Privacy Policy

Effective 2026-08-18

This privacy policy applies to the First35 app for mobile devices, together with any related services operated by NEX HOLDINGS (collectively, the "Application"). NEX HOLDINGS is hereby referred to as the "Service Provider".

Information Collection and Use

The Application collects information when you download and use it. This information may include:

• Your device's Internet Protocol address
• The pages of the Application that you visit, the time and date of your visit, the time spent on those pages
• The time spent on the Application
• Your mobile operating system
• Text you enter when creating a self-introduction, including the context, audience, goal, and similar prompts you provide during onboarding and in the intro editor
• Voice recordings you make while practicing your self-introduction
• Audio measurements derived from those recordings, including pitch, volume, pause pattern, and timing
• Transcriptions of your practice recordings
• Practice history and progress trends, such as scores over time, streaks, and per-metric progress

Voice recordings, derived audio measurements, transcriptions, and practice trends are used to power the coaching features described under "Artificial Intelligence" below.

Cookies and Tracking Technologies

The Application or its third-party SDKs may use cookies, SDKs, pixels, and similar technologies to support functionality, analytics, or service delivery. Where required by applicable law, the Service Provider will obtain consent before using non-essential tracking technologies.

Your Rights

You may request access to, correction of, or deletion of your personal data held by the Service Provider. To exercise these rights, or to withdraw consent where processing is based on consent, contact the Service Provider at support [at] nex.tokyo.

Your California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have the right to know what personal information is collected, the right to delete personal information, the right to opt out of the sale or sharing of personal information, and the right to non-discrimination for exercising these rights. To exercise your CCPA/CPRA rights, contact the Service Provider at support [at] nex.tokyo.

Artificial Intelligence

The Application uses two Artificial Intelligence (AI) components to provide its core features. Both are operated through the Service Provider's servers, with data forwarded to third-party AI model providers for processing under contractual terms described below.

Intro generation. When you complete the onboarding questionnaire or edit an existing intro, the Service Provider sends your typed answers (context, audience, goal, and related prompts) to a third-party AI model, which returns tailored self-introduction variants. Voice recordings are not sent at this stage.

Delivery coaching. After each practice recording, the Service Provider sends the following to a third-party voice AI model for coaching feedback: your voice recording, the audio measurements derived on your device (pitch, volume, pause pattern, timing), a transcription of what you said, and your practice trends for the intro being practiced. The AI returns short personalized coaching text about your pace, pauses, expressiveness, and overall delivery. The Service Provider does not use your voice recordings to train external AI models, and requires third-party AI providers under contract not to use your recordings to train their own models.

You can delete your voice recordings and associated data at any time from the Application's Settings screen. All AI processing is performed in accordance with this privacy policy and applicable laws. If you have questions about the AI features or data processing, please contact the Service Provider.

The Service Provider may use the information you provide to send important information, required notices, and, where permitted by law, marketing communications.

For a better experience while using the Application, the Service Provider may require you to provide certain personally identifiable information, including but not limited to UserID and age group. The information the Service Provider requests will be retained and used as described in this privacy policy.

Third Party Access

Aggregated, anonymized analytics data is periodically transmitted to external services to aid the Service Provider in improving the Application and their service. In addition, your voice recordings, derived audio measurements, transcriptions, and practice trends are transmitted to third-party AI model providers for the purpose of generating coaching feedback and self-introduction drafts, as described under "Artificial Intelligence" above. These providers process the data under contractual terms that prohibit them from using it to train their own models. The Service Provider may also share your information with third parties in the ways described in this privacy statement.

International Data Transfers

The Service Provider or its third-party service providers may transfer personal data to countries outside your country of residence, including outside the European Economic Area (EEA). Where applicable law requires safeguards for international transfers, the Service Provider will use appropriate mechanisms.

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Adequacy decisions or other legally recognized transfer mechanisms
• Your consent, where required and legally permitted

Data protection laws in other countries may differ from those in your jurisdiction. Where required by law, the Service Provider will apply appropriate safeguards and obtain any consent required for the transfer.

The Service Provider may disclose User Provided and Automatically Collected Information:

• as required by law, such as to comply with a subpoena, or similar legal process;
• when they believe in good faith that disclosure is necessary to protect their rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
• with their trusted services providers who work on their behalf, do not have an independent use of the information the Service Provider discloses to them, and have agreed to adhere to the rules set forth in this privacy statement.

Opt-Out Rights

You can stop further collection of information from your mobile device by uninstalling the Application. Uninstalling will stop the Application from collecting data from your device, but it does not automatically delete information that has already been transmitted to the Service Provider or to third parties.

To request deletion of your personal data, to withdraw consent, or to exercise any of your rights, contact the Service Provider at support [at] nex.tokyo.

Data Retention Policy

The Service Provider retains personal data based on its necessity for the stated purposes:

• User Provided Data, including intros, voice recordings, derived audio measurements, and transcriptions: Retained for the duration of your use of the Application plus 12 months thereafter, unless longer retention is required by law
• Automatically Collected Data: Retained for up to 24 months from collection, unless longer retention is required for legal compliance
• Aggregated and Anonymized Data: Retained indefinitely as it no longer identifies you
• Data required for legal compliance: Retained as long as required by applicable law

You may delete individual voice recordings from the Application's Settings screen at any time. To request bulk deletion of your personal data, subject to any legal obligation to retain it, please contact the Service Provider at support [at] nex.tokyo. Please note that some User Provided Data may be required for the Application to function properly.

Children

The Application is not intended for children under 16 years of age, or such higher age as required by applicable law. The Service Provider does not knowingly solicit data from children or market the Application to them.

The Service Provider does not knowingly collect personally identifiable information from children. The Service Provider encourages all children to never submit any personally identifiable information through the Application and/or Services. The Service Provider encourages parents and legal guardians to monitor their children's Internet usage and to help enforce this Policy by instructing their children never to provide personally identifiable information through the Application and/or Services without their permission. If you have reason to believe that a child has provided personally identifiable information to the Service Provider through the Application and/or Services, please contact the Service Provider at support [at] nex.tokyo so that they will be able to take the necessary actions. If you are under 16 years of age, your parent or guardian must provide consent on your behalf where permitted by law.

Security

The Service Provider is concerned about safeguarding the confidentiality of your information. The Service Provider provides physical, electronic, and procedural safeguards to protect information the Service Provider processes and maintains.

Data Breach Notification

If a data breach occurs that affects your personal data, the Service Provider will notify you in accordance with applicable legal requirements, including, where required, providing information about the nature of the breach and the steps being taken to address it.

Changes

The Service Provider may update this Privacy Policy from time to time. The Service Provider will notify you of material changes by posting the updated Privacy Policy with an effective date. Where required by law, the Service Provider will seek your consent to material changes before they take effect.

Previous versions of this Privacy Policy will be maintained and made available upon request by contacting the Service Provider at support [at] nex.tokyo.

Your Consent

Where processing is based on consent, you provide that consent by affirmatively opting in to the relevant feature or action. You may withdraw consent at any time without affecting processing carried out before withdrawal. Processing based on other lawful bases is carried out as described above.

Contact Us

If you have any questions regarding privacy while using the Application, or have questions about the practices, please contact the Service Provider via email at support [at] nex.tokyo.