DRAFT — internal review copy. Items highlighted like this are to be confirmed before publication.

The Japanese version will be published after legal review. 日本語版は法務確認後に公開します。

Privacy Policy

Last updated: [date] TBC

This Privacy Policy explains how [Company legal name] TBC (“we”, “us”) collects, uses, stores and shares your personal information when you use Tomo Box: the Tomo Box device (the “Device”), the Tomo Box companion app (the “App”), the AI-powered features available through them (the “AI Features”), and our website at tomobox.world (together, the “Services”). It also explains the choices and rights you have.

Please read this Policy before using the Services. By using the Services you acknowledge that your information will be handled as described here. If you do not agree, please do not use the Services.

1. Who we are

[Company legal name], [registered address] TBC is the controller of your personal information (the “business operator handling personal information” under Japan’s Act on the Protection of Personal Information). Contact details are in Section 13.

2. Information we collect

We collect the following categories of information. Where we rely on a specific legal basis under laws such as the GDPR, it is noted in brackets.

2.1 Information you give us

• Account information. Email address, and if you sign in with Apple or Google, the identifier and basic profile information those services share with us (such as a name or email). You may optionally add a nickname and birthday, which your character uses to greet you and celebrate your birthday. [Contract; consent for optional fields]
• Character creation — images. If you use “Generate from image”, the image you upload (for example a selfie, a photo of your pet, or a drawing). The image is processed by our AI systems to generate a 3D character. Whether the original image is retained after generation, and for how long — TBC with the engineering team. [Consent]
• Character creation — voice recordings. If you create a custom voice, the audio recording you make or the audio you extract from a video you provide. The recording is processed to generate a synthetic voice for your character. Because a voice recording can identify a person, we treat it as sensitive and use it only to create and operate your character’s voice. You must only record your own voice or that of someone who has given you permission (see our Terms of Service). Retention of the source recording and the generated voice model — TBC. [Explicit consent]
• Character settings. The name, appearance, personality description, backstory, speaking style and voice you choose for your character, and what you call each other.
• Conversations and memories. What you say to your character by voice or text, your character’s responses, and the “memories” the Services derive from your conversations (for example your favourite food or an upcoming event you mentioned) so that your character can remember them in later conversations. Voice input is converted to text to generate a response; whether raw audio of conversations is stored, and for how long — TBC. [Contract; consent]
• Gifts and activity. Gifts you send, mini-games you play, quests you complete, alarms, focus timers and other settings, and your character’s affinity level and relationship history.
• Purchase information. If you subscribe or buy in-app items, we receive transaction records (such as the product, price, date and a transaction identifier) from the Apple App Store or Google Play. We do not receive or store your full payment card details; those are handled by the store.
• Support communications. When you contact us, the contents of your message, your contact details, and any attachments you choose to send.

2.2 Information collected automatically

• Device and app information. Device model, operating system and version, App version, language and time-zone settings, a device identifier, and the Device’s serial number, firmware version and pairing status.
• Network information. IP address, and during setup the name (SSID) of the Wi-Fi network you choose to connect the Device to. The Wi-Fi password you enter is sent to the Device to connect it to your network; confirm that the Wi-Fi password is not stored on our servers — TBC.
• Usage and diagnostic information. Which features you use and when, performance data, crash reports and error logs, so that we can keep the Services working and improve them. [Legitimate interests]
• Device permissions. The App asks for permissions only when needed for a feature. You can change them at any time in your phone’s settings; turning a permission off disables the related feature.
  • Microphone — to record a custom voice and to talk with your character in the App.
  • Camera / Photos — to take or choose an image for character creation or a custom gift.
  • Bluetooth and local network — to find and pair the Device and send it your Wi-Fi settings.
  • Notifications — to send you messages from your character and alarms, if you opt in.

2.3 Information collected on the Device

• Microphone. The Device has a built-in microphone used for voice conversations. Describe how listening is activated (e.g. button press / wake word / always on while awake) and what audio leaves the Device — TBC with the product team. You can mute the microphone [how] TBC.
• Clock and status. Local time, alarm and focus-timer settings, and operating status, which are synced with your account.

2.4 Information from third-party SDKs

The App includes software development kits from third parties that collect limited information to provide their functions. Final list TBC. Expected: Apple / Google sign-in; App Store / Google Play billing; a crash-reporting and analytics SDK; push-notification SDK; hardware pairing SDK.

3. How we use your information

• To provide the Services: create and run your character, remember your conversations, sync between the App and the Device, deliver alarms and notifications, and process subscriptions and purchases.
• To generate your character and its voice from the images and recordings you provide.
• To personalize your character’s conversations and behaviour based on your interactions and the memories you allow it to keep.
• To provide customer support and respond to your requests.
• To keep the Services secure, prevent abuse, and enforce our Terms of Service.
• To understand how the Services are used and to fix problems and improve features, using aggregated or de-identified data where possible.
• To send you service announcements, and, only if you opt in, news and offers about Tomo Box. You can opt out of marketing messages at any time.
• To comply with legal obligations and to establish, exercise or defend legal claims.

AI training. We do not use your images, voice recordings, conversations or memories to train AI models that are used for other users, unless you expressly opt in. — Confirm this commitment with engineering / AI vendors before publishing. TBC.

4. How AI processing works

1. Conversation, speech recognition, speech synthesis, character generation and memory extraction are performed partly on our own servers and partly by specialist AI service providers acting on our behalf, including [large-language-model provider], [speech-to-text / text-to-speech provider], [image-to-3D provider] — TBC.
2. These providers process your information only to provide the relevant feature to us, under contracts that restrict their use of your data. Confirm with each vendor that data is not retained beyond the request or used for their own model training (e.g. API “zero data retention” terms). TBC.
3. AI outputs can be inaccurate. Your character is not a professional advisor, and the memories it keeps are derived automatically; you can review and delete them (see Section 8).

5. How we share your information

We do not sell your personal information. We share it only:

• With service providers that help us run the Services — cloud hosting, AI processing (Section 4), analytics and crash reporting, customer-support tools, email delivery and push notifications — who may only use it to provide services to us.
• With app stores and payment processors (Apple, Google) to process subscriptions and purchases.
• With our affiliates within our corporate group that help provide the Services (list TBC), on the same terms as this Policy.
• For legal reasons, where required by law, regulation, legal process or government request, or to protect the rights, property or safety of our users, the public or us.
• In a business transfer, such as a merger, acquisition or sale of assets, in which case we will notify you and the recipient will be bound by this Policy.
• With your consent, or at your direction.

6. International transfers

Our servers and service providers are located in [countries / regions] TBC, which may be outside the country where you live. When we transfer personal information across borders we take steps required by applicable law, such as entering into standard contractual clauses or confirming that the recipient is in a jurisdiction with an adequate level of protection.

Notice for users in Japan. If you are in Japan, your personal information may be transferred to and processed in [countries] TBC. Information about the personal-information protection systems of those countries and the measures taken by the recipients is available on request from the contact in Section 13 (prepare a per-country disclosure page as required under APPI Art. 28 — TBC).

7. How long we keep your information

• Account and character data — for as long as your account exists. When you delete your account, your characters, conversations, memories, custom voices, images and gifts are deleted within [30] days TBC, except as noted below.
• Source images and voice recordings — retained [only until generation completes / for as long as the character exists] TBC.
• Conversation audio — [not stored / stored for X days] TBC.
• Diagnostic and usage logs — [up to 12 months] TBC, then deleted or de-identified.
• Purchase records and support correspondence — for as long as required by tax, accounting and consumer-protection laws.

We may keep de-identified or aggregated information that can no longer be linked to you for longer.

8. Your choices and rights

Depending on where you live, you may have the right to access, correct, delete or receive a copy of your personal information, to object to or restrict certain processing, to withdraw consent, and to complain to a data-protection authority. We will not discriminate against you for exercising these rights.

You can exercise many of these choices directly in the App:

• Review and edit your account information and your character’s settings.
• Delete memories your character has kept (path TBC), delete a character, or delete your account (Me → Account → Delete account TBC).
• Change device permissions (microphone, camera, photos, Bluetooth, notifications) in your phone’s settings.
• Mute the Device microphone [how] TBC.
• Opt out of marketing messages using the link in the message or in the App settings.
• Manage subscriptions in your Apple or Google account.

For anything else, contact us using the details in Section 13. We may need to verify your identity before acting on a request, and will respond within the time required by applicable law. If you are in the EEA or UK, you may also lodge a complaint with your local supervisory authority; if you are in Japan, with the Personal Information Protection Commission; if you are a California resident, you have the rights described in the CCPA, including the right to know, delete and correct, and we do not sell or share your personal information for cross-context behavioural advertising.

9. Security

We use technical and organisational measures designed to protect your information, including encryption in transit, encrypted storage of sensitive data, access controls limiting staff access to what is needed for their role, and monitoring. No system is completely secure; please keep your login credentials safe and tell us if you suspect any unauthorised access. If a breach affecting your personal information occurs, we will notify you and the relevant authorities as required by law.

10. Children

The Services are not directed to children under 13 TBC, and we do not knowingly collect personal information from them. Users under the age of majority in their country (18 in Japan) may use the Services only with the consent and supervision of a parent or guardian, who should review this Policy with them. If you believe a child has provided us with personal information without appropriate consent, please contact us and we will delete it.

11. Third-party links

The Services may link to websites or services we do not operate (for example, a crowdfunding platform or app store). Their privacy practices are governed by their own policies.

12. Changes to this Policy

We may update this Policy from time to time. If we make material changes, we will notify you in the App or by email before they take effect, and we will update the “Last updated” date above. Continued use of the Services after a change means you accept the updated Policy.

13. Contact us

[Company legal name] TBC
[Address] TBC
Email: support@tomobox.world
Data protection contact / EU or UK representative, if required — TBC