# Privacy Policy & Legal Notice — Changelog This log tracks material changes to the Privacy Policy, Terms of Use, and related notices at https://study.peranabi.com/legal (until v1.8, https://mastermindjapanese.com/legal). ## v1.0 — 2026-04-18 (effective) Initial versioned release of the Privacy Policy & Legal Notice. Notable content posture: - **Operator identity**: Jason Kobayashi, Tokyo, Japan (natural person; JP corporate entity planned). Full postal address on request. - **Data controller contact**: single privacy-contact email reserved for formal data-protection requests required by law. - **Lawful bases (GDPR)**: performance of contract (account + study features); legitimate interest (security logs); consent (product-update emails, withdrawable in Settings). - **Processors**: Render (US, API hosting), Supabase (US, PostgreSQL), Google (US, optional Sign-In/One Tap — controller-to-controller share), Resend (transactional + opt-in product-update email). - **Cross-border transfers**: disclosed. Formal GDPR Chapter V transfer memo + APPI Art. 28 memo are tracked as post-beta follow-ups in the internal compliance plan. - **Retention**: logs per Render plan tier (7–30 days); DB backups per Supabase plan tier; email subscriptions while opted in with separate consent-audit record. - **Age clause**: general-audience service, not directed to children under 13; teen learners welcome with parental awareness; under 13 requires parental consent. - **Liability / governing law**: `$0` cap during free beta, cap tied to "amount paid in preceding 12 months" at monetization; Japanese law default with mandatory consumer-protection rights preserved for EU/UK/JP/other jurisdictions that provide them. - **Attributions**: KanjiVG (CC BY-SA 3.0, adapted bundle also released under CC BY-SA 3.0 ShareAlike), AivisSpeech Engine (LGPL-3.0, used offline only, not redistributed), にせ and まお voice models (ACML 1.0, used offline, not redistributed), with no-endorsement disclaimers on both KanjiVG and Aivis. - **Support**: general questions will route to an in-app support form (planned). The privacy-contact email is reserved for formal privacy requests until that form ships. ## v1.1 — 2026-05-26 (effective; changelog entry recorded 2026-07-12) Two changes shipped in late May 2026 ahead of the "Upcoming" triggers below and are recorded here retroactively so this log stays a faithful audit trail: - **特定商取引法 (Specified Commercial Transactions Act) page added** (2026-05-23) at /legal/tokutei-shotorihiki, ahead of the first paid customer, in preparation for paid launch. Linked from the legal hub. - **Operator identity: full postal address published** in the Privacy Policy (Jiyugaoka, Meguro-ku, Tokyo) — supersedes the v1.0 "full postal address on request" posture. Required disclosure posture for the 特定商取引法 page. ## v1.2 — 2026-07-12 (effective) - **Stripe customer cleanup at account deletion** (Payment records / Stripe section): deleting your Mastermind account now also deletes your Stripe customer record, or — when a cancelled subscription still has paid time remaining — strips it of all identifying details (email, name, address, phone) so the paid period finishes without your identity attached. Supersedes the v1.1 statement that Stripe's customer record persists per Stripe's policy. - **Restoration scope narrowed accordingly**: sign-up-again restoration by e-mail match is available only while your account exists; it is no longer possible after account deletion (the identifying link is removed as part of deletion). ## v1.3 draft — 2026-10-09 (folded into the 2026-10-10 rewrite below) - Fonts are served locally. Google sign-in starts only after the Google button is tapped; the app preload and One Tap have been removed. - The full Privacy Policy now describes actual collection, purposes and legal bases, provider roles, optional speech-model downloads, browser storage, account deletion, retained audit/payment records, and privacy rights. - Hosting regions, provider agreement coverage and provider-copy retention are described without assuming unverified deployment settings or safeguards. - Terms now includes a copyright-complaint contact and the details to include. ## v1.3 — 2026-10-10 (written on the development site; effective on production from 2026-10-14; existing accounts stay on the previous Terms until they expressly accept the new ones) - **Terms of Use and Privacy Policy rewritten as two standalone English documents** at /legal/terms and /legal/privacy. English is the only binding version. The 特定商取引法 page stays bilingual. The short Terms, Beta Notice and Privacy sections on /legal are retired; their clauses moved into the two documents. The previous text is archived at /legal/archive/terms-before-2026-10-14.md. - **Terms**: liability limited to the greater of fees paid in the prior 12 months and 10,000 yen, never for intentional misconduct or gross negligence (ours or anyone acting for us), and not for death or personal injury; change clause follows Civil Code Art. 548-4 with advance notice; under-18 users need parent or guardian consent; a warning before an account is limited; Tokyo District Court as a non-exclusive venue, with local courts and mandatory consumer law kept. Accounts created before publication stay on the previous terms until they expressly accept. - **Privacy**: providers named with their countries (Render, Supabase Pte. Ltd. of Singapore with the database in California, Cloudflare, Resend); Google sign-in described as an independent controller; foreign transfers disclosed with the PPC country information for the United States and Singapore and available contractual safeguards, reviewed yearly; the local fonts, Google sign-in only on tap, and optional Hugging Face model downloads are described; cookies and browser storage itemized; retention per category, including the 24-month deletion record, 12-month sign-in abuse records and error records deleted within 2 days (purge jobs added 2026-10-10); security measures by APPI category; complaint routes; no EU/UK representative appointed. - **Conditional payment disclosures retained**: Stripe collection and seven-year accounting retention apply only if payment features are enabled; paid sales remain off. ## v1.4 — 2026-10-14 (written on the development site; effective on production from 2026-10-14) - **Recognised browsers**: a new essential first-party cookie, mastermind_device, holds a random value; the server keeps only its hash per account, with first- and last-use times. A recognised browser keeps its own allowance of sign-in codes (so repeated code requests from elsewhere cannot use it up) and can sign in with a password without an email code. The browser keeps the cookie up to about 13 months; the server stops recognising it 180 days after last use. Learners can forget this browser, or sign out and forget all others, in Settings; account deletion removes the records. No browser details, IP address or location are stored for it, and it is not used for tracking. - Section 2 (what we collect), section 6 (cookies) and section 7 (retention) updated accordingly. - **Hosting region**: section 4 now says the app runs on Render servers in Singapore, which also store feedback screenshots and error records, and that Render's terms place its primary processing operations in the United States; the database stays in California. The Render region is no longer listed as unconfirmed. Section 7 also says that feedback screenshots are lost whenever the app is redeployed or restarted. ## Production publication — 2026-10-14 - Release 0.7.8 publishes the new Terms of Use and Privacy Policy v1.4 (which includes the v1.3 changes) on mastermindjapanese.com. They take effect on production from 2026-10-14; the dates above are when each text was finalised on the development site. The previous text, in force on production until 2026-10-14, is archived at /legal/archive/terms-before-2026-10-14.md. - Privacy Policy section 6 also lists the sign-in code request kept in session storage while you sign in with a code (the email address and the request's identifiers and send times), and says when each session-storage item is removed. - Terms of Use section 4 names the emailed sign-in code: the sign-in email no longer carries a link. This describes how sign-in works; no right or obligation changes. - The service is now named PeraNabi (ペラナビ in Japanese text), formerly Mastermind Japanese: the same service, operator and address. The legal pages say "PeraNabi (formerly Mastermind Japanese)" at first mention; no right or obligation changes. - EU/UK representative: none is currently appointed. The Upcoming entry for it is restated: it replaces the earlier production wording ("First serious EU user growth → EU representative appointment + named") and the later plan, written on the development site, to appoint any required representative before production publication. The decision will instead be revisited before paid sales start, or sooner on the triggers listed under Upcoming. ## v1.5 — 2026-10-15 (written on the development site; effective on production from 2026-10-16) - **Feedback screenshots** are now kept in our database in California instead of on the app servers in Singapore, so a redeploy or restart no longer loses them. Each one becomes eligible for automatic deletion 180 days after it is sent and is removed by our scheduled cleanup; account deletion also removes them. The browser re-encodes each screenshot before upload (shrinking large ones), which drops embedded details such as camera location data. Sections 2, 4 and 7 updated accordingly. ## v1.6 — 2026-10-16 (written on the development site; effective on production from 2026-10-17) - Name-only revision. The service is named Mastermind Japanese again, the name it had until 2026-10-14; from 2026-10-14 it was named PeraNabi (ペラナビ in Japanese text). It is the same service, operator and address. The Privacy Policy and the Terms of Use say "Mastermind Japanese" at first mention and "Mastermind" for short. No right or obligation changes, and the change does not alter how personal data is handled. The Terms of Use keep their 2026-10-14 publication date, which decides which accounts they cover. PeraNabi remains the name of the separate website at peranabi.com. ## v1.7 — 2026-10-17 (written on the development site; effective on production from 2026-10-23) - **Encrypted copies held by the operator** (section 7, and "Physical" in section 10): for maintenance, and to check how well the learning model predicts what learners remember, we may take an encrypted copy of the database and keep it on the operator's own computer. Each copy is deleted when it is no longer needed, and automatically 14 days after it was taken by a deletion service on the operator's computer, which checks every ten minutes while it runs and again when it starts (if that service is not running at that point, the copy stays encrypted until it runs again); an account deleted while a copy exists stays in it until the copy is deleted. A copy is restored over the live database only to recover from data loss, and only after every account deletion made since it was taken has been applied again. AI tools never read these copies; they see only summaries of them that describe no individual learner. This adds a storage location and a retention period; no right or obligation changes. - **Cookies** (sections 2 and 6; added 2026-10-23, before this version was published): the mastermind_device cookie holds a random value for each account that has signed in with that browser, instead of one value per browser, and both sign-in cookies are sent only over HTTPS, except when the app runs on a developer's own computer. We still keep only a hash of each value; nothing else changes. ## v1.8 — 2026-10-23 (written on the development site; effective on production from 2026-10-23) - Name, address and contact revision. The service is named PeraNabi Study (formerly Mastermind Japanese) and moves to https://study.peranabi.com; the old address forwards there for a transition period and is then given up. The privacy and support contact is support@peranabi.com instead of support@mastermindjapanese.com. The two sign-in cookies are named __Host-mastermind_refresh and __Host-mastermind_device; the __Host- prefix means only this address (study.peranabi.com) can set them, not other peranabi.com addresses (on a developer's own computer they keep their plain names). The Privacy Policy and the Terms of Use say "PeraNabi Study (formerly Mastermind Japanese)" at first mention and "PeraNabi Study" after it. It is the same service and operator; no right or obligation changes, and the change does not alter how personal data is handled. The Terms of Use keep their 2026-10-14 publication date, which decides which accounts they cover. peranabi.com itself remains the separate PeraNabi website. ## Production publication — 2026-10-23 - Release 0.7.12 publishes Privacy Policy v1.8, which includes the v1.7 changes, on production, at mastermindjapanese.com and, once its address is connected, study.peranabi.com. Both versions take effect on production from 2026-10-23; the dates above are when each text was finalised on the development site. The Terms of Use keep their 2026-10-14 publication date. ## Upcoming Changes that will trigger a new version + effective-date entry: - Incorporation of a Japanese company → controller identity update (personal → company) - First real paid customer → liability cap tied to actual paid amount; pricing/charge timing reflected on the 特定商取引法 page - EU or UK representative appointed → named in Privacy Policy section 1 (none is currently appointed; the decision will be revisited before paid sales start, or sooner if we market to the EU or UK, price in euros or pounds, add an EU language besides English, or learn that a meaningful share of learners is in the EU or UK) - Production database backups switched on → backup location and retention added to the retention section - Product-update emails start → sender details and opt-out confirmed in the Emails section - Any vendor swap, addition, or removal affecting cross-border processing - Any expansion of OAuth scopes beyond `openid profile email` --- For the currently effective text, see https://study.peranabi.com/legal/privacy and https://study.peranabi.com/legal/terms. Current privacy and support contact (from v1.8, 2026-10-23): support@peranabi.com. Earlier entries name the address in use at the time.