1. A non-volatile semiconductor storage device comprising: a first non-volatile memory cell provided on a first insulator above a substrate; and a second non-volatile memory cell provided on a second insulator above the first non-volatile memory cell, wherein the first non-volatile memory cell includes: a first semiconductor layer including an n-type region and a p-type region; and a first gate stack which is provided above the first semiconductor layer and includes a first charge storage layer and a first control gate electrode, the second non-volatile memory cell includes: a second semiconductor layer including an n-type region and a p-type region; and a second gate stack which is provided above the second semiconductor layer and includes a second charge storage layer and a second control gate electrode, the second gate stack being positioned to be aligned with the first gate stack, and wherein the first control gate electrode functions as a back gate electrode with respect to the second non-volatile memory cell.