Real Time Translator Product Privacy Policy (by Edition)

PRIVACY POLICY

Fairuse Inc. (hereinafter referred to as the “Company”) establishes this Privacy Policy regarding the handling of personal information and related data in providing the various editions of Real Time Translator (“RTT”), including the Desktop Edition, Web/Teams Edition, and RTT Portal (collectively referred to as the “Product”).
Please review the contents of this Policy before using the Product.
Matters not specified in this Policy, as well as the handling of personal information related to the Company’s overall business operations (including principles, security measures, procedures for disclosure requests, cookies, etc.), shall be governed by the Company’s “Personal Information Protection Policy for General Business Operations.”
https://fairuse.jp/en/userprofileinformation/

0．Terminology (Notes on GDPR Terminology)

In this Policy, the terms “Controller” and “Processor” are used as defined under the General Data Protection Regulation (GDPR).
In the context of the Japanese Act on the Protection of Personal Information (APPI), these concepts roughly correspond to:

  • Controller: Personal Information Handling Business Operator (management entity)
  • Processor: Entrusted contractor

1．Our Role as Controller / Processor (Common to All Editions)

Depending on the use of the Product, the Company may process personal information in either of the following capacities.

(1) Processor (when the customer entrusts the Product to us)
When the Product handles conversation data, such as meeting audio, transcripts, translations, corrections, and summaries (collectively “Conversation Data”), the contracting organization (customer company or organization) typically acts as the Controller, and the Company acts as a Processor.
In such cases, the Company processes the data only within the scope of the customer’s instructions and applicable agreements (including DPA).
As stated in the Company’s general personal information protection policy, the Company may not be able to independently respond to requests for disclosure in such cases.

(2) Information handled as Controller
On the other hand, the Company may act as a Controller when handling contact information and similar data obtained for:

  • contract management
  • billing and payment management (such as invoice issuance)
  • responding to inquiries

Such handling shall follow the Company’s general privacy policy.

2．Categories of Information Processed in the Product (Common to All Editions)

The Product mainly handles the following categories of information:

  • Authentication and display information
    (accounts, display names, email addresses)
  • Tenant-related information
    (integration settings such as Tenant ID)
  • Conversation Data
    (audio, transcripts, translation results, conversation history, texts subject to correction or summarization)
  • Configuration information
    (word conversion rule files, Azure AI Services API keys, region information)
  • Logs for operation and maintenance
    (application logs, error logs, authentication logs)
  • Note：
    Logs and data stored by the Company for the provision of the Product do not include device identifiers or IP addresses.
    (Cookie usage for the Web/Teams edition and RTT Portal is described later.)

3．Security Measures (Common to All Editions)

As described in the Company’s general privacy policy, the Company implements continuous organizational and technical measures, including:

  • operation in compliance with Personal Information Protection Management System (JIS Q 15001)
  • information security management based on ISMS (ISO/IEC 27001)

4．Cloud Services and Data Center Locations (Common to All Editions)

  • The Product is provided using Microsoft Azure.
  • The primary data center used is Microsoft Azure Japan East region.

However, when advanced services are used (such as features using Azure OpenAI for correction or summarization), overseas data centers (such as those in North America) may be used.
If information regarding the destination country/region or service providers is required, please contact the Company’s personal information inquiry desk.

5．Use of Microsoft Services and Secondary Use of Data (Common to All Editions)

In providing the Product, the Company may use Microsoft’s paid services, including but not limited to:

  • Speech Services
  • Speech to Translate
  • Translator
  • Text to Text
  • Azure OpenAI (where applicable)

The Company selects contractual service offerings under which data of the Company and its customers is not used for secondary purposes, such as:

  • model training
  • marketing

The Company confirms these conditions through publicly available information from the provider and through support channels.

6．Handling by Edition

  1. 6-1．Desktop Edition (Real Time Translator Desktop)

    6-1-1．Information Collected and Purpose of Use

    The Company processes the following information to the extent necessary for providing this edition.

    (A) Authentication and display ・Microsoft 365 account
    Authentication of contract information and association with chat rooms
    ・Microsoft 365 display name
    Screen display during login and chat window display
    ・Email address
    Authentication of contract information and chat room association
    ・Email address (RTT Portal username)
    Display during login and chat window displ
    (B) Tenant related information ・Tenant ID
    Identification of the contracting tenant and Microsoft 365 integration configuration
    (C) Conversation data ・User audio
    For speech-to-text conversion and translation
    ・Conversation logs (transcripts and translation results)
    For screen display, history export, and optional correction or summarization
    (D) Configuration information ・Word conversion rule files
    For converting recognized text into specified terms
    ・Azure AI Services API key and region information
    For speech recognition and translation
    (E) Operation and maintenance ・Application logs / error logs / authentication logs
    For troubleshooting, maintenance, and security
    ・Chat room participation information
    For service provision
    6-1-2．Generative AI Correction and Summarization

    This edition may provide features using generative AI (such as Azure OpenAI) including:

    • transcript correction
    • conversation summary generation

    In such cases, conversation history (transcripts and translations) may be transmitted for AI processing.
    The Company does not use conversation data for independent purposes such as analysis, model training, or marketing.

    6-1-3．Data Storage Locations
    • Conversation logs: Local PC
    • Output files such as summaries: Local PC
    • Azure AI Services API keys: Azure database server
    • Application logs / error logs / authentication logs: Azure servers
    • Chat room participation information: Azure servers
    6-1-4．Retention Period and Deletion
    • Conversation logs stored on local PCs should be deleted according to the policies of the user or contracting organization.
    • Azure logs are retained only for the minimum period necessary for stable operation and troubleshooting and are automatically deleted after approximately 7 months.

    Where legal obligations require longer retention, those requirements take precedence.
    Once deleted, data cannot be restored.

    6-1-5．Cookies

    The Desktop edition does not rely on browser cookies.

    6-1-6．Requests for Disclosure

    Conversation data handled as Processor should be requested through the Controller (customer organization).
    For information handled as Controller (such as billing or contract management), requests are handled according to the Company’s general privacy policy.

  2. 6-2．Web Edition / Teams Edition

    6-2-1．Information Collected

    The Company may process the following information:

    • Microsoft 365 account / display name
    • email address
    • tenant ID
    • participant audio
    • conversation logs
    • guest email addresses (when using guest invitation features)
    • Azure AI Services API keys
    • operational logs
    6-2-2．Generative AI Features

    Correction and summarization features may also be provided using generative AI.
    Handling is the same as described for the Desktop edition.
    Conversation data is not reused by the Company.

    6-2-3．Conversation Log Storage Patterns (Important)

    Two storage patterns exist.

    Pattern 1
    Conversation logs stored for web browser viewing.

    • Stored in Azure database servers
    • Retention period follows customer instructions

    Pattern 2
    CSV download per meeting/chat room.

    • Licensed participants may download logs to their own PCs.
    • After browser sessions end, temporary memory data in Azure is deleted.

    Downloaded CSV files are managed under the customer’s internal governance.

    6-2-4．Data Storage Locations
    • Azure AI Services API keys: Azure database servers
    • logs: Azure servers
    • chat room participation data: Azure servers
    6-2-5．Retention
    • Pattern 1 logs follow customer instructions
    • Pattern 2 logs are managed by the customer
    • logs stored by the Company are retained for approximately 7 months
    6-2-6．Cookies

    For browser-based usage, cookies may be used for:

    • maintaining login sessions
    • security
    • configuration retention

    See the Company’s general privacy policy for cookie details.
    Logs stored by the Company do not include device identifiers or IP addresses.

  3. 6-3．RTT Portal

    RTT Portal is a management interface used to manage:

    • contract information
    • user information
    • configuration settings
    6-3-1．Company Role

    Portal data may be handled under two roles.

    • (A) Controller
      Information for contract management and communication.
    • (B) Processor
      User and configuration information registered by customers.
    6-3-2．Information Collected
    (A) Contract management ・company name
    ・contact email address
    ・contracted edition
    ・contract period
    ・RTT usage time
    (B) User authentication and configuration ・Microsoft 365 account or email
    ・portal username
    ・tenant ID
    ・user information (groups etc.)
    ・encrypted Azure AI Services API keys
    (C) Operation and maintenance ・Application logs / error logs / authentication logs
    For troubleshooting, maintenance, and security
    6-3-3．Data Storage

    All portal information is stored in:

    • Azure database servers
    • Azure application servers

    Logs are stored on Azure servers.

    6-3-4．Retention
    • Contract management information: retained during the contract period and 7 months after termination
    • User/configuration information: retained according to customer instructions
    • logs: retained for approximately 7 months

    Deleted data cannot be restored.

    6-3-5．Cookies

    RTT Portal uses cookies for:

    • session management
    • security
    • configuration retention

    Logs stored by the Company do not include device identifiers or IP addresses.

    6-3-6．Disclosure Requests

    For Controller data handled by the Company, requests follow the Company’s general privacy policy.
    For Processor data, requests should be directed to the customer acting as Controller.

7．Revisions

The Company may revise this Policy in response to:

  • legal or regulatory changes
  • feature additions or modifications to the Product

Revisions become effective when published on this page.