Soroban Portal Privacy Policy

This is an English reference translation. Only the Japanese version is legally binding. If the two versions differ, the Japanese version prevails.

SIC Co., Ltd. ("we", "us" or "our") handles personal information in the "Soroban App School and Organization Account Discount" and its management site "Soroban Portal" (together, the "Service") as follows, in accordance with the Act on the Protection of Personal Information and other laws and regulations.

1. Business operator

• Name: SIC Co., Ltd.
• Address: #1-1-1 Osaka Ekimae No.3 Bldg 29F, 1-1-3 Umeda, Kita-ku, Osaka-shi, Osaka-fu 530-0001, Japan
• Representative: Hiroki Inoue, Representative Director

2. Scope of this policy

1. This policy covers the personal information of Subscribers to the Service (schools and organizations) and their administrators, and of the users of accounts that Subscribers issue through the Service (students and teachers).
2. Information generated when the Soroban app is used with an issued account (such as learning records) is handled under the Soroban app privacy policy.

3. Information we collect

1. Administrator information: the email address used to sign in to Soroban Portal, and identifiers assigned by the authentication system (including the identifier of the Google Account when signing in with a Google Account)
2. School information: school name, country of the school (Japan or outside Japan), and subscription status
3. Account user information: the display name and role (student or teacher) entered by the Subscriber, the login ID we assign, and whether the account is active or disabled. Passwords are kept only in a form converted by the authentication system for verifying sign-ins; we never store or view the passwords themselves
4. Payment information: school name, administrator's email address, and the status of the subscription, invoices and payments. Payment details such as credit card numbers are collected directly by the payment service (Stripe), and we do not keep them
5. Operation records: for operations performed in Soroban Portal, the administrator who performed them, the date and time, and what was done (including, for example, a display name before and after a change; passwords are not included)
6. Access records: information such as IP address, date and time, and browser type that comes with access to the Service
7. Records of sending sign-in links: the recipient email address and the source of the connection, converted into values that cannot be restored to the original, and the number of sends

4. Purposes of use

1. To provide and manage the Service, including issuing, disabling and re-enabling accounts
2. To bill and collect fees and to issue receipts and invoices
3. To send notices about the Service and to respond to inquiries
4. To prevent unauthorized use, investigate failures and operate the Service safely
5. To improve the Service

5. Provision to third parties

1. We do not provide personal information to third parties without the consent of the individual, except where required by law or otherwise permitted by law.

6. Entrustment and handling outside Japan

1. To the extent necessary to achieve the purposes of use, we entrust the handling of personal information to the following businesses.
2. Google LLC (United States): authentication (Firebase Authentication), data storage (Google Cloud Firestore, stored in the Tokyo region), server operation and access records
3. Stripe, Inc. (United States) and its group companies: payment of fees and issuing invoices and receipts. The handling of payment information is also subject to Stripe's privacy policy
4. Amazon Web Services, Inc. (United States; sending is done in the Tokyo region): sending emails with sign-in links
5. Cloudflare, Inc. (United States): detecting fraudulent automated access on the sign-in page
6. The system for the protection of personal information in the United States is as described in the survey of systems for the protection of personal information in foreign countries published by the Personal Information Protection Commission, Japan (Japanese only). Based on an understanding of that system, we take measures to select and supervise the businesses we entrust and other measures for safe management.

7. Retention period

1. Operation records are deleted automatically 3 years after the date they were recorded.
2. Access records are, as a rule, deleted after 30 days.
3. Records of sending sign-in links are, as a rule, deleted automatically within 3 days.
4. Other information is kept during the subscription and, after it ends, for the period required by law or necessary to operate the Service, and is deleted when no longer needed.

8. Security measures

1. Sign-in to Soroban Portal is limited to Google Accounts or a sign-in link in an email received by the person themselves, and each administrator can handle only the information of the schools they manage.
2. Two-step verification is set up on the accounts of our staff who manage the whole Service.
3. Communication is encrypted (HTTPS), and operation records are kept.
4. When we entrust businesses outside Japan, we take measures based on an understanding of that country's system, as described in Section 6.

9. Information about students

1. Display names are entered by the Subscriber. A display name does not have to be a full name; the Service can be used with a nickname or similar.
2. The Subscriber shall explain to students and their guardians the use of the Service and the handling set out in this policy.

10. Requests for disclosure and inquiries

1. We accept requests for notification of the purposes of use, disclosure, correction, addition or deletion, suspension of use or erasure, suspension of provision to third parties, and disclosure of records of provision to third parties concerning retained personal data, as well as inquiries and complaints about the handling of personal information, at the contact below. After confirming the identity of the individual, we will respond without delay in accordance with the law.
2. Contact: Personal Information Inquiries, SIC Co., Ltd. Email: support@sicorp.jp

11. Revisions

1. We may revise this policy in response to changes in laws or to the Service. The revised policy takes effect when it is posted on this page.

SIC Co., Ltd.
support@sicorp.jp
Established: October 25, 2026

Terms of Use (Soroban App School and Organization Account Discount) ・ Disclosure under the Act on Specified Commercial Transactions