Inside Sales Co., Ltd. (インサイドセールス株式会社) ("we") sets out this privacy policy ("this Policy") as follows for the personal information handled in "Hotori" ("the Service") and its website. We comply with the Act on the Protection of Personal Information ("APPI"), the Telecommunications Business Act, and other relevant laws, regulations, and guidelines.
1. Information we collect
The Service collects the following information.
(1) Account information
- Email address
- Display name (if you log in with a Google account, the Google account's name is used as your first display name. You can change it later on the "Profile" screen.)
- Identifier used to log in (a number issued by Firebase Authentication)
- Avatar color, date and time of registration, and date and time of last use
(2) Space information
- Space name and the selected template (map)
- Participants and their roles (owner, admin, member, guest)
- Invite records (invite type, expiry, who issued it, and how many times it was used) and records of removal from the space
- Settings made by the owner (guest password, allowed domains, and the destination and events for external notifications; for notifications to Chatwork, the Chatwork room ID and API token). Guest passwords are stored only in an irreversible form (a hash value). The Chatwork API token is stored in order to send notifications and is not shown on the settings screen either.
(3) Payment information
- Plan, contract status, and the end dates of the trial period and the contract period
- Customer and contract numbers at Stripe
- Records of payment notifications received from Stripe (which may include the billing name and email address, amounts, periods, and so on)
- If you sign up for yearly billing with payment by invoice (bank transfer), the invoice addressee (such as a company name) and the email address to which the invoice is sent (these are registered with Stripe, and Stripe sends the invoice)
- For customers whose billing address is outside Japan, the billing address and, if entered, a business tax ID (entered on Stripe's screen, and also kept in the records of payment notifications received from Stripe)
- Card numbers and the like are entered directly by users on Stripe's screen, so they do not reach our servers and we do not store them.
(4) Calendar information (only if you register it)
- The URL registered in "Calendar (ICS URL)"
- Whether it is currently within the time of an event, and the time that event ends
- Events are read every 5 minutes (recurring events are read as well). Event titles, participants, body text, and the like are not stored.
(5) Connection records
- IP address, date and time of access, features used (pages and APIs opened), date and time of entering and leaving, and a number that distinguishes users
- Information sent along with communications, such as browser and device type
- When a space is created, a marker showing which page or ad the person came from (the location of the introductory page, and the ad's name and keyword)
(6) Inquiry information
- When you contact us by email: your name, email address, and the content of your inquiry
(7) Browsing information for this website (the introductory pages)
- The address of the page opened and the address of the page viewed before it (the referrer), measurements such as the time taken to display the page, and the browser and device type
- These are aggregated using Cloudflare Web Analytics (see sections 6 and 9). Cookies are not used.
2. Information we do not store
- Voice, video, screen share, chat, notes added to knocks, and avatar positions pass through our servers in order to reach the other party, but we do not store them. There is also no audio or video recording feature.
- Chat is delivered only to the people in the space at that time (meeting room chat, only to the people in the same meeting room at that time). No history that can be read later is kept.
3. Purposes of use
We use the information we collect for the following purposes.
- To provide the Service (login, running spaces, delivering voice, video, and chat, invites, displaying status, external notifications, and automatic status switching based on calendars)
- To bill fees and manage payments (including deciding whether Japanese consumption tax applies, and keeping a record of that decision)
- To verify identity, prevent and investigate unauthorized use, and ensure security
- To investigate and fix failures
- To respond to inquiries
- To send important notices, such as changes to terms, changes to fees, failures, and the end of a contract
- To improve the Service (we use usage data aggregated in a form that does not identify individuals; we do not use the content of conversations)
- To aggregate the number of views of this website, where visitors came from, and which pages and ads led to the creation of spaces, in order to improve the website and the information we provide about the Service (aggregated in a form that does not identify individuals)
- To know when a free trial starts and use this in operating the Service (when a space is created, we send the space's name, the owner's display name and email address, a marker showing which page or ad they came from, and the date and time to our own email address. When a paid plan is signed up for, we likewise send the space's name, the plan, the payment method, the amount, the billing country, and the marker showing which page or ad they came from)
- To respond to acts that violate the Terms of Service
4. Information visible to other users in a space
- Users in the same space can see each other's display name, avatar color and position, status (Available, Away, Focusing, In a meeting), location (such as a meeting room), raised hands, and reactions.
- Voice, camera video, and screen share reach only nearby users within voice range (inside a meeting room, users in the same meeting room). At a focus desk, neither voice nor video is exchanged. Our server decides who they reach, and the media server passes them only to those people.
- If you register a calendar, then while you are in a space, if your status is "Available" when an event starts, it automatically changes to "In a meeting", which other users can also see (recurring events are included). Event titles and the like are not visible.
- The owner and admins can also see users' email addresses and roles.
- If the owner sets up "External notifications (Webhook)", then when a selected event (knock, join, or leave) occurs, the event, the display name of the person involved and a number that distinguishes users, the space's name and identifier (the string used in the URL), and the time are sent to the destination specified by the owner. If the Slack format is selected, only 1 sentence containing the display name and the space's name is sent. If Chatwork is selected, only that same sentence is posted to the specified Chatwork room using the API token registered by the owner (posts are made under the name of the holder of that API token).
5. Provision to third parties
Except in the following cases, we do not provide personal data to third parties without first obtaining the consent of the person concerned.
- Cases based on laws and regulations
- Cases where it is necessary to protect a person's life, body, or property and it is difficult to obtain the consent of the person concerned
- Cases where it is especially necessary to improve public health or promote the sound development of children and it is difficult to obtain the consent of the person concerned
- Cases where it is necessary to cooperate with a national government agency, a local government, or a party entrusted by them in carrying out duties prescribed by laws and regulations, and obtaining the consent of the person concerned is likely to interfere with those duties
Note that entrusting information to the external services described in section 6 below, and passing information on to a party that takes over the business, do not constitute provision to third parties, to the extent provided by laws and regulations.
6. External services we use
The Service is provided using the following external services. The information each provider handles is limited to the extent necessary to provide the Service.
Firebase Authentication (Google LLC)
- Role
- Login and identity verification (including sending login emails). When you log in with a Google account, you connect to Google's login screen through Firebase Authentication.
- Information handled
- Email address, display name, identifier used to log in, login records, IP address, and so on
- Provider's country
- United States (processing takes place in data centers in the United States)
Stripe (Stripe, Inc.)
- Role
- Credit card payments for paid plans, issuing receipts, and the payment management screen. For payment by invoice on yearly billing, issuing invoices and sending them by email, and accepting bank transfers (Stripe provides a transfer account for each customer). Used from the time you sign up for a paid plan.
- Information handled
- The owner's email address, space name, contract and payment information, the invoice addressee and destination email address (for payment by invoice), and the billing address and business tax ID (for a billing address outside Japan). Card information is received directly by Stripe.
- Provider's country
- United States
SAKURA internet server (SAKURA internet Inc.)
- Role
- The Service's server (where stored data is kept). Inside this server, we also run the media server (LiveKit) that delivers voice and video to the other party, and the relay for logging in with a Google account (auth.hotoriplace.com).
- Information handled
- The information described in section 1 (excluding information received directly by Firebase Authentication and Stripe)
- Provider's country
- Japan (the server is in Tokyo)
Cloudflare® (Cloudflare, Inc.)
- Role
- Managing the Service's domain names (DNS), delivering this website (the introductory pages) (Cloudflare Pages) and aggregating its view counts (Cloudflare Web Analytics), forwarding inquiry emails (support@hotoriplace.com) (Cloudflare Email Routing), and sending the email that tells us a space has been created (Cloudflare Email Service). Communications between users and the app do not pass through Cloudflare.
- Information handled
- Queries made when domain names are looked up (which may include the IP address of the querying party and the like); information sent along with communications, such as the IP address, browser type, and pages opened by people who view this website; view measurements for this website (pages opened, referrer, time taken to display, and so on); inquiry emails (sender's email address, subject, and body); and the email that tells us a space has been created (the space's name, the owner's display name and email address, a marker showing which page or ad they came from, and the date and time)
- Provider's country
- United States
Gmail (Google LLC)
- Role
- Receiving and storing inquiry emails (support@hotoriplace.com). Emails forwarded by Cloudflare Email Routing are received in our Gmail mailbox. The email that tells us a space has been created is received and stored in the same mailbox.
- Information handled
- Inquiry emails (sender's email address, name, subject, and body), and the email that tells us a space has been created (the space's name, the owner's display name and email address, a marker showing which page or ad they came from, and the date and time)
- Provider's country
- United States
7. Use of providers located in foreign countries
- Of the providers in section 6, Google LLC, Stripe, Inc., and Cloudflare, Inc. are providers in the United States. Through these services, part of the personal data is handled in the United States.
- We use these services after checking the United States' system for protecting personal information using information published by the Personal Information Protection Commission. The measures each provider takes to protect personal information are described in that company's terms and privacy policy.
- If the person concerned requests it, we will provide details of the measures we have checked.
8. Security measures
- Encryption of communications: Page and operation traffic is sent over HTTPS, and voice and video are sent with WebRTC's standard encryption. Voice and video reach the other party via our servers.
- Restricting where voice and video go: Who can receive voice and video (including screen share) is decided by our server (nearby users; inside a meeting room, users in the same meeting room), and the media server passes them only to those people. This is not left to the receiving browser.
- Design that does not store: We do not store voice, video, screen share, chat, notes added to knocks, or avatar positions.
- Password protection: We do not hold login passwords. Guest passwords are stored only in an irreversible form.
- Limits on participation: Invite links have an expiry (1 to 30 days). Participation can be restricted by email domain (only verified email addresses are accepted), and guests can be required to enter a password.
- Protection against unauthorized attempts: We set limits on the number of attempts for password entry, knocks, chat, and so on.
- Restrictions on outbound communications: For external notifications and calendar loading, we check the destination and refuse communications directed at internal networks.
- Management structure: We limit the people who handle personal data to those who need to. Connections for server administration are limited to key-based authentication.
- Backups: We back up the database every day and keep 14 days of backups. Backups are kept in the same server, with settings that only administrators can read.
- Understanding the external environment: See section 7.
9. Browser storage and cookies
- The Service's app uses browser storage (such as local storage) to keep your login state, display settings, and the marker showing which page or ad you came from (until a space is created, for up to 30 days).
- The Service's app and website do not use cookies for advertising or access analytics. They do not use ad tags either.
- This website (the introductory pages) uses Cloudflare Web Analytics to count views. It does not use cookies or browser storage. The app has no access analytics program.
- Information sent from users' devices to external providers is shown in the Disclosure under the External Data Transmission Rules.
10. Retention periods
- Account information: Until you delete your account. You can delete your account from "Profile" in the app or from the home screen (if you own a space, first transfer the owner role or delete the space). When you delete your account, we erase your account information and your records as a member of the spaces you joined, and we also erase the account used to log in (Firebase Authentication).
- Space information (members, invites, settings): While the space exists. If the owner deletes a space, it is erased 30 days after the deletion. A space that has stayed paused for 90 days, whether paused after the trial period ended or after cancellation, is also erased. In the case of cancellation, the 90 days are counted from the day the period already paid for ended. Until we begin accepting sign-ups for paid plans, spaces are not paused even after the trial period ends, so this 90-day period does not begin (Terms of Service, Article 6, paragraph 6).
- Payment records: For the period required by laws and regulations
- Connection records: For the period needed to investigate failures and respond to unauthorized use
- Calendar information: Until you delete the URL or delete your account (when you delete the URL, the event end time is also erased)
- Inquiry information: For the period needed to respond
- Emails telling us that a free trial has started: For the period needed to operate the Service. They remain in our mailbox, so they are not erased automatically when you delete your account (you can request erasure as described in section 11).
- Backups: Information stored in the database on our server is also included in the daily backups. Because only 14 days of backups are kept, information erased under the periods above also disappears from the backups in turn.
11. Requests for disclosure and other actions
- With respect to personal data we hold, the person concerned may request notification of the purpose of use, disclosure (including records of provision to third parties), correction, addition, or deletion of the content, suspension of use or erasure, and suspension of provision to third parties.
- Please contact the contact point in section 14 by email. After confirming that you are the person concerned, we will respond without delay in accordance with laws and regulations.
- You can change or delete your display name, avatar color, and calendar URL at any time on the "Profile" screen in the app. Members and guests can also leave a space. If you want to delete the account itself, you can do so on the app's screens (as described in section 10).
12. Secrecy of communications
- We protect the secrecy of communications in accordance with the Telecommunications Business Act. We do not view or listen to the content of voice, video, screen share, or chat, and, except in cases based on laws and regulations, we do not disclose it to others.
- We also treat connection records as covered by the secrecy of communications, and use them only to the extent necessary to provide the Service, such as investigating failures and responding to unauthorized use.
13. Changes to this Policy
- We may change this Policy to reflect changes in laws and regulations or in the Service.
- We will give advance notice of important changes on the Service's screens or website, and will obtain the consent of the person concerned where laws and regulations require it.
- The changed Policy takes effect when it is posted on this page.
14. Contact point
For inquiries about the handling of personal information, please contact the following contact point by email.
- Business operator
- Inside Sales Co., Ltd.
- Address
- 1-31-16 Takadanobaba, Shinjuku-ku, Tokyo 169-0075, Japan (ワイム高田馬場ビル)
- Personal information protection manager
- Inside Sales Co., Ltd., Responsible person 菊池 孝行