerns regarding the contents of this Policy or other aspects of how your personal information is handled, please contact us below:

KOMODO Co., Ltd.
 Attn: Personal Information Protection Manager
 VORT Akihabara North 8F, 4-7-11 Sotokanda, Chiyoda-ku, Tokyo, Japan 101-0021

Email: [email protected]
Reception hours: 10:00 a.m. to 5:00 p.m. JST, Monday through Friday (excluding Japan’s public holidays, the Year-End and New Year holidays)

  1. Changes to This Policy

12.1 We reserve the right to revise this Policy from time to time and will keep an updated copy on our website at all times. Please review this Policy regularly to be aware of any recent changes we may have made.

12.2 If you have an Account with the Company, we will contact you using the email address associated with your Account to inform you of any changes in our use of your Personal Data or other material modifications to this Policy.

12.3 In the event of revisions, they shall apply automatically at the point in time they are posted on our websites or when we notify you of them.

  1. Complaints

13.1 You have the right to report a complaint to us using the contact information provided in Section 11.

13.2 If you feel that our response to your complaint was inadequate, you may contact the appropriate regulatory authority in your jurisdiction.

 

Last Updated: October 14, 2026