Privacy Policy

This Privacy Policy applies to children and their parents/guardians who use our Services, faculty and staff of schools and educational institutions, persons who contact us, purchasers of materials, and others whose personal information we handle.

We may collect the following information as needed to provide our Services:

• User and account information: child’s name, user ID, school, grade, class, nickname, email address, and other information needed for registration and authentication

• School / institution information: school name, address, contact person, contact details, contract terms, grades/classes covered, etc.

• Learning information: date/time of use, materials/content used, answers, correctness, scores, medals earned, progress, operation history, learning history, and other results

• Speech, conversation, and generated content: recorded audio, speech recognition results, conversation logs, text entered, interactions with AI characters, generated images/settings, and other content created or sent by users

• Inquiry and application information: name, school/organization, address, phone, email, inquiry content, requests for materials/samples, order details, etc.

• Payment and transaction information: products purchased, amounts, payment time, transaction history, and other information needed for payment

• Device, network, and usage information: IP address, cookies, device/OS/browser type, access time, referrer, error information, and other access logs

If we collect location data, advertising identifiers, or other information not listed above, we will disclose the items and purposes in advance on the service screen or by other appropriate means.

We collect information directly from users, parents/guardians, or schools; automatically when users use our Services; and from schools or other third parties that lawfully provide it.

Our Services are intended for use by children, including elementary school students. We strive to explain clearly in ways suited to children’s ages and development, and to avoid unduly harming children’s rights and interests.

Before use begins, we display this Privacy Policy to parents/guardians and obtain necessary consent by having them check “I agree to the Privacy Policy.” For school contracts, the school explains the policy to parents/guardians and obtains their consent. Roles between us and the school are set out in the school contract and terms of use.

We use collected information for the following purposes:

• Registration, identity verification, authentication, account management, provision, maintenance, and operation of our Services

• Providing materials, learning content, AI conversation, quizzes, games, and generative-AI activities

• Linking children’s names with learning history so contracted school staff can identify students and review progress, teach, provide individual support, and manage accounts

• Recording learning history, speech, answers, and operation history, and displaying them to the user, parents/guardians, and contracted school staff

• Helping schools understand difficulties and learning status for teaching, support, and review

• Handling inquiries, material/sample requests, orders, contracts, billing, payment, shipping, and after-sales support

• Preventing, investigating, and responding to misuse, unauthorized access, outages, and other security issues

• Improving quality, fixing defects, and planning/developing new features and materials

• Creating non-identifying statistics and analyzing usage and educational effectiveness

• Informing school contacts about our products/services, revisions, training, and seminars

• Complying with laws, contracts, and our policies, and exercising rights or performing duties

We do not use children’s names, learning data, or other personal information about children for advertising, sales outreach, promotions, or similar purposes targeted at children.

When we provide our Services under a contract with a school or educational institution, we may share the following information about users belonging to that school with its faculty/staff:

• Information shared: child’s name or user ID, grade/class, use date/time, learning progress, answers/scores, speech audio, conversation logs, operation history, generated content, and other information needed for teaching and support

• Recipients: the school/institution where the user is enrolled and that has adopted our Services, and faculty/staff designated by that school

• Purposes: class operation, understanding learning status, assessment, review, individual support, explaining to parents/guardians, and other educational needs

Schools handle information shared by us under their own responsibility in accordance with applicable laws and their privacy policies.

Except in the following cases, we do not provide personal data to third parties without prior consent of the individual or their legal representative:

• When required by law

• When necessary to protect life, body, or property and obtaining consent is difficult

• When especially necessary to improve public health or promote the sound upbringing of children and obtaining consent is difficult

• When cooperating with a national or local government body in performing duties prescribed by law, and obtaining consent would impede those duties

• When otherwise permitted under the Act on the Protection of Personal Information or other laws

Entrustment of handling, provision in connection with business succession, and joint use under law do not constitute third-party provision under the Act.

We may conduct research and surveys to improve teaching methods and our Services and to verify learning outcomes. In such cases we generally use non-identifying statistics, anonymized processed information, or other information processed so that individuals cannot readily be identified.

If we conduct joint research with a university or other research institution and need to provide personal data, we will confirm the research purpose, recipient, data provided, and publication methods, and either obtain consent from the individual or legal representative or handle the data under academic-research provisions or other legal grounds. When publishing results, we take measures so individuals are not identified.

To the extent needed to provide our Services, we may entrust all or part of personal data handling to providers of cloud servers, generative AI, speech recognition/synthesis, email delivery, payment, analytics, system maintenance, and similar services. We select vendors carefully, restrict use beyond the stated purposes by contract or other means, and supervise them as necessary and appropriate.

We confirm the items sent to external services, purposes, whether processing occurs abroad, and whether data is used to train AI models, and where legally required we publish or notify necessary information on our website, service screens, or by other appropriate means. We may not disclose system architecture, vendor contracts, or other confidential information beyond what the law requires.

When we provide personal data to a business operator abroad or process it on servers located abroad, we check the recipient’s personal information protection system and safeguards in accordance with applicable law. Where required, we provide necessary information to the individual or legal representative and obtain consent, or ensure the recipient maintains equivalent measures on an ongoing basis.

Our website and Services may use cookies and similar technologies to maintain login state, ensure security, understand usage, and improve features. Users may disable cookies in browser settings, but some parts of our Services may then be unavailable.

If we use analytics services that send device or usage information to a provider, we will disclose the information sent, the recipient, and the purpose through external-transmission notices or other appropriate means.

We retain audio, conversation logs, generated images, learning history, and other personal information for as long as needed to provide our Services, review learning status, support teaching, handle inquiries, prevent misuse, and achieve other stated purposes.

After a contract ends, we may retain information for a limited period as needed for inquiries, confirming contract/use status, responding to misuse, and other necessary operations. When retention is no longer needed, we delete or dispose of the information in a non-recoverable or otherwise appropriate manner under law and our data management policies.

To prevent leakage, loss, or damage of personal data and otherwise manage it securely, we take measures including:

• Establishing basic policies and handling rules for personal information protection

• Appointing a person responsible for personal data, clarifying handlers and scope, and setting incident reporting channels

• Training employees and enforcing confidentiality

• Preventing theft, loss, and unauthorized viewing of devices, media, and documents that handle personal data

• Access control, authentication, communications protection, and measures against unauthorized access and malware

• Selecting, contracting with, and supervising vendors

• Understanding foreign systems when personal data is handled abroad

Details of security measures will be answered upon request by the individual or legal representative, to the extent that does not impair the security of our Services.

Individuals or their legal representatives may request, under our procedures, notice of purpose of use; disclosure of retained personal data or third-party provision records; correction, addition, or deletion; suspension of use or erasure; or suspension of third-party provision.

To make such a request, contact the Smile Online personal information desk below with the requester’s name, relationship to the child, child’s name, school, grade/class or user ID, the procedure requested, and reasons as needed.

For school contracts, we generally verify identity as the individual or parent/guardian through the school. We may ask for documents to confirm identity or authority. We generally reply by email to a registered address or another method we deem appropriate. Fees are generally free, though actual costs may apply for postal or other special methods.

We respond within a reasonable period after identity verification under law. If we cannot comply, we will explain the reason.

Providing personal information is voluntary, but if information needed to provide our Services is not provided, you may be unable to use all or part of our Services.

Business name: DreaMagic Inc.

Address: Kudan Central Bldg. 604, 2-1-4 Iidabashi, Chiyoda-ku, Tokyo 102-0072, Japan

Representative: Representative Director Masamitsu Odaka

Personal information inquiries and disclosure requests: info@smile-english.online

We may change this policy as needed due to legal amendments, changes to our Services, or other reasons. For material changes, we will announce or notify the content and effective date on our website or by other appropriate means. Where consent of the individual or legal representative is legally required, we will obtain consent under our procedures.

July 14, 2026