PRIVACY POLICY
Effective Date: 11 January 2026
Last Updated: 11 January 2026

This Privacy Policy explains how GoGen Languages株式会社 and GoGen Languages, Inc. (together, “GoGen,” “we,” “us,” or “our”) collect, use, disclose, and otherwise handle Personal Information in connection with our websites, coaching services, courses, programs, community spaces, live calls, livestreams, seminars, workshops, webinars, and related offerings (collectively, the “Services”), and when you otherwise communicate with us.

This Privacy Policy is intended to satisfy notice obligations under applicable privacy laws, including Japan’s Act on the Protection of Personal Information (“APPI”). If any provision of this Privacy Policy conflicts with mandatory law, mandatory law controls to that extent.

IMPORTANT: This Privacy Policy is a privacy notice. Contractual terms governing your purchase and participation (including group-session recording rights and content rights) are set out in the applicable Terms of Sale/Use, Membership Terms, Event/Live Session Terms, and/or Coaching Agreement (collectively, “Contract Terms”). If there is any inconsistency between this Privacy Policy and the Contract Terms regarding participation rules (e.g., recordings, acceptable use), the Contract Terms control to the maximum extent permitted by law.

  1. WHO WE ARE; CONTACT

GoGen Entities
• GoGen Languages株式会社
Address: 2‑13‑10 Shinjuku, Shinjuku‑ku, Tokyo 160‑0022 Japan
Representative: [INSERT REPRESENTATIVE DIRECTOR NAME]

  • GoGen Languages, Inc.
    Address: [INSERT ADDRESS]
    Representative: [INSERT NAME/TITLE, IF APPLICABLE]

Primary contact for privacy matters:
Email: [email protected]

  1. DEFINITIONS

“Personal Information” means information relating to an identified or identifiable individual (including “personal information,” “personal data,” and “retained personal data” as those terms are used under APPI, where applicable).

“Sensitive Personal Information” means Personal Information requiring special care or special protection under applicable law (including APPI “special care-required personal information”).

“Private 1‑on‑1 Coaching” means private, one‑on‑one coaching sessions (including private strategy calls) delivered directly between you and GoGen.

“Group Services” means anything other than Private 1‑on‑1 Coaching, including (without limitation) livestreams, cohort/group calls, seminars, workshops, webinars, office hours, community calls, live events, and community/forum spaces (whether paid or free).

“Contributions” means anything you provide, submit, or make available in connection with Group Services, including your voice, image, likeness, name/username, profile image, chat messages, questions, posts, comments, reactions, shared screens, files, links, or other content.

“Recordings” includes audio/video recordings, screen captures, chat logs, transcripts, summaries, clips, excerpts, highlights, and derivative versions.

  1. THE PERSONAL INFORMATION WE COLLECT

We collect Personal Information in several ways. The categories below are illustrative and not exhaustive.

3.1 Information you provide directly

Depending on how you use the Services, you may provide:

  • Contact details (e.g., name, email, phone number).
  • Account and profile information (e.g., username, display name, profile photo, preferences).
  • Application/intake information for coaching or programs (e.g., background, goals, challenges, and other information you choose to share).
  • Scheduling and attendance information (e.g., bookings, cancellations, time zone, participation logs).
  • Communications (e.g., emails, messages, support requests).
  • Payment and transaction information (e.g., purchase history, invoice details, payment confirmation). Payment card details are typically processed directly by our payment processors; we do not intentionally store full card numbers.
  • Your Contributions in Group Services (e.g., chat, Q&A, posts, shared files).

3.2 Information collected automatically

When you access or use the Services, we (and our service providers) may automatically collect:

  • Device and network information (e.g., IP address, browser type, device identifiers, operating system).
  • Log and usage data (e.g., pages viewed, time spent, clicks, referral URLs, interaction data).
  • Approximate location (derived from IP address).
  • Cookies and similar tracking technologies (see Section 9).

3.3 Information from third parties

We may receive information about you from third parties, such as:

  • Platforms and tools used to operate the Services (e.g., website hosting, learning/community platforms, video conferencing, livestream platforms, scheduling tools, analytics, email/SMS tools).
  • Payment processors and billing partners (e.g., confirmation of payment status, fraud signals).
  • Advertising/marketing partners (e.g., campaign performance signals), where used.
  1. PURPOSES OF USE (HOW WE USE PERSONAL INFORMATION)

We use Personal Information for the following purposes (“Purposes”):

  1. A) Service delivery and operations
  • To provide, administer, and maintain the Services (including applications, onboarding, scheduling, delivery of content, and customer support).
  • To communicate with you about the Services, your account, transactions, updates, and administrative messages.
  • To manage accounts, access control, and authentication.
  1. B) Improvement, development, training, and research
  • To evaluate, improve, and develop our Services, including current and future programs, products, coaching frameworks, and content.
  • To conduct internal quality assurance, team training, supervision, and internal analytics (including trend analysis).
  • To create aggregated, pseudonymized, or anonymized insights and datasets.
  1. C) Safety, integrity, and enforcement
  • To maintain the security and integrity of the Services; prevent, detect, and investigate fraud, abuse, unauthorized access, violations of policies/agreements (including unauthorized recording or content misuse), and suspected illegal activity.
  • To enforce our terms, protect our rights, and protect the rights and safety of our clients, users, and team.
  1. D) Legal, compliance, and business administration
  • To comply with legal obligations (including tax, accounting, and regulatory obligations).
  • To establish, exercise, or defend legal claims, and for dispute resolution.
  1. E) Marketing and promotion
  • To market and promote our Services, subject to applicable law and your choices.
  • For Group Services, marketing may include use of Recordings and Contributions as described in Section 6 (and as further governed by the applicable Contract Terms).

We may use Personal Information for additional purposes where permitted by law, and we may combine information from different sources to accomplish the Purposes above.

  1. SENSITIVE PERSONAL INFORMATION

We do not request Sensitive Personal Information unless it is necessary for a specific request or accommodation you initiate.

If you choose to provide Sensitive Personal Information, you consent to our collection and use of it for the Purposes described in this Privacy Policy and any related intake notices, to the maximum extent permitted by law. If required by applicable law, we may request additional or explicit consent at the point of collection.

  1. GROUP SERVICES: RECORDINGS, CONTRIBUTIONS, AND COMMERCIAL USE DISCLOSURE

THIS SECTION IS IMPORTANT. It applies to Group Services (not Private 1‑on‑1 Coaching).

6.1 Recording and capture in Group Services (privacy notice)

Group Services may be recorded or captured by default, including audio, video, chat, Q&A, and shared content, and may also be transcribed or summarized. Recording/capture may occur on third‑party platforms we select or change over time.

By registering for, joining, or participating in Group Services (including by speaking, appearing on camera, posting in chat/community, reacting, or sharing content), you:

  • consent to recording/capture and related processing; and
  • acknowledge that your Personal Information and Contributions may be included.

If you prefer not to appear or be identifiable, do not speak, keep your camera/microphone off, limit what you share, and use a pseudonym or generic display name where the platform allows. We do not guarantee these measures will fully prevent capture or identification.

Group Services are not confidential. Do not share information you would not want recorded, reused, or made public.

6.2 Use of Group Services Recordings for business purposes (including marketing)

We may use Recordings and Contributions from Group Services for GoGen business purposes, including (without limitation) education, cohort access/replays, support, moderation, quality assurance, internal training, analytics, product/program development, and marketing/promotional purposes, to the maximum extent permitted by law.

This may include editing, excerpting, clipping, captioning/subtitling, translating, reformatting, combining with other materials, and publishing on public platforms.

6.3 Contractual rights grant (Article 27/28; moral rights; performer rights)

The legal rights governing GoGen’s ability to record, edit, translate/adapt, and commercially exploit Group Services Recordings and your Contributions (including rights relating to derivative works, moral rights non‑exercise, and performer/neighbouring rights) are set out in the applicable Contract Terms (for example, the Course/Membership Terms and any Live Session Recording & Rights Release annex).

This Privacy Policy provides notice of recording and data use. The binding rights grant/assignment is governed by the Contract Terms you accept at checkout and/or at Live Session entry.

6.4 No obligation to remove from distributed/published materials

Because Group Services may be recorded, shared with registrants, incorporated into course materials, or published (including on public platforms), we may be unable to remove, retract, or edit Recordings upon request, especially once distributed or posted externally. Where required by law, we will honor valid requests to the extent legally required and technically feasible.

6.5 Public platforms and third‑party re‑use

Some Group Services may occur on public or semi‑public platforms. If you participate, your Contributions may be viewed, captured, or reshared by other participants or the public. We do not control and are not responsible for how third parties use or redistribute information that becomes public through your participation.

  1. PRIVATE 1‑ON‑1 COACHING: RECORDING RULE (CONSISTENT WITH YOUR COACHING AGREEMENT)

This Section applies only to Private 1‑on‑1 Coaching.

7.1 Client recording prohibited

Clients may not record (audio or video), screenshot, or use AI meeting bots/note‑takers to capture any Private 1‑on‑1 Coaching session or Strategy Call without GoGen’s prior written consent. Enforcement may include investigation of suspected violations.

7.2 GoGen recording only with explicit consent

Private 1‑on‑1 Coaching sessions are not recorded unless you provide explicit consent (for example, by checking a separate consent checkbox or responding in writing). If you do not consent, GoGen will not record.

7.3 Anonymization (optional; internal use)

If you consent to recording, GoGen may create anonymized notes, extracts, or transcripts for internal quality improvement and training purposes, provided GoGen removes direct identifiers to a reasonable extent. GoGen does not guarantee anonymization is risk‑free, but will use reasonable efforts to reduce identification.

7.4 Marketing use requires separate permission

GoGen will not use your name, image, voice, or identifiable story from Private 1‑on‑1 Coaching in marketing without separate written permission (unless mandatory law provides otherwise).

  1. HOW WE DISCLOSE PERSONAL INFORMATION

We may disclose Personal Information as follows, to the maximum extent permitted by law and consistent with the Purposes:

8.1 Service providers (processors/entrusted parties)

We may share Personal Information with vendors and contractors who provide services on our behalf, such as hosting/infrastructure, learning/community platforms, video conferencing/livestream platforms, scheduling tools, payment processing/fraud prevention, analytics, customer support tools, and email/SMS tools.

These parties may process Personal Information under our instructions and subject to appropriate contractual and security controls.

8.2 Platform providers as independent parties

When you use third‑party platforms (e.g., Zoom/Meet, YouTube, social platforms, community platforms), those platforms may collect and process information under their own terms and privacy policies. We are not responsible for their practices.

8.3 Affiliates and corporate group

We may share Personal Information within our corporate group for the Purposes (see Joint Use in Section 10).

8.4 Marketing/advertising partners

Where we engage marketing/advertising partners, we may share or allow collection of identifiers and usage data to measure and improve campaigns, personalize outreach, and attribute conversions, subject to applicable law and your choices.

8.5 Legal, compliance, and business transactions

We may disclose Personal Information to comply with law, protect rights/safety, or in connection with a merger/acquisition/financing/reorganization/sale of assets.

  1. COOKIES AND TRACKING TECHNOLOGIES

We use cookies, pixels, SDKs, and similar technologies to operate the Services, remember preferences, improve performance, run analytics, and (where used) conduct marketing/advertising.

You can control cookies through browser settings and, where available, platform‑level privacy controls. Blocking cookies may impair functionality.

We do not respond to “Do Not Track” signals where not required by law.

  1. JOINT USE (APPI) BETWEEN GOGEN ENTITIES

To the extent permitted under APPI and other applicable laws, GoGen Languages株式会社 and GoGen Languages, Inc. may jointly use Personal Data as follows:

  1. a) Items of Personal Data subject to joint use:
    Contact details; account/profile information; purchase/transaction records; application/intake information; scheduling/attendance records; communications; support history; and records/metadata reasonably necessary to operate, secure, and improve the Services (including Group Services recordings and related metadata).
  2. b) Scope of joint users:
    GoGen Languages株式会社 and GoGen Languages, Inc. (and any successor entities).
  3. c) Purposes of joint use:
    The Purposes described in Section 4.
  4. d) Party responsible for management of the Personal Data for joint use:
    GoGen Languages株式会社
    Address: 2‑13‑10 Shinjuku, Shinjuku‑ku, Tokyo 160‑0022 Japan
    Representative: [INSERT REPRESENTATIVE DIRECTOR NAME]
    Contact: [email protected]
  5. INTERNATIONAL TRANSFERS

Because we operate internationally and use service providers globally, your Personal Information may be transferred to, stored in, or processed in countries other than where you reside (including Japan and the United States).

Where required by applicable law, we will provide required notices and obtain required consents, or implement recognized safeguards and equivalent protective measures, as applicable.

  1. SECURITY

We implement reasonable administrative, technical, and organizational measures designed to protect Personal Information. However, no security measure is perfect, and we cannot guarantee absolute security.

  1. RETENTION

We retain Personal Information for as long as reasonably necessary for the Purposes, including compliance, dispute resolution, and enforcement.

General guidance (non‑exhaustive):

  • Private 1‑on‑1 Coaching application/intake records and coaching records (including scheduling records): retained as reasonably necessary for service delivery, compliance, disputes, and enforcement; we may retain longer where needed for legitimate business purposes and legal protection, and delete sooner in our discretion.
  • Group Services Recordings and Contributions: may be retained for replay access, internal use, marketing, and future product versions for an extended period and potentially indefinitely, to the maximum extent permitted by law.
  • De‑identified/aggregated/pseudonymized information: may be retained and used without a fixed time limit, where permitted by law.

Deletion from active systems may not immediately remove information from secure backups or logs.

  1. YOUR RIGHTS AND CHOICES

Depending on your jurisdiction, you may have rights such as access, correction, deletion, cessation of use, or objection, subject to legal requirements and exceptions.

We may require identity verification. We may deny or limit requests where permitted by law, including where responding would violate law/third‑party rights, seriously interfere with operations, be technically infeasible or disproportionately costly, or where we must retain information for compliance, security, disputes, or enforcement.

Marketing preferences: You may opt out of promotional emails via unsubscribe links or by contacting [email protected]. You may still receive non‑promotional communications.

  1. CHILDREN

The Services are not intended for individuals under 18. We do not knowingly collect Personal Information from individuals under 18.

  1. THIRD‑PARTY WEBSITES AND SERVICES

The Services may link to or integrate with third parties. We do not control and are not responsible for their privacy practices.

  1. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. We will post the updated version and change the “Last Updated” date. If required by law, we will provide additional notice. Continued use of the Services after an update means you accept the updated Privacy Policy to the extent permitted by law.

  1. CONTACT

[email protected]
GoGen Languages株式会社
2‑13‑10 Shinjuku, Shinjuku‑ku, Tokyo 160‑0022 Japan

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