Privacy Policy
This is a draft for the test period and may change before release.
Effective date: Draft
SHIFTEX, LIMITED LIABILITY COMPANY (the “Company,” “we,” or “us”) describes below how it handles information in Kogu (the “Service”).
At a glance
- We do not collect email addresses or passwords for sign-in.
- If you do not use AI, your ride records are stored on your device.
- We do not use your conversations or ride content for advertising or sell that content.
- We do not use your conversations or ride content to train AI.
- You can turn AI off at any time, export your data, and close your account in the app.
1. Information we handle
| Category | Information | Where it is stored |
|---|---|---|
| Account | User ID, passkey public keys, recovery code hash, consent version | Server |
| Conversations | AI conversations, things the AI remembers, character settings | Server |
| Rides | Ride summaries (distance, duration, speed). Full routes are stored on your device | Server and device |
| Location | Commute start and destination, approximate location for weather | Server |
| Garage | Bike model, components, photos, bicycle registration number, frame number, insurance information | Server and device |
| Notifications | Device push notification token, notification settings | Server |
| Billing | Plan status, purchase identifiers. We do not receive your card number | Server |
| Usage | Screen views, interactions, device type, error records | Google Analytics and similar services |
| Health | Heart rate and other data you permit. Handled only on your device and in Health | Device |
Bicycle registration numbers and frame numbers are encrypted when stored.
2. Why we use information
- To provide the Service, AI responses, morning messages, and notifications
- To authenticate accounts, prevent misuse, and manage usage
- To respond to support requests
- To improve features and fix problems through usage analysis
- To meet legal requirements
3. AI processing
- We send conversations and necessary context to our AI provider to generate responses.
- We do not use conversation or ride content to train AI, and we do not allow our providers to use it for training.
- Software retrieves factual information, such as numbers and weather, and supplies it to the AI.
- You can view and delete what the AI remembers in the app’s Memory screen.
- Our staff do not ordinarily read conversations. They may review the minimum necessary information when needed for support, safety, abuse investigations, or legal requirements.
4. Providers and external services
| Provider | Purpose | Principal location |
|---|---|---|
| Anthropic | Generating AI responses | United States |
| Google Cloud | Servers and database | Japan |
| Google Analytics | Usage analysis | United States |
| Apple | Notifications, weather, in-app purchases | United States |
| Cloudflare | Website delivery and network proxying | United States and other locations |
| RevenueCat | Subscription management | United States |
We do not disclose personal data to third parties except:
- With your consent
- Where required by law
- Where necessary to protect someone’s life, physical safety, or property
5. International transfers
Some providers listed above are outside Japan. We use contracts and other measures to ensure appropriate handling of personal data. For information about other countries’ systems, see the Personal Information Protection Commission’s research on personal information protection systems in other countries.
For transfers from the EEA, the United Kingdom, or Switzerland, we use applicable transfer mechanisms, such as standard contractual clauses.
6. Retention
- We retain account data until you close your account.
- When you close your account, server data is deleted immediately. Backups are deleted within 30 days.
- Ride records remain on your device until you delete the app.
- Information that must be retained by law is kept only for the required period.
7. Your choices
- Turn AI off in Settings and use Kogu as a ride recording app.
- Turn notifications off in Settings.
- Delete remembered information in Memory.
- Export your data from the Account screen.
- Close your account from the Account screen.
- Manage Health and location permissions in iPhone Settings.
Contact us below to request access, correction, or suspension of use of your information. We will verify your identity.
8. Regional rights
If you are in the EEA, the United Kingdom, or Switzerland, you have rights of access, rectification, erasure, restriction of processing, data portability, objection, withdrawal of consent, and complaint to a supervisory authority. Our legal bases for processing are performance of a contract, consent, legitimate interests, and legal obligations.
Residents of California and other US states have rights under applicable state laws, including rights to know, delete, correct, and receive equal treatment when exercising those rights. We do not sell personal information or share it for targeted advertising.
9. Security
- We encrypt data in transit and at rest.
- Database access is restricted to the server.
- We store only hashes of recovery codes and sign-in tokens.
No security measure is perfect. If a serious breach occurs, we will provide notice as required by law.
10. People under 18
AI features are not intended for people under 18. If we learn that we hold information from someone under 18, we will delete it.
11. Changes
We will announce changes in the app or on our website. We will ask for your agreement again for material changes.
12. Contact
SHIFTEX, LIMITED LIABILITY COMPANY
Representatives: Managing Members 和田 凱 and 岡本 徹平
Address: 4-18-16 Komazawa, Setagaya-ku, Tokyo 154-0012, Japan
Contact: info@shiftex.jp