Privacy Policy

Personal Information Protection Policy

The Company recognizes that complying with laws, government guidelines and other relevant standards on the protection of personal information, and managing and using all personal information handled in our business (including information about customers and about our employees) appropriately, is an important social responsibility of a company. We therefore set out this Privacy Policy as follows.

1. Collection and Use of Personal Information

When we collect personal information, we state the purpose of use and use it appropriately within the scope of that purpose. Except as permitted by law, we will not use personal information beyond the scope of that purpose without the prior consent of the person concerned. To prevent such use, we take necessary and appropriate measures, such as establishing internal controls.

2. Provision to Third Parties

We do not provide personal information we have collected to third parties except in the following cases:

• when the person concerned has consented;
• when required by law;
• when it is necessary to protect a person's life, body or property and it is difficult to obtain the person's consent;
• when it is especially necessary to improve public health or promote the healthy development of children and it is difficult to obtain the person's consent; or
• when it is necessary to cooperate with a national or local government body, or a party entrusted by one, in carrying out duties prescribed by law.

3. Security Measures

To prevent leakage, loss or damage of personal information and to otherwise keep it secure, we take the following organizational, personnel, physical and technical measures.

• Organizational measures

  We have appointed a person responsible for personal information protection, set up operations and audits based on internal rules, and established a clear reporting process for when violations or signs of risk are found.

• Personnel measures

  We regularly educate and train all staff on the proper handling of personal information to raise awareness.

• Physical measures

  We manage documents and equipment containing personal information carefully, for example by storing them locked and taking precautions when they are taken out, to prevent unauthorized access, theft and loss.

• Technical measures

  Communications between users, such as the content of messages, are protected by end-to-end encryption (E2EE), and no third party, including the Company, can decrypt or view them. In our information systems, we control access, limit the people who handle personal information and the scope of what they handle, and take measures to prevent unauthorized access.

Personal information is kept under strict control in a secure server environment with restricted external access.

4. Complaints and Inquiries

We respond sincerely and promptly to opinions, inquiries and complaints about the handling of personal information. We review the details, investigate the facts and handle the matter appropriately.

5. Continuous Improvement

In light of changing social expectations and technology surrounding the protection of personal information, we continuously review and improve this Policy and our internal systems.

Established: April 20, 2025 (revised July 2, 2026)

Use of Personal Information

COUPPLY, Inc. handles the personal information it collects from customers in its app for couples appropriately within the scope of the following purposes.

1. Purposes of Use

The information we collect is your email address, nickname, profile photo, date of birth, gender, location information and any other profile information you choose to enter ("User Information"). We use this information for the following purposes:

• creating and managing user accounts;
• providing, maintaining and improving app features;
• supporting communication between users;
• understanding and analyzing how the Service is used;
• sending information and notifications, and providing support;
• improving the quality of the Service and developing new features;
• responding as required by the Terms of Service or by law;
• providing location-based features (including recording and sharing location information and automatic recording; location information is encrypted with E2EE);
• showing other users information that users choose to make public, such as public profiles and check-in information; and
• providing AI-based features such as the counselor and conversation support (including sending data decrypted on your device to AI processing services).

2. Provision to Third Parties

We do not provide personal information we have collected to third parties except with your consent or as required by law. However, this does not apply in the following cases:

• when we entrust the handling of personal information to contractors to the extent necessary to operate the app (for example, cloud server providers, analytics tool providers and AI processing service providers);
• when disclosure is required by law; or
• when the business is succeeded due to a merger or other reasons.

We supervise our contractors to make sure personal information is kept secure.

Text, images, videos, location information and other data are all encrypted with E2EE, and it is technically impossible for the Company to decrypt them. Even when there is a legal request, we cannot decrypt and provide the original data. However, we may provide metadata (such as the date and time of communications and sender and recipient information) in response to a legal request.

Depending on your own actions and settings, the following information may be shown to other users of the Service. This information is not covered by E2EE and is stored separately as public data:

• public profile (public couple name, avatar, home area, time on COUPPLY, etc.);
• check-in information (places visited, number of check-ins, "recommended" comments, etc.); and
• posts to the shared spots for everyone.

You can set and change what is made public yourself. If you do not want to make it public, you can set it to private in the settings of each feature.

3. Cookies and Personally Related Information

On our website and in the app, we may use cookies, advertising identifiers and similar technologies to analyze usage, improve the Service and optimize advertising. This collection never accesses the content of messages or other data protected by E2EE, and is limited to metadata such as how the app is used and how often features are used. We may also link personally related information provided by third parties with information we hold, after taking the measures required by law.

4. Use of Anonymized Information

We may process the personal information we collect (excluding the content of messages encrypted with E2EE) into anonymized or statistical information that cannot identify a specific individual, and use it to improve the Service and for marketing analysis. Anonymized information is created and analyzed based on metadata such as how the app is used and how often features are used, and does not include the content of encrypted messages or other data. We may outsource this work as necessary.

5. Disclosure, Correction and Deletion

If you or your legitimate representative requests disclosure, correction, addition, deletion, suspension of use or suspension of provision to third parties of personal information we hold, we will respond appropriately in accordance with the law. However, we may not be able to comply with the request in the following cases:

• when it may harm the life, body, property or other rights or interests of the person concerned or a third party;
• when it may seriously interfere with our business operations; or
• when it may violate the law.

If you withdraw (delete your account), your data is kept for 30 days from the date of withdrawal, during which it can be restored. After 30 days, all data is permanently deleted. Withdrawal affects both members of the couple, and your partner's account is deleted at the same time.

6. Notes on End-to-End Encryption (E2EE)

The Service uses end-to-end encryption (E2EE) for messages, content sharing and location sharing between users. Please understand that this has the following characteristics:

• The content of encrypted messages can be accessed only by the sender and the recipient. No third party, including the Company, can decrypt or view it.
• Even if our servers are compromised, the content of encrypted data remains protected.
• Encryption keys are managed only on your devices and are not stored on our servers.
• However, if you use the backup feature for cases such as losing your device, you are responsible for keeping your encryption key (PIN code) safe.
• Because of E2EE, we cannot monitor the content of messages exchanged between users or automatically detect inappropriate content. We respond to reports of violations based on reports from the paired user.
• When you use AI-based features such as the counselor, data decrypted on your device is sent to AI processing services to generate replies. This data is not used to train AI models, which is guaranteed by our contracts with the AI providers. We also do not store or record the data sent in a form that we can view. AI replies are encrypted again before being stored.
• Information that users choose to "make public to other couples", such as check-ins, public profiles and posts to the shared spots, is not covered by E2EE. It is stored and displayed as separate public data.

Contact

COUPPLY, Inc.

Email: contact@coupply.co.jp