Privacy Policy

Privacy Policy – Iroha Passport

Last updated: August 2026

1. Data Controller

Iroha Passport, operated by Risako Okisugi
Location: Japan
Contact: info@irohapassport.co.uk

2. Information We Collect

We collect the following information when you use our website or services:

• Your email address, when you sign up for our Free Plan, subscribe to our newsletter, or submit an enquiry form
• Your name and contact details, when you book a trial lesson, private lesson, or other service through our booking forms
• Payment information, when you make a purchase (processed securely by our payment provider — see Section 12)
• Usage data collected automatically through analytics tools, such as pages visited and general browsing behaviour (see Section 12)

3. Information We Collect from Teachers

If you work with us as a teacher, we collect your name, address, bank account details, National Insurance number and signature. This information is used solely to administer your contract, process payments and meet our accounting and tax obligations. Access is limited to the business owner. This information is never shared with students or used for any other purpose.

4. Job Applicants

When you apply to teach with us, we collect the information you provide in the application form, together with interview notes and the results of any level check. This information is used only to assess your application. Application information may be processed using AI tools to help organise and review applications, as described under AI-assisted processing. Final decisions are always made by a human.

5. How We Use Your Information

We use the information you provide to:

• Deliver the content, plans, or services you have requested
• Send you our newsletter and occasional updates about our services
• Process bookings and payments for lessons and other services
• Respond to enquiries you send us directly
• Understand how visitors use our website, so we can improve it

AI-assisted processing

We may use AI tools to help process information submitted to us — for example, to organise and review teacher applications, respond to enquiries, or prepare travel planning and lesson support materials. AI tools are used to assist our work only; final decisions and communications are reviewed by a human. Information is not used for any purpose beyond the service or process for which it was submitted, and is not used to train AI models.

6. Legal Basis for Processing

We process your personal information on the following bases:

• Performance of a contract: to deliver lessons, travel planning and other services you have booked.
• Consent: for marketing emails, publication of student testimonials, and use of lesson recordings for teacher training.
• Legitimate interests: to review teacher applications, improve our services, and maintain business records.
• Legal obligation: to meet accounting and tax record-keeping requirements.

7. Lesson Records

We keep records of your lessons, including your level, learning goals and progress notes, so that we can provide consistent teaching. If your teacher changes, these records are passed to your new teacher.

8. Student Feedback

We ask for feedback after every ten lessons and at the end of each package. Feedback is used to improve our service and forms part of how we review our teachers’ performance.

9. Lesson Recordings

With your consent, lessons may be recorded. Recordings may be used to train our teachers. Where recordings are shared for training purposes, they are edited so that students cannot be identified — faces and names are removed. You may withdraw your consent to recording at any time.

10. Testimonials and Reviews

With your consent, we may publish your first name and comments on our website or social media. You may ask us to remove your testimonial at any time by contacting info@irohapassport.co.uk. We may also invite you to leave a review on Google; any review you leave there is governed by Google’s own terms.

11. Children

Where a student is under 18, we require consent from a parent or guardian before lessons begin, and all communication about the lessons is conducted with the parent or guardian.

12. Third-Party Services

We use trusted third-party services to operate our business. These include:

• Stripe — payment processing
• MailPoet — email newsletters
• SureForms — website forms
• Google Analytics — website analytics

In addition, we use third-party services for website hosting, file storage and email, internal record-keeping, video lessons, and AI-assisted processing as described above. These providers process information only as needed to deliver our services, in accordance with their own privacy policies. Some of these providers are based outside the UK, including in the United States and Japan.

We do not sell your personal information. We may share limited information with our teachers, who work with us under contract and are bound by confidentiality obligations, only to the extent necessary to deliver lessons (for example, your level, learning goals and lesson history).

13. International Transfers

Iroha Passport is operated from Japan. Information you provide is therefore transferred outside the UK. Some of our service providers, including AI tools and cloud services, process data in the United States and other countries. Where information is transferred outside the UK, we take steps to ensure it remains protected in line with UK data protection standards.

14. How We Protect Your Information

Access to personal information is limited to those who need it to deliver our services. We use two-factor authentication on our business accounts, and information is stored in access-controlled cloud services.

15. Data Breaches

If a data breach occurs that is likely to affect your rights, we will notify the Information Commissioner’s Office within 72 hours and inform you without undue delay.

16. Data Retention

We retain personal information only as long as necessary for the purposes described in this policy:

• Teacher contracts, payment details and tax-related records: 7 years after the end of the contract, in line with accounting and tax record-keeping requirements.
• Student contact details and lesson records: 3 years after the final lesson.
• Payment records: 7 years, in line with accounting requirements.
• Unsuccessful job applicants: 1 year after the recruitment process ends, so that we may contact them about future opportunities.
• Newsletter subscribers: deleted within 30 days of unsubscribing.

Where we are required by law to retain information for longer, we will do so.

17. Your Rights

You have the right to:

• access the personal information we hold about you;
• request correction of inaccurate information;
• request deletion of your information;
• restrict or object to how we process your information;
• request a copy of your data in a portable format;
• withdraw consent at any time, where processing is based on consent;
• unsubscribe from marketing emails at any time.

To exercise any of these rights, contact us at info@irohapassport.co.uk.

If you are in the UK and are not satisfied with our response, you have the right to complain to the Information Commissioner’s Office (ICO) at ico.org.uk.

18. Cookies

Our website may use cookies through Google Analytics to help us understand how visitors use our site. You can control or disable cookies through your browser settings at any time.

19. Contact Us

If you have any questions about this Privacy Policy or how we handle your data, please contact us at info@irohapassport.co.uk.