Privacy Policy

This is an English translation provided for reference. If there is any discrepancy between this English version and the Japanese version, the Japanese version prevails.

Shiba Investment LLC ("we", "us") sets out below how user information is handled in the application we provide, "Osewa Navi" (the "Services"). This application is an internal business tool used by group homes for people with disabilities in Japan. It is distributed privately and is not offered to the general public.

Scope of the Services

The Services are business tools for welfare service providers under contract with us, and for the staff of the group homes they operate. They are not offered to general consumers. An account issued by us or by the contracted provider is required to use them.

Who controls the data

We are the controller of the personal information handled in the Services.

The operation of each group home, and the contractual relationship with its residents and staff, rests with the provider operating that group home. We provide the Services to those providers and to their residents and staff.

1. Operator and Contact

2. Information We Collect

(1) Residents (people living in the group home)

• Name, login ID, email address (optional), phone number (optional)
• The group home where they live
• Profile image (a face photograph or an illustration of their choice)
• Meal orders and records of meals actually eaten
• Photographs of meals (taken by staff as a record; residents may appear in them)
• Shopping records (item, amount, purpose, payment method, date) and receipt images
• Records of the operations residents perform in Gohan Note (for details, please see the Gohan Note privacy policy)

(2) Staff (caregivers and administrators)

• Name, login ID, email address (optional), phone number (optional)
• Assigned group homes and role (caregiver / administrator)
• Profile photo or illustration
• A record of who created or modified each entry
• PIN code (when a shared device is used)
• Operation records (signing in to and out of the app; operations such as registering, changing and deleting; and details of errors that occur during operation. These include the staff member's ID, the date and time, the type of operation, and the screen or item concerned)

(3) Group homes

• Name and address of the group home

(4) Face photographs

• A registered face photograph is used solely to make the person easy to identify on screen.
• We do not generate facial feature vectors, face recognition templates, or any other biometric data from it, and we do not use it for identity verification by face recognition.
• Where device biometrics (face or fingerprint) are used, the biometric data itself is processed by the secure mechanism of the device and is never sent to or stored on our servers.

(5) Device information

• Credentials used to keep the user signed in
• Whether biometric sign-in (face or fingerprint) is enabled
  • The biometric data itself is never sent to us; it is handled entirely on the device.
• Device type (tablet or phone)
  • Used only to switch the layout. It is not transmitted to us.
• A list of contract numbers (4 digits)
  • A convenience value used to narrow the choices on the sign-in screen. It is not the basis of any permission. Before sign-in, it is sent to our server in order to narrow the list of group homes shown. It contains no information identifying an individual.

3. How We Collect It

• All information is entered or captured by the resident or by staff through the screens of the Services.
• The Services contain no components intended for advertising or for tracking users across services, and we perform no advertising or behavioural-targeting analysis of our own.
• We do not collect advertising IDs or location data. Only the device type (tablet or phone) is used, for layout purposes, and it is not transmitted to us.
• However, because the application communicates with Expo (EAS Update) to deliver updates, information about the OS and platform, an identifier used to decide whether an update applies, the IP address, and other technical information may be processed by Expo (see section 7).

4. Purposes of Use

• To manage meals in the group home (orders, meals eaten, stock, ordering)
• To record and manage shopping and related money
• To create draft shopping records from receipt images (AI reading; see section 7-2 below)
• To share handover notes and work records among staff
• To verify identity and sign users in
• To respond to enquiries and send important notices
• To maintain the Services, fix defects, and improve quality
• To investigate the causes of defects and failures, to prevent and detect improper operations, and to check how the Services are being operated (operation records)

We do not use the information collected for any purpose other than those listed above.

5. Special Care-Required Personal Information

The Services handle information relating to the provision of welfare services for people with disabilities. This may include information that constitutes "special care-required personal information" under the Act on the Protection of Personal Information of Japan.

• Except where the law does not require consent, we obtain such information only after confirming the consent of the individual.
• Where the individual has difficulty making that decision, we obtain or confirm the necessary consent from a person with parental authority, a statutory representative, an adult guardian, or another lawfully authorised representative.
• We do not provide such information to third parties under the opt-out method.
• Where provision to a third party becomes necessary, we obtain the individual's consent on each occasion, except where required by law.

6. Provision to Third Parties

We do not provide collected information to third parties, except in the following cases.

• Where the individual has consented
• Where required by law
• Where necessary to protect a person's life, body, or property and it is difficult to obtain the individual's consent
  • For example, passing necessary information to a medical institution when a resident's condition changes suddenly.

We do not sell or rent the information we collect, and we do not provide it to third parties for their advertising or marketing purposes.

Where we entrust the handling of personal data to a subcontractor, we select that subcontractor carefully and, by contract and other measures, exercise the necessary and appropriate supervision to ensure a level of protection equal to or higher than that required by this policy and by applicable law.

7. Subcontractors (External Services)

We exercise necessary and appropriate supervision over our subcontractors.

Push notifications are not used.

7-2. AI Reading of Receipts (Kaimono Note)

The Kaimono Note feature of the Services can have receipt photographs read by an AI to create draft shopping records. The following applies to this feature.

(1) Information sent externally

• Only two things are passed to the external AI: the receipt image and a fixed reading instruction defined by us.
• The names of residents and staff, login IDs, the name and address of the group home, and any other information relating to an individual are never passed.

(2) Subcontractor and handling by the subcontractor

• Reading is entrusted to the AI model "Claude Sonnet 5" provided by Anthropic.
• We exercise the necessary and appropriate supervision over the subcontractor, by contract and other measures, to ensure a level of protection equal to or higher than that required by this policy and by applicable law.
• Retention: the subcontractor automatically deletes the received image and the reading result within 30 days of receipt or creation. There are two exceptions, under which data may be retained for up to two years: (a) where retention is required by law, and (b) where the data has been flagged by the subcontractor's automated checks as violating its usage policies.
• Use for AI training: the subcontractor does not use retained data to train its AI models without explicit permission. We have not given that permission. Therefore the images and reading results we send are not used to train the subcontractor's AI.
• Processing location: not limited to any particular country or region. The subcontractor's system processes the data wherever is most suitable. Processing is not necessarily carried out in Japan.

(3) How the image is passed

• We do not transmit the image itself. We pass the subcontractor a temporary URL valid for five minutes only, and the subcontractor retrieves the image from that URL. The image cannot be retrieved once the URL has expired.

(4) Storage on our side

• Our AI-calling mechanism stores neither the image nor the reading result.
• The receipt image remains in our storage as an image attached to the shopping record (it is not deleted automatically; deleting the shopping record deletes the image, and the older version that remains after deletion is removed after 90 days).
• The text read by the AI (shop name, item, date, amount, and so on) is kept in our records for the purpose of checking the accuracy of the reading.
• The retention of these items follows "11. Retention Period" of this policy.

(5) Separation by contract

• Reading records are stored completely separately for each contracted provider. Records of one contracted provider are never used for reading on behalf of another.

(6) Status of the reading result

• What the AI produces is a draft. It does not become an official shopping record until a caregiver has checked each item and confirmed it.
• The feature is optional; records can still be entered by hand as before.

(7) No use by us for AI training

• We do not use profile photographs, meal photographs, receipt images, or any other personal information registered in the Services to train our own AI models, for advertising analysis, or for profiling users, and we do not provide such information to third parties for those purposes.

(8) Consent

• Before offering this feature, we set out in this policy the data concerned, the purpose, the external transfer, and the storage, and obtain consent again.

8. Device Permissions

The Services use the following device features. Permission is requested when the feature is needed; if permission is not granted, only that feature becomes unavailable.

A microphone (recording) permission may appear in the Android system settings, but the Services do not use any recording feature. No microphone permission is requested on iOS.

9. Exporting and Sharing Reports

• The Services can export shopping and meal records as PDF, CSV, or Excel files.
• Exported files contain resident names and the details of purchases.
• Exported files can be sent to email or cloud storage using the device's share function. Once sent, handling of the file is outside our control. Please use this feature only as far as necessary for the work.

10. Security Measures

• Communication between the application and the servers we operate uses HTTPS/TLS encryption.
• The database is placed in a network segment that cannot be reached directly from the internet.
• Permissions are separated per staff member; information about group homes other than those assigned is not displayed.
• Sign-in for staff who have left, and for residents who have moved out, is disabled promptly.
• On shared devices (one device used by several staff members), sign-in credentials are not stored on the device. Credentials are cleared when the application is closed, so no information of the previous user remains for the next one.
• PIN codes are stored on the server in a form that cannot be reversed (a one-way hash). They are not stored on the device.
• Photographs are transferred using short-lived temporary URLs, including when receipt reading is entrusted to the AI subcontractor.

11. Retention Period

• We retain collected information for five years from the day use of the Services ends (moving out, leaving employment, and so on).
• Information past the retention period is promptly deleted or anonymised.
• Where a longer retention period is required by law, that period applies.
• Where an individual (or a family member or other representative) requests deletion, we delete the information promptly, except where retention is required by law. The same applies to profile photographs.
• Operation records: retained for about three years from the time they are collected and then deleted automatically. Only our system administrators can view them.

12. Disclosure, Correction, and Suspension of Use

Where an individual (or a family member or other representative) requests disclosure, correction, addition, deletion, suspension of use, or suspension of provision to third parties of retained personal data, we respond promptly in accordance with the law.

• Contact: support@shiba-invest.jp
• We explain the process in a way that is easy for the individual to understand. Where the individual has difficulty doing so, a lawfully authorised representative may act on their behalf.

Withdrawing consent

• Where we handle personal information on the basis of consent, the individual may withdraw that consent for the future. The contact is the same as above.
• To prevent impersonation, we respond only after reasonably confirming that the request comes from the individual or a lawfully authorised representative.
• Withdrawing consent, or deleting part of the data, may make some features of the Services unavailable. We explain the effect in advance.
• Where information cannot be deleted immediately because of a legal retention obligation or another legitimate reason, we explain the reason and the period, and do not use it beyond the necessary period.

13. Changes to This Policy

• This policy may be revised in response to changes in the law or in the Services.
• Where a significant change is made, we notify users within the application and obtain consent again.
• The revised policy applies from the time it is published on this page.

14. Notes on This Application

Osewa Navi (for caregivers and administrators)

• Used by caregivers and administrators of the group home.
• Staff handle resident information for work purposes. A staff member can view only the residents of the group homes they are assigned to.
• The creator and modifier of each record are stored, to keep the records accurate.
• Four kinds of images are handled: staff profile photos, resident profile photos, meal photos, and receipt images.
• In Kaimono Note, receipt images can be read by an AI to create draft shopping records (see section 7-2).
• It can be used on a shared device (tablet). In that case a PIN confirms the individual and sign-in credentials are not left on the device.

15. Cookies

• This privacy policy web page does not use cookies for advertising, behavioural targeting, or analytics by us.

16. History

• Established: 7 August 2026
• Revised: 8 August 2026
• Revised: 30 August 2026
• Last revised: 6 October 2026