1. Service and operator

東会道 Toukaidou helps Japanese professionals practise business English. An AI plays a manager, client or colleague, then provides written feedback. This is currently a free test version for invited testers aged 18 or older.

Operator: Avtaar Singh KalsiContact: hello@toukaidou.jpAddress: disclosed without delay on request.

2. Information handled

• Account: last name, first name, email address, password, and the versions of the Terms and this notice accepted, with acceptance times. The login provider stores the password as a hash; the operator cannot see it.
• Approximate location: country and time zone estimated from the IP address at registration and each session’s start. The Toukaidou app does not store the IP address itself, but hosting providers may retain it in normal server logs.
• Practice content and records: both sides’ transcripts, time taken to start answering each turn, session length, start and end times, scenario, difficulty, normal completion or connection drop, and written feedback. We also record notes derived from transcripts: number of turns, whether you began by apologising for your English, and whether the task was completed.
• Session-start logs: start time, scenario, difficulty, country and time zone, for managing the daily limit.
• Enquiries: emails sent to hello@toukaidou.jp.
• Bot checks: Cloudflare Turnstile processes browser and device signals on registration, login and password-reset screens.

Microphone audio streams directly from your browser to OpenAI. Toukaidou does not record or retain audio. See section 4 for OpenAI’s retention.

We use only the necessary login session cookie, with no analytics, advertising or tracking cookies.

3. Purposes

We use information to provide conversations and feedback, manage accounts, email confirmation and password-reset codes, manage the daily practice limit, prevent abuse, understand users’ countries, improve the test service, and contact testers about their experience. The daily limit resets at midnight in the estimated time zone.

The operator may read transcripts and feedback to improve scenarios, AI behaviour and feedback quality.

We also use anonymised data for research or product statistics. 【要確認：anonymisation method, specific research/statistical purposes, and whether data will be shared or published】

We do not sell data or use it for advertising or training Toukaidou’s own AI models.

4. Providers and international transfers

We use the following providers, and data is also handled outside Japan.

Countries’ protection systems (from the Personal Information Protection Commission’s published reports):

• USA: no comprehensive federal personal-information protection law; sector-specific laws such as the Electronic Communications Privacy Act (ECPA) and state laws such as California’s. No federal provisions were found matching the OECD Privacy Guidelines’ data quality, purpose specification, openness and accountability principles (as of October 2021). Participates in the APEC Cross-Border Privacy Rules (CBPR) system.
• Singapore: a comprehensive Personal Data Protection Act (PDPA) for the private sector. Police can order businesses to produce information (Criminal Procedure Code), with no provisions found for, e.g., approval by an independent body (as of February 2022). Participates in the APEC CBPR system.
• EU member states such as France and Lithuania, and the UK: protected under the GDPR and related laws, and recognised by the Commission as having a standard equivalent to Japan’s.

OpenAI’s published API policy: API data is not used to train or improve its models unless the customer explicitly opts in to sharing. Abuse-monitoring logs may contain inputs and outputs and are retained for up to 30 days by default, with longer retention where legally required or reasonably necessary to prevent harm. Separate feature-specific storage may apply. Toukaidou uses the Realtime API for voice conversations and the Chat Completions API for feedback. It uses no feature that stores conversation content on OpenAI’s side, and data sharing is not enabled.

For providers in the USA and Singapore (OpenAI, Vercel, Supabase and Cloudflare), we provide the information above and obtain your consent to transfer to third parties in foreign countries when you agree to this notice at registration. EU member states and the UK are recognised as having an equivalent standard to Japan’s, so transfers there are outside this consent. Each provider publishes its subprocessors, and data may be processed in other countries.

5. Retention and security

Information linked to an account is retained until the account is deleted. 【要確認：deletion completion time, treatment of backups, consent records and provider logs, and retention of enquiry emails—including from people without accounts】

Retention of anonymised research/statistical data: 【要確認：retention period and treatment after account deletion】.

Connections use HTTPS encryption. Database row-level security restricts users to their own data. Passwords are hashed. On Toukaidou’s side, only the operator has administrative access.

6. Requests, contact and changes

Please do not share company-confidential information or other people’s personal information in sessions. Fictional names and details work fine for practice.

You can delete your account at any time from the Account screen (Delete account). This deletes your account and all linked practice records, including transcripts and feedback. For other requests, such as access, correction or a stop to the use of your data, email hello@toukaidou.jp. Response/action time: 【要確認：period from receipt to response/action】.

Changes to this notice will be announced in the app or by email.