Privacy Policy
Established: 3 May 2026 / Last revised: 30 August 2026
This English version is a translation provided for convenience. If there is any difference between the Japanese and English versions, the Japanese version prevails.
Introduction
Raflect Inc. ("we") handles user information in INUPLA, our app for dog owners ("the service"), in accordance with this Privacy Policy. The service includes the app, related web pages, Firebase and other backends, notifications, advertising, AI chat, records, walk tracking, training courses, the dog personality quiz, health history and reminders, connections to external services, subscriptions and other related services. Established: 3 May 2026 Last revised: 17 August 2026 Company: Raflect Inc. Address: Aoyama Marutake Bldg. 6F, 3-1-36 Minami-Aoyama, Minato-ku, Tokyo 107-0062, Japan Representative: Koya Wakiyama Contact: info@raflect.co
1. Information we collect
We collect the following, to the extent needed to provide the service. 1. Account information Firebase Authentication user ID, sign-in method (Apple, Google and so on), email address, display name, user ID, profile image, language setting, creation date, last sign-in date, notification settings, and information about switching accounts. 2. Dog information Name, breed, sex, weight, birthday, photos, whether you keep the dog, whether they are neutered or spayed, answers and results of the personality quiz, health certificates, vaccination certificates, rabies vaccination certificates, registration tags, microchips, pedigrees, pet insurance documents, clinical records, and other certificate images and information you register. 3. Records and chat Photos, videos, captions, record dates, meals, walks, care, training, achievements, toileting, weight, symptoms, clinic visits and other records, chat history, and information needed for reports, enquiries and support. 4. AI chat Your messages, attached images, conversation history, AI responses, search queries where a search is needed, and the profile information about you and your dog that is passed to the AI to shape its answer. 5. Walks, location and activity Walk start and end times, steps, distance, elapsed time, GPS coordinates, routes, walk goals, walk summaries, images for sharing, and information obtained under the device's location and motion permissions. Location is used for walk records, for generating shareable images, and for other features of the service. 6. Area and weather The postal code you register, and the prefecture and municipality derived from it. These are used to show and notify weather, and to reflect local conditions in AI chat answers. We do not collect a full street address, recipient name or building name, because we do not ship physical goods. 7. Purchases and paid plans Subscription plan, product ID, purchase date and time, purchase receipts and verification data, subscription status, and expiry date. 8. External service connections If you connect Threads: your Threads user ID, username, display name, profile image URL, access token, connection settings, and the content of posts you choose to import or publish. 9. Advertising, device and usage Advertising identifier, App Tracking Transparency permission status, device information, OS, app version, FCM token, IP address, access times, crash and error information, ad impressions and clicks, in-app activity, and information obtained through cookies or similar technologies. 10. Enquiries Subject, message, email address, account identifier, support history, and information needed to verify your identity. 11. Statistics and analysis Statistical, aggregated, anonymised and pseudonymised information, trend analysis, market analysis, reports and other analysis created from the above, from which individuals cannot be identified.
2. How we collect it
We collect the above through what you enter and send, through device permissions, and through Firebase, Google Mobile Ads, Google Sign-In, Sign in with Apple, Threads, in-app purchase and other SDKs and external services. For features that need device permissions — photos, video, location, motion, notifications, tracking and so on — consent is taken through the permission screens of the OS or the app. You can change permissions in your device settings, but some features may stop working if you withdraw them.
3. Why we use it
We use the information we collect for the following purposes. · To register accounts, verify identity, sign in, switch accounts and process account deletion · To provide dog profiles, records, training courses, the dog personality quiz, health history and reminders, and other features · To generate AI chat responses, analyse images, store conversation history, and support dog- and pet-related searches · To provide walk records, GPS routes, steps, distance, walk goals, shareable images and summaries · To show and notify weather, and to provide reminders for health, care, walks, vaccinations and so on · To operate the external connections you choose (importing records from Threads, posting to Threads) · To handle subscriptions, paid plans, purchase restoration, subscription status, benefits, and prevention of payment fraud · To show advertising, measure its effect, and hide advertising for paying users · To respond to enquiries, verify identity, provide support, and send important notices and notices of changes to the terms · To investigate, prevent and respond to misuse, spam, infringement, breaches of the terms and security incidents · To improve quality, develop features, analyse usage and investigate faults · To create statistical, aggregated, anonymised and pseudonymised information and analysis reports from which individuals cannot be identified, and to use them for our own analysis, research and development, and consideration of new services · To carry out underwriting, rate setting, risk analysis, policy administration and claims administration where a user applies for insurance, mutual aid or other financial services, and for us or our group companies to consider, develop and provide such services · To consider, develop and provide new businesses such as adoption and matching, services for shops and breeders, health, medical and care services, and data analysis and provision · To jointly use personal data with group companies, affiliates or partners within the scope set out in Section 5 · To provide corporate analysis information from which individuals cannot be identified, with or without charge, to pet businesses, advertisers, research institutions, insurers, financial institutions, local governments and partners, for product development, advertising, market analysis, research, risk analysis and regional analysis · To respond to requests from laws, courts, public authorities and store operators, and to internal audits Information obtained from Threads (your Threads user ID, username, display name, profile image URL, access token, and the content of the posts you choose to import) is not used for any of the following purposes in this section: showing, delivering or measuring advertising; sale or provision to third parties; creating or providing corporate analysis information; or underwriting, rate setting or risk analysis for insurance, mutual aid or other financial services. We use this information only to import your own records and to post to Threads as you choose.
4. What is shared
The service has no posting, feed, follow, ranking or other features that publish content between users. Your records, photos, chats and walks are handled as your own records. If you share a personality quiz result image, a walk record image, a care pass for sitter mode, an invitation link or other content to a social network, a messaging app, Threads or another external service, third parties may be able to see it, depending on the settings of that service. Please check the content before you share it. For information you save inside the service, we may review it to the extent necessary for operations, legal compliance, fraud prevention and fault investigation. Detailed GPS coordinates such as walk routes are handled as your own records and are not disclosed to third parties unless you choose to share them.
5. Provision to third parties, joint use, transmission abroad and outsourcing
We do not provide personal data to third parties without consent, except in the following cases. · Where required by law · Where necessary to protect life, body or property and it is difficult to obtain consent · Where particularly necessary for public health or the sound growth of children · Where cooperation with national or local government or their contractors is needed · Where personal data is transferred with a merger, company split, share transfer, business transfer or other succession (including the transfer of all or part of our business or shares to a third party). In that case, the successor handles personal data within the purposes set out in this Policy · Where you choose to publish, share or send it · Where we outsource handling within what is needed to achieve the purposes above [Joint use] We may jointly use personal data as follows. Under the Act on the Protection of Personal Information, joint use is not provision to a third party. · Items jointly used: account information, dog profile, health, care, records, walks and contract information, usage information and the other items in Section 1 · Scope of joint users: our group companies and affiliates (including companies in insurance and small-amount short-term insurance, adoption and shop-facing business, health and medical business, and data analysis and provision) · Purpose of joint use: the purposes in Section 3 (including, beyond providing and improving the service, the consideration, development and provision of insurance, adoption, data and other new businesses) · Party responsible for management: Raflect Inc. (address and representative as in Section 13) If we change the scope of joint users or the purpose, we will notify you in advance or make the change readily available to you, as required by law. We do not sell personal data that can identify you — such as your name, email address, postal code, detailed GPS routes, the content of records and chats, or certificate images — to corporate customers. In accordance with the law, we may provide information that has been aggregated, statistically processed or anonymised so that individuals cannot be identified (for example, walking trends by breed, age group, postal code or municipality; times of day; walk frequency; step and distance trends; in-app viewing, clicks, ad response and feature-use trends; ad effectiveness; and interest trends in health and care) to pet businesses, advertisers, research institutions, insurers, financial institutions, local governments and partners, with or without charge. We do not provide it at the level of an individual user, an individual household, or any unit small enough to identify or infer a small number of users. We also do not sell advertising identifiers, device IDs, user IDs, detailed GPS coordinates, individual walk routes or individual time-stamped activity histories to corporate customers. We prohibit re-identification from such information and impose contractual restrictions where necessary. When creating and providing corporate analysis information, we take measures so that individual users cannot be identified: we remove direct identifiers such as names, email addresses and user IDs; we round location and timing to area and period units as far as needed; we hide or merge aggregates covering small numbers of users; and we prohibit attempts at re-identification. If we begin providing corporate analysis information in earnest, we will publish the items provided, the categories of recipients, the method of provision and other necessary matters in this Privacy Policy, in the app, or on our website. When we create or provide anonymised information to third parties, we publish the categories of information it contains and the method of provision, as required by law. When we provide pseudonymised information, personal-related information or other information that the recipient may obtain as personal data, we take the consents, confirmations, records, disclosures and other measures required by law. To the extent needed to provide the service, we may send information to, store it with, or outsource its handling to the following providers or services. · Google / Firebase: authentication, database, storage, Cloud Functions, FCM, Remote Config, Google Sign-In, Google Mobile Ads, Gemini API, Google Search grounding · Apple: Sign in with Apple, App Store, in-app purchase, subscription management, App Tracking Transparency · Google Play: in-app purchase, subscription management, distribution to Android devices · OpenWeatherMap: weather information · Meta Platforms (Threads): where you choose to connect — authentication, importing records, and posts you select · Contractors for email, support, monitoring, analysis and image or video processing: within what is needed for enquiries and operations Messages, attached images, conversation history and related user and dog information entered in AI chat may be sent to Google's generative AI services to produce an answer. Please do not enter unnecessary addresses, phone numbers, health insurance details, payment details or other people's personal information into AI chat. What you do after opening an external link, what you do on an external site, and any enquiries there are governed by that provider's terms and privacy policy.
6. Third parties abroad and processing outside Japan
The cloud, AI, advertising, store, weather, authentication and external connection providers we use may be located outside Japan or may process information outside Japan. The countries concerned include the United States and other countries or regions where those providers or their contractors have offices or servers. When we provide personal data to a third party abroad or outsource its handling, we take the consents, disclosures, contractor management and security measures required by the Act on the Protection of Personal Information and other applicable laws. We will provide information about the systems and measures of overseas providers within a reasonable scope on request.
7. Advertising and tracking
We may show banner, native and interstitial advertising to users on the free plan. Ad providers may obtain advertising identifiers, device information, impression and click information and estimated attributes, and use them for ad delivery, measurement and fraud prevention. Information sent to external providers for ad delivery and measurement may include advertising identifiers and device information, but we do not sell personal data to advertisers. You can control personalised advertising through the App Tracking Transparency permission on iOS, and through the advertising ID setting and other device settings on Android. Even if you do not give permission, non-personalised or contextual advertising may be shown.
8. Security measures
To prevent leakage, loss, damage, unauthorised access and misuse of personal data, we take necessary and appropriate measures including access control, authentication, encryption in transit, Firebase Security Rules, separation of fields containing personal information into non-public areas, log management, selection and supervision of contractors, management of employees and related parties, and vulnerability response. However, internet communication, cloud services, user devices and external services carry inherent risks, so we cannot guarantee absolute safety.
9. Retention and deletion
We retain information for the period needed to achieve the purposes above, for periods required by law, accounting, tax, fraud prevention, dispute handling and audit, or for as long as you hold an account. If you delete your account, we delete or anonymise the dog information, records, chats, walks, settings and other data linked to it, within a reasonable scope. However, information we are required by law to keep, records needed for fraud prevention, safety and disputes, records of payments, subscriptions and enquiries, and information that temporarily remains in backups and logs may be kept for the period needed. If you disconnect Threads, we immediately delete the Threads access token, user ID, username, profile image URL and connection settings. If you remove the service from “Apps and websites” in Threads or Instagram, Meta notifies us and we do the same (we delete only the connection information; records you have already imported remain as your own records). If you formally request data deletion through Meta, we additionally delete the records imported from Threads and the copies of their photos and videos that we stored. Uninstalling the app does not automatically delete your account information on the server or cancel your subscription. Subscriptions must be cancelled in the Apple or Google subscription settings.
10. Your rights
Under the Act on the Protection of Personal Information, you may request notification of the purpose of use, disclosure, correction, addition, deletion, suspension of use, erasure, suspension of provision to third parties, and disclosure of records of provision to third parties, for retained personal data. To make a request, please contact us. After verifying your identity, we respond within a reasonable period as required by law. We may be unable to meet all or part of a request where the law does not allow it, where we cannot verify your identity, where it risks harming the rights or interests of others, or where it would seriously impede our operations. If you have questions about the provision of statistical, aggregated or anonymised information to corporate customers, or wish to be excluded from future creation of such information, please contact us. We respond within what is possible under the law and technically. For statistical information already created in a form that cannot identify individuals, we may be unable to delete or stop it in relation to a specific user.
11. Minors
If a minor uses the service, please obtain the consent of a parent or other legal guardian. Where a minor registers personal information, we treat it as having the consent of their legal guardian. Where a legal guardian requests disclosure, correction, deletion or suspension of use of a minor's personal information, we respond as required by law after verifying identity and authority to act.
12. Changes to this Policy
We may change this Privacy Policy in response to changes in law, changes to the service, changes to external services, and operational improvements. Where we make changes that materially affect users — including provision of personal data to third parties, joint use, provision of statistical information to corporate customers, and advertising and tracking — we will make them known in the app, on our website, by notification or by another appropriate method, and will obtain consent where the law requires it. The revised Policy applies from the effective date we set.
13. Contact
For the handling of personal information, requests for disclosure, complaints, consultations and privacy enquiries, please contact us. Raflect Inc. — INUPLA Personal Information Desk Email: info@raflect.co Address: Aoyama Marutake Bldg. 6F, 3-1-36 Minami-Aoyama, Minato-ku, Tokyo 107-0062, Japan Representative: Koya Wakiyama
Questions about this page: info@raflect.co