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This Privacy Policy ("Policy") explains how Journely LLC ("we," "our," or "Company"), operating Tamhon from Japan, collects, uses, and protects your personal information in compliance with applicable data protection laws, including Japan's Act on the Protection of Personal Information (APPI) and Vietnam's Decree 13/2023/NĐ-CP on Personal Data Protection for our Vietnamese users.

By using our Service, you acknowledge that you have read and understood this Policy. If you do not agree, please discontinue use immediately.

We operate in compliance with applicable data protection laws:

For All Users (Japan-based Operations):

• Act on the Protection of Personal Information (APPI)
• Personal Information Protection Committee (PPC) Guidelines
• Telecommunications Business Act
• Act on Specified Commercial Transactions

For Vietnamese Users (Nghị định 13/2023/NĐ-CP):

• Decree 13/2023/NĐ-CP on Personal Data Protection
• Cybersecurity Law 2018 (where applicable)
• Your data rights under Vietnamese law are detailed in Section 17 below

3.1 Information You Provide

• Account Information: Email address only (we follow minimal data collection principles)
• Birth Data: Date, time, and location of birth for BaZi/Zi Wei chart generation
• Photos: Palm and face photos you upload for readings (processed by AI, not stored permanently)
• Audio: Voice recordings you upload for phonognomy analysis (processed by AI, not stored permanently)
• Conversation History: Your chat interactions with the AI for continuity
• Support Communications: Inquiries and feedback you send to us

3.2 Automatically Collected Information

• Technical Data: IP address, browser type, device information
• Usage Data: Features used, time spent, interaction patterns
• Cookies: Session management and preference storage only
• Location: Country-level only for language preferences

3.3 Information We DO NOT Collect

• Government-issued ID numbers or identification documents
• Financial information (bank accounts, credit cards, income)
• Medical records or health information
• Biometric data for identification purposes
• Photos or audio from minors
• Information about third parties without their consent

3.4 Photo and Audio Processing

• Photos and audio are processed by AI for readings only
• We do not use your photos/audio for facial recognition or identity verification
• Media files are processed in real-time and not permanently stored
• You can request deletion of any stored conversation data at any time

We use your information ONLY for:

• Service Provision: Generating BaZi/Zi Wei charts and providing AI-powered readings
• Reading Analysis: Processing photos and audio for palm, face, and voice readings
• Communication: Sending service updates and responding to inquiries
• Improvement: Analyzing usage patterns to enhance user experience
• Legal Compliance: Meeting regulatory requirements
• Security: Preventing fraud and unauthorized access

We will NEVER use your information for: Facial recognition, identity verification, training AI models on your personal data, or selling to third parties.

5.1 We DO NOT Share Data With:

• Marketing or advertising companies
• Data brokers or aggregators
• Social media platforms
• AI training datasets or research institutions

5.2 Limited Sharing Circumstances:

• AI Processing: Anthropic Claude for generating readings (processed in real-time, not stored)
• Service Providers: Only essential services (e.g., Supabase for authentication) under strict data processing agreements
• Legal Requirements: When required by Japanese law or court order
• Emergency: To protect vital interests or prevent serious harm
• Business Transfer: In case of merger/acquisition (with prior notice)

Important Notice for Vietnamese Users: By using Tamhon, your personal data will be transferred outside of Vietnam. This is necessary to provide our AI-powered services.

Where Your Data Goes:

• Japan: Our primary servers and company operations (Journely LLC)
• United States: AI processing via Anthropic Claude (processed in real-time, not permanently stored)
• United States: Authentication and data storage via Supabase

How We Protect Cross-Border Transfers:

• We ensure adequate protection through contractual agreements with all service providers
• All data is encrypted during transmission (TLS 1.3) and at rest (AES-256)
• Photos and audio are processed in real-time and not permanently stored on third-party servers
• We only work with service providers who maintain appropriate security standards

Your Consent: By using Tamhon, you explicitly consent to these cross-border data transfers as necessary for service provision. You may withdraw consent at any time by deleting your account, though this will prevent you from using the Service.

We implement comprehensive security measures:

• Encryption: TLS 1.3 for transmission, AES-256 for storage
• Access Control: Role-based access, multi-factor authentication
• Monitoring: 24/7 security monitoring and intrusion detection
• Employee Training: Regular security and privacy training
• Incident Response: Established breach notification procedures
• Regular Audits: Annual security assessments

You have the following rights regarding your personal information:

• Access Right: Request disclosure of your personal data
• Correction Right: Request correction of inaccurate data
• Deletion Right: Request deletion of unnecessary data
• Suspension Right: Request suspension of data use
• Portability: Receive your data in a structured format
• Objection: Object to certain processing activities

To exercise these rights, contact: hello@journely.me. We will respond within 30 days.

• Active Accounts: Retained while account is active
• Inactive Accounts: Deleted after 2 years of inactivity
• Legal Records: 5 years as required by Japanese commercial law
• Marketing Communications: Until opt-out + 6 months

We use minimal, essential cookies only:

• Essential Cookies: Authentication and security
• Preference Cookies: Language settings (EN/JA/VI)
• NO Third-Party Tracking: We don't use advertising or analytics cookies

Our Service is not intended for minors. The minimum age to use Tamhon is:

• Japan: 20 years old (age of majority)
• Vietnam: 18 years old (tuổi thành niên)
• Other countries: The age of majority in your jurisdiction, or 18 years, whichever is higher

We do not knowingly collect information from minors. If we discover such collection, we will immediately delete the information. If you are a parent or guardian and believe your child has provided us with personal information, please contact us at hello@journely.me.

In the event of a data breach that may harm your rights and interests:

• We will notify the Personal Information Protection Committee within 72 hours
• We will notify affected users without undue delay
• We will provide details of the breach and mitigation measures

We may update this Policy to reflect legal changes or service improvements. Material changes will be notified via email at least 30 days before taking effect. Continued use after updates constitutes acceptance.

Data Controller:

Journely LLC (Operating Tamhon)
Location: Tokyo, Japan
Email: hello@journely.me

If you are unsatisfied with our response, you may file a complaint with:

Personal Information Protection Committee
Website: www.ppc.go.jp
Phone: 03-6457-9680

Tamhon integrates with third-party services for AI processing and authentication. We do NOT:

• Store your photos or audio on third-party services permanently
• Use your data to train AI models
• Share your readings or personal information with third parties
• Sell or monetize your data in any way

Third-party services we use:

• Anthropic Claude (USA): AI processing for readings (data processed in real-time, not permanently stored)
• Supabase (USA): For secure authentication and conversation storage
• PayOS (Vietnam): For secure payment processing for Vietnamese users (we never see your card or bank details)
• PostHog: For product improvement (anonymized usage data only)

All third-party integrations are subject to their respective privacy policies and terms of service.

Theo Nghị định 13/2023/NĐ-CP về Bảo vệ Dữ liệu Cá nhân:

If you are a Vietnamese user, you have the following rights under Decree 13/2023/NĐ-CP (Nghị định về Bảo vệ Dữ liệu Cá nhân):

• Quyền được biết (Right to Know): You have the right to know what personal data we collect, how we use it, and who we share it with.
• Quyền đồng ý (Right to Consent): We will obtain your consent before collecting and processing your personal data. You may withdraw consent at any time.
• Quyền truy cập (Right to Access): You may request a copy of your personal data that we hold.
• Quyền chỉnh sửa (Right to Correction): You may request correction of inaccurate or incomplete personal data.
• Quyền xóa (Right to Deletion): You may request deletion of your personal data when it is no longer necessary for the purposes collected.
• Quyền hạn chế xử lý (Right to Restrict Processing): You may request that we limit how we use your personal data.
• Quyền phản đối (Right to Object): You may object to the processing of your personal data in certain circumstances.
• Quyền khiếu nại (Right to Complain): You may lodge a complaint with the relevant Vietnamese authorities if you believe your data rights have been violated.

Chuyển dữ liệu ra nước ngoài (Cross-Border Data Transfer Notice):

Bằng việc sử dụng Tâm Hồn, bạn đồng ý cho phép chuyển dữ liệu cá nhân của bạn ra nước ngoài (Nhật Bản và Hoa Kỳ) để cung cấp dịch vụ AI. Việc chuyển dữ liệu này là cần thiết để vận hành dịch vụ.

By using Tamhon, you consent to the transfer of your personal data outside Vietnam (to Japan and the United States) for the purpose of providing AI-powered services. This transfer is necessary for service operation.

Liên hệ về quyền dữ liệu (Data Rights Contact):

Để thực hiện các quyền trên, vui lòng liên hệ: hello@journely.me
Chúng tôi sẽ phản hồi trong vòng 30 ngày kể từ khi nhận được yêu cầu của bạn.

To exercise any of these rights, please contact: hello@journely.me
We will respond within 30 days of receiving your request.