Final Revision: July 20, 2023
NAVITIME JAPAN Co., Ltd.
NAVITIME JAPAN Co., Ltd. (hereinafter known as the 'Company') adheres to the rules stipulated below (hereinafter known as 'these Rules') when handling Personal Data acquired by the Company pertaining to the provision of 'Japan Travel by NAVITIME' (hereinafter known as the 'Service') as offered by the Company. Moreover, with respect to these Rules, in the event there is any discrepancy between the English version and the version translated into other languages, the English version shall supersede.
In these Rules:
'Data Protection Laws' means, in relation to a user, all applicable laws, rules, regulation, directives and governmental requirements relating in any way to the privacy, confidentiality, security, integrity and protection of Personal Data, including without limitation: the Data Protection Act 2018; the UK General Data Protection Regulation ('UK GDPR'); the EU General Data Protection Regulation 2016/679 ('EU GDPR'), the EU ePrivacy Directive 2002/58/EC, each as amended or superseded from time to time, and any EU Member State national implementing legislation; and the Act on the Protection of Personal Information in Japan ('PPI').
'Personal Data' means any data relating to an identified or identifiable person, such as name, addresses, email addresses, telephone numbers and dates of birth.
'process' or 'processing' or 'processed' means any operation performed upon Personal Data, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction;
'user' means any individual that uses the Service and is the subject of Personal Data that is processed by the Company.
The Company shall acquire the Personal Data listed below (hereinafter collectively known as 'Acquired Information') through the provision of this Service.
The Company shall handle the Acquired Information in accordance with the “Personal Information Protection Policy” separately established by the Company and Paragraphs (1) – (4) of this Section 3 (Handling of Acquired Information).
The Company will use Acquired Information for the following purposes:
If the Company intends to use the Acquired Information for a purpose other than those listed above, it will provide the user with information on that purpose and if necessary under applicable Data Protection Laws, obtain consent.
The Acquired Information will be stored for no longer than necessary for the fulfilment of the purposes listed above and may be stored for longer periods insofar as Acquired Information will be processed for statistical purposes.
In principle, the Company shall not provide the user's Acquired Information to third parties. The Company will only provide Acquired Information to third parties in the following circumstances:
Additionally, the user agrees by accepting the Terms of Use and Privacy Policy that the user's Acquired Information will be handled by the Company within the applicable scope of the laws of Japan, applicable Data Protection Laws and these Rules. Additionally, the user understands and consents to the possibility that the extent of protection of their Acquired Information through the laws of Japan and these Rules may be less effective than the laws of the user's country and that there may be limitations on the rights set out in this Privacy Policy, depending on the specific circumstances concerning the data subject’s data and applicable law.
The Company may transfer or outsource the handling of, in part or in whole, the Acquired Information to a provider. However, such outsourcing of the Acquired Information shall be undertaken only within the scope necessary to accomplish the purpose of use provided for in Section 3 (Handling of Acquired Information) and the Company shall ensure that appropriate safeguards are in place to ensure an adequate level of protection for the user and that applicable Data Protection Laws are complied with.
For EU/EEA/UK Personal Data, please note that the European Commission has issued a decision and the Information Commissioner's Office has issued adequacy regulations which state that Japan has an adequate level of protection for transfers of EU/EEA Personal Data and UK Personal Data respectively and the Company may therefore transfer Acquired Information from the UK/EU/EEA to Japan without additional safeguards, other than those the Company already imposes to protect Acquired Information.
The Company uses the following information collection modules to analyze access and use conditions of this Service. These information collection modules collect information regarding the use of this Service in a way that it does not identify a specific individual, and the collected information will not be used to identify the user.
Provided by: Google LLC
Privacy Policy of Google LLC
(https://policies.google.com/privacy?hl=en)
Provided by: Google LLC
Privacy Policy of Google LLC
(https://policies.google.com/privacy?hl=en)
Provided by adjust GmbH, adjust Inc. and adjust KK
Privacy Policy of adjust GmbH, adjust Inc. and adjust KK
(https://www.adjust.com/privacy-policy/)
Provided by: Blogwatcher Inc.
The user may refuse the information to be collected by Profile Passport
SDK by changing the setting of this Service.
Provided by:Treasure Data, Inc.
Privacy Policy of Treasure Data, Inc.
(https://www.treasuredata.com/privacy/)
Provided by:Switch Smile, Inc.
Privacy Policy of Switch Smile, Inc.
(https://switch-smile.com/privacy-policy)
Advertisements are displayed using GPS Beacon information acquired using the Bluetooth function on the
devices of our customers. By altering the settings of the Bluetooth function on their devices, customers
can stop pinable from gathering this information.
The Company uses iOS advertising identifier ‘Identification for Advertisers’ (IDFA) (hereinafter known as 'IDFA') to display behavior targeting advertisements. IDFA will never be used to identify the user.
The user may refuse the use of IDFA to display behavior targeting advertisements. In order to refuse such use, follow the procedure below.
On the user's device: 'Settings' → 'Privacy' → 'Ads' → activate 'Restrict Tracking Ads'
*This operation may not be available or may differ depending on the OS versions of the user's device.
The Company uses the Android OS advertising identifier ‘Google advertising ID’ (hereinafter known as 'Google advertising ID') to display behavior targeting advertisements. Google advertising ID will never be used to identify the user.
The user may refuse the use of Google advertising ID to display behavior targeting advertisements. In order to refuse such use, follow the procedure below.
On the user's device: 'Google Settings' → 'Ads' → place a check in 'Opt Out of Interest Base Ads'; or
On the user's device: 'Settings' → 'Google' → 'Ads' → place a check in 'Opt Out of Interest Base
Ads'
*This operation may not be available or may differ depending on the OS versions of the user's device.
Users who are minors under the age of 13 cannot use this Service. If you believe that the Company is retaining information of a minor below the age of 13, please contact the Personal Information Protection Desk indicated in Section 13 (Inquiries Regarding Acquired Information).
Please note that there may be limitations on the rights set out in this Privacy Policy, depending on the specific circumstances concerning the data subject’s data and applicable laws.
Regarding the handling of Acquired Information, the Company sets forth company regulations based on the laws and guidelines stipulated by the Japanese government and compliant with applicable Data Protection Laws, makes these rules well-known among its employees, and takes safe management/preventative measures.
Should the user discontinue the use of this Service, the Acquired Information provided by the user will be appropriately deleted/destroyed based on the regulations of the Company.
In addition, should the user wish to have the Acquired Information they provided to the Company updated, the Company will make efforts to promptly respond to such request. However, the Company may refuse to respond to a request if it has been repeatedly made without justifiable cause, or the request requires excessive technological burden (such as the deletion of the data from the backed-up data).
The Company would welcome the opportunity to handle a user's complaint, which may be submitted via the contact details in Section 13 (Inquiries Regarding Acquired Information).
In relation to Japanese data protection issues, the name of the Company's authorized person-related information protection organization and the contact point for filing complaints is listed below.
Japan Information Processing Development Center (JIPDEC)
Personal Information Protection Complaints Desk
Address
12F Roppongi First Bldg., 1-9-9 Roppongi, Minato-ku, Tokyo 106-0032
Inquiry Form
https://contact.jipdec.or.jp/m?f=245
*Please be noted that the above inquiry form is not for inquiries regarding the products and services of the Company.
In relation to UK data protection issues, please contact the Information Commissioner's Office ('ICO'), the UK Supervisory Authority for data protection issues, using the contact details provided on the ICO’s website at https://www.ico.org.uk
For a list of European Supervisory Authorities, please see https://edpb.europa.eu/about-edpb/about-edpb/members_en
These Rules are subject to revision at the discretion of the Company for reasons such as to respond to the law or government guidelines etc. Such revisions shall become valid at the time the revised Rules have been posted on this website. However, should there be a major revision that will have a significant impact on the users, a reasonable notification period will be set in advance, users will be notified in an easy-to-understand way through this Service, and the revised Rules will be posted to this website. In such case, after the notification period has passed, the revised Rules shall be considered valid.
User inquiries regarding Acquired Information are handled at the Personal Information Protection Desk provided below.
Inquiries to:
Personal Information Protection Desk
NAVITIME JAPAN Co., Ltd.
3-8-38 Minami Aoyama, Minato-ku, Tokyo 107-0062
Personal Information Protection Manager:
Compliance Manager, Intellectual Property Legal Department
e-mail:
japantravel-privacy@navitime.co.jp