Privacy Policy

Revised October 30, 2026, effective the same day (established October 21, 2026)

FRAME00, Inc. (“we”, “us” or “our”) sets out below how we handle users’ information in CLUBS (the “Service”). The Service includes the website (clubs.place), connections from AI tools (MCP), the daily report automation tool (CLI) and email notices. Anything not covered by this Policy follows our company-wide privacy policy.

Article 1. Information we collect

We collect the following information.

• Contact and account information: email address, display name and similar (when you sign up for notices or register an account; when you sign in with a Google or GitHub account, we receive that account’s email address)
• What users record: what the user, or an AI the user connected, sends to the Service (notes, projects, daily reports and so on)
• Information sent with inquiries and bug reports: what the user sends, along with the environment sent with it (the page being viewed, device, connected AI, errors and so on) and usage status (such as plan)
• Payment information: information used to pay for a paid plan (card numbers are received by the payment processor; we do not hold them)
• Usage information: IP address, device and browser type, access times, activity logs, records of opening links in emails from the Service (notices, daily report emails the user set up and so on), cookies and similar technologies
• Records of AI connections: the kind of AI the user connected (such as Claude or ChatGPT), and the time, type and number of operations that AI performed on the Service on the user’s instructions (including part of what was read or written, such as titles or the start of the text). When the user uses the daily report automation tool (CLI), we also collect the amount of AI work the tool sends (the hours it was active, the number of runs and failures, the first and last times and counts per model or tool used)
• Invitation records: who invited the user and through which entry point they started, and records of invitations the user sent
• Chat tool integration information: the Slack, Discord or Telegram destinations the user connected
• Answers to the 30-day impact study: if the user takes part in our study of how the time their work takes changes over their first 30 days (the “30-day impact study”), their answers to its questions (such as how much time they spend explaining background to AI)

If what you record includes personal information of third parties, such as business partners, record only what is necessary.

Article 2. Purposes of use

We use the information we collect for the following purposes.

1. Providing and running the Service (storing and organizing records left by users or the AI they connected, creating and sending daily report emails, periodic reports and work reports based on them, and responding to reads and writes from connected AI)
2. Confirming registration and sign-in, and verifying identity
3. Getting-started guidance and notices such as the launch of the Service
4. Notices of new features, updates and campaigns (you can stop these at any time; see Article 8)
5. Responding to inquiries, including those sent through “Help”
6. Investigating bugs, operating safely and responding to misuse or violations of the Terms of Service
7. Billing, and managing trials and invitation rewards
8. Analysis to improve the Service (results are used in aggregate)
9. Running the 30-day impact study and publishing its results (we publish only figures aggregated so that no individual can be identified; we do not publish per-person figures, and we do not publish results where the number of participants is so small that individuals could be identified; when we publish, we also make the number of participants, the period and the method available)
10. Sending results and thanks to people who took part in the 30-day impact study
11. Proving that records have not been altered: for some records left by users or the AI they connected (such as daily reports), we register information about them with Lemma, our proof system, so that it can be verified they have not been altered. What we register is not the body of the record but a value calculated from it (a hash) and the minimum information needed for verification (the user’s identifier, the date, the AI’s name, the number of work runs, the hours of activity and so on)
12. Featuring testimonials and case studies: before featuring anything, we tell you what will be shown and where, and ask for your consent. You can withdraw consent at any time, and after you do, we remove it from places we manage. Materials already handed out or published in other media may not be retrievable. We never use answers to the 30-day impact study in features without consent

When we change the purposes of use, we do so within a scope reasonably related to the original purposes and notify or announce it on the Service. Beyond that scope, we ask for your consent in advance, except where permitted by law.

Article 3. Relationship with AI

An AI the user connected (such as Claude or ChatGPT) reads and writes records on the Service on the user’s instructions. Information passed to the AI is handled under that AI provider’s terms and privacy policy, and we are not involved in how it is handled.

We do not use user records to train AI models, and we do not provide them to third parties for training.

The Service itself does not send records to external AI services to summarize them or make suggestions.

Article 4. Provision to third parties

We do not provide personal data to third parties without the user’s consent, except in the following cases.

• When required or permitted by laws and regulations
• When necessary to protect a person’s life, body or property and it is difficult to obtain the user’s consent
• When especially necessary to improve public health or promote the healthy development of children and it is difficult to obtain the user’s consent
• When we need to cooperate with a national or local government body carrying out duties set by law, and obtaining the user’s consent could interfere with those duties

The following do not count as provision to third parties.

• Entrusting handling to the service providers in Article 5, to the extent needed for the purposes of use
• Provision as part of a business succession such as a merger
• Sharing the user does themselves: with club members, with people they give a share link to, with an AI they connected and by sending to chat tools they connected (Slack, Discord or Telegram)

Article 5. Entrusting handling

We may entrust the handling of personal data to outside companies to the extent needed to run the Service (data storage, sending email, payments and so on). We sign confidentiality and security agreements with these service providers (including each company’s terms of use and data processing agreements) and supervise them as needed, such as by reviewing third-party audit reports.

Article 6. Service providers outside Japan

Our service providers include companies in the United States. We require them by contract to take measures equivalent to those required under Japan’s Act on the Protection of Personal Information (APPI). Information on each country’s personal information protection system is available in surveys published by Japan’s Personal Information Protection Commission. On request, we will tell you the outline of the measures our service providers take and how we check them.

Article 7. Security measures

We take the following measures to prevent personal data from being leaked, lost or damaged.

• Organizational measures: we appoint a person responsible for handling personal data and set rules for handling.
• Personnel measures: we require officers and staff to keep information confidential and train them regularly.
• Physical measures: we prevent loss and theft of devices used for work and use measures such as screen locks.
• Technical measures: we encrypt communications and limit who can access data to those who need it. Users can revoke AI connection permission at any time.
• Understanding the external environment: for service providers in other countries, we take measures after understanding each country’s personal information protection system.
• Responding to leaks: if a leak or similar incident involving personal data occurs and the law requires it, we report it to the Personal Information Protection Commission and notify the affected users.

Article 8. Retention and deletion

• When you delete your account: within 30 days of your request through “Request account deletion” in Settings or by contacting us (Article 12), we delete your records and account information (except the “payment records” and “record of free trial use” below). Comments and other items you wrote in a club remain as club records, shown under the name “Former member”. The club’s member list keeps only the fact that you left and the date.
• Payment records: records of payments for paid plans (the plan and the period during which it could be used) are kept after you close your account for the period required by tax and accounting laws (7 years as a rule), and are also used to answer inquiries about refunds and billing. These records do not include your name or email address.
• Record of free trial use: after an account is deleted, we keep only whether the free trial was used and the deletion date, so that someone who signs in the same way does not receive the free trial again. This record does not include your name or email address.
• Notice sign-ups: you can stop these with the unsubscribe link in the notice emails. When you stop them, we delete the sign-up. You can also stop them by contacting us (Article 12).
• Information sent through “Help”: deleted about 1 year after we finish responding.
• Answers to the 30-day impact study: deleted within 60 days after your own 30-day study ends; we keep only monthly counts of people per answer. If you stop taking part partway through, we promptly delete your answers and remove them from these counts (records left on the Service by users or the AI they connected are not covered by this deletion). If you want your answers deleted after the study ends, please contact us (Article 12).
• Testimonials and case studies: removed from places we manage when you withdraw consent or when we stop featuring them.
• Excerpts of content in AI connection records: deleted after 60 days. Records left on the Service by users or the AI they connected (notes, projects, daily reports and so on) are handled as described for those records.
• Values registered with Lemma: by design, these cannot be deleted. It is not normally possible to recover the body of a record from a hash alone. When you delete your account, we delete the information that links your user identifier to you, so after that you can no longer be identified from the registered values.
• Anything else that the law requires us to keep is kept for the required period.
• Deleted data remains for a certain period in backups kept in case of outages, and is then erased.

Article 9. Requests for disclosure, correction, suspension of use and more

Users may request the following regarding their own personal data held by us. Please contact us (Article 12). We will respond without delay after confirming your identity.

• Notification of the purposes of use, and disclosure (including in electronic form)
• Correction, addition or deletion of the contents
• Suspension of use or erasure, and stopping provision to third parties
• Disclosure of records of provision to third parties

You can check and correct most account information and records on the Service’s screens. A fee of 1,000 yen per request applies to notification of the purposes of use and disclosure (including actual costs of research and mailing). There is no fee for requests for correction, deletion, suspension of use and the like.

Article 10. Cookies and analytics

The Service uses cookies and similar technologies to keep you signed in, remember settings and analyze usage. Some pages of the Service (such as marketing pages and club sites) include analytics tools from the following companies, and opening those pages sends information from your device to those companies.

• Google Analytics (Google LLC): pages viewed, access times, device and browser type, cookie IDs (used to tell devices apart) and so on, to analyze usage. How to opt out
• Microsoft Clarity (Microsoft Corporation): pages viewed, on-screen actions such as clicks and scrolling, what was shown on the screen at the time (session recordings), device and browser type, cookie IDs (used to tell devices apart) and so on, to analyze how screens are used. We have set it up so that records, member names and other content users left on the Service are not included in session recordings. For how information is handled, see the Microsoft Privacy Statement.

You can turn off cookies in your browser settings, but parts of the Service may then stop working.

Article 11. Changes to this Policy

When we change this Policy, we will announce the changes and the date they take effect on the Service. For changes that significantly affect users’ rights, we will also notify you by email before they take effect.

Article 12. Company and contact

FRAME00, Inc.
3-5-7 Ebisu-Minami, Shibuya-ku, Tokyo 150-0022, Japan
Representative Director: Mayumi Hara
Contact: contact@frame00.com

Article 13. Language

This Policy is available in Japanese and English. If the Japanese and English versions differ, the Japanese version prevails.

Revised October 30, 2026, effective the same day (established October 21, 2026)