Our Philosophy regarding Personal Information Protection
In utilizing personal information, which is essential in order to pursue our business activities, we the Gurunavi Group (the "Company Group") fully recognize the importance of and our social responsibility for appropriately protecting such personal information, and we will comply with the Act on the Protection of Personal Information and other relevant laws and ordinances. In addition, we have established a "Personal Information Protection Management System", internal company rules that ensure confidentiality and appropriate handling of personal information. All employees comply with the system in accordance with personal information protection policies.
Personal Information Protection Policy
1. Handling of Personal Information
We will handle personal information in a legal and fair manner, taking into account the content and size of our business. We will indicate to you the purpose of utilization and will not use any personal information for any purpose other than the purpose indicated to you.
2. Compliance with Laws, Ordinances, and Standards
We will comply with the laws, ordinances, policies, and other standards, customs and social rules in Japan and any other countries and regions.
3. Appropriate Measures for Personal Information Management
We will take organizational, human, physical and technical measures to securely manage personal information, endeavoring to prevent the leakage, destruction, damage, loss, falsification, or illegal access of personal information. We will constantly seek to improve in this area.
Organizational measures to securely manage personal information:
We have appointed a supervisor for the handling of personal information, clarified the employees handling personal information and the scope of personal information handled by those employees, and established a system for reporting and contacting the supervisor in accordance with laws, regulations and internal rules in the event a violation or an indication thereof is found.
Human measures to securely manage personal information:
We conduct education of employees on the protection of personal information to provide awareness of the importance of handling personal information.
We also ensure employees comply with matters related to maintaining the confidentiality of personal information by stating these in internal rules and the written pledge made when joining the company.
Physical measures to securely manage personal information:
We implement access control for employees in areas where personal information is handled.
We take measures to prevent the theft or loss, etc. of equipment, electronic media and documents, etc. used to handle personal information.
Technical measures to securely manage personal information:
We implement appropriate access controls to limit the scope of databases, etc. handling personal information.
Information systems handling personal information are equipped with systems protecting them from unauthorized access and unauthorized software from outside.
Understanding of the external environment:
When personal information is handled by a third party in a foreign country, we implement secure management measures based on an understanding of the systems for protection of personal information in that foreign country.
When providing personal information to a third party in a foreign country that does not have the same level of personal information protection systems as Japan, the information is provided with the consent of the individual to whom the information pertains. When obtaining consent, we provide the individual to whom the information pertains with information on the name of the foreign country, systems for the protection of personal information in the foreign country and measures to protect personal information taken by the third party in accordance with laws and regulations.
4. Organized Activities for Personal Information Protection
- (1)We will designate a personal information manager and establish a Personal Information Protection Management System. The personal information manager is granted the authority and responsibility to implement and manage the System in the course of our operations.
- (2)We will improve internal rules and operations based on the results of internal inspections.
- (3)The Policy will be available to the public via our website and other means.
- (1)We will regularly reevaluate our "Personal Information Protection Management System" to establish, implement, maintain, and improve our measures for appropriate personal information protection.
- (2)We will endeavor to train and educate our employees in personal information protection so that they can recognize the importance of personal information protection and appropriately manage and handle personal information.
- (3)We may change the Policy to better protect personal information we have obtained or to make the Policy compliant with amendments of laws, ordinances, and other rules, as well as taking into account our customers' opinions. If we make any changes to the Policy, we will announce it by publishing the changes on our website and the like.
6. Complaints, Opinions, and Other Enquiries about Personal Information
Please send any complaints, opinions, or enquiries regarding our handling of your personal information (specific personal information) using the "Complaints, opinions, or enquiries regarding personal information (specific personal information)" link at the bottom of the page. We will appropriately and promptly respond to you within a reasonable period and to a reasonable extent.
Handling of Personal Information
1. Obtaining Personal Information
We obtain personal information in any of the following circumstances:
- •when such information is provided to us directly by the person orally or in writing, etc.;
- •when such information is automatically transmitted to us in association with the person’s use or browsing of our services, etc. (products, advertisement, content, etc.);
- •when such information is provided to us indirectly by a third party who has obtained consent from the person; or
- •when we obtain personal information disclosed in the printed publication or on the Internet, etc. We may obtain the browsing history/action history on the Web collected through attribute information such as cookies (including IP address, identifier, location information) and the analysis results thereof through our services and the Data Management Platform operated by a third party and, after linking such information with the customer’s personal data, use them for the purpose of delivering advertisement, etc., in which case we treat such information as the personal information.
2. Purpose of use of personal information
|Category||Purpose of Utilization|
|Customers' Personal Information||
|Personal Information Obtained for Compliance with Laws and Ordinances||
|Personal Information Obtained from Public Information Sources||
|Personal Information Obtained During Recruiting Activities||
|Personal Information of Current and Former Employees||
|Personal Information of Shareholders||
3. Provision of personal information
3-1 Provision of personal information
When providing personal information, the Company Group takes measures to avoid providing personal information to any third party (Including third parties located in the foreign countries) without your consent except in the following cases:
- (1)Cases in which the provision of personal information is required by laws and ordinances
- (2)Cases in which the provision of personal information is necessary for the protection of the life, body or property of an individual, and for which your consent is difficult to obtain
- (3)Cases in which the provision of personal information is particularly necessary for improving public health or promoting the sound development of children, and it is difficult to obtain your consent
- (4)Cases in which the provision of personal information is necessary for cooperating with a state organ or a local government, or those entrusted by the state organ or local government in executing the affairs prescribed by laws and ordinances, and in which obtaining your consent is likely to impede the execution of such affairs
- (5)Cases in which we entrust the handling of personal data in whole or in part within the scope necessary for the achievement of the specified purpose of utilization
- (6)Cases in which we provide personal data as a result of succeeding to a business due to a merger or other event, and the acquirer uses such personal data within the scope of the purpose of utilization before the succession
- (7)Cases in which personal data is jointly used between the Company Group and a specific entity or individual, and in advance we notify, or make readily available to, you the following matters, or similar details of equal or greater scope
- •Joint use of personal data
- •Purpose of utilization of an entity or individual using personal data
- •Items of personal data to be jointly used
- •Name or company name responsible for the management of personal data
- •Scope of entities or individuals jointly using personal data
- •Method of obtainment
3-2 Provision of information of officers and shareholders of corporations and other entities
We may provide information regarding the officers and shareholders of corporations or other organizations that is included in the information of such corporation or other organization and that has already been disclosed or publicly announced under laws and ordinances or by such person or such corporation or other organization, after obtaining the person's consent and notifying the person of the purpose of utilization.
3-3 Supervision of contractors
When we entrust the performance of services involving the handling personal information, we execute an agreement with the contractor regarding personal information protection, and exercise appropriate supervision or other control over the contractor to ensure the prevention of leakage, destruction, damage, loss, falsification, or illegal access of personal information or other divulgement of personal information.
4. Activity History, Attribute Information, and Advertisement Delivery by a Third Party
4-1 Delivery of advertisements using cookies
Cookies allow data to be temporarily saved on a computer or other devices used by a customer when accessing a web site. Using cookies enables us to acquire and save in the Company Group's server the customers' activity history in the Company Group's websites (including, but not limited to, URLs and content accessed and the order of access), and unidentifiable attribute information (by the combination of which an individual is not identifiable) such as age and sex, occupation, resident area, record of coming to the store, and location information.
If you prefer not to allow us to collect your information, you can block cookies by modifying your internet browser preferences. Please contact your software manufacturer for instructions on how to change your browser settings. If you choose to block cookies, you may be unable to use a part of the Company Group's services such as the auto login function.
- (2)The Company Group uses advertisement delivery services provided by third parties. In providing advertisement delivery services, such third party may collect and use the information of customers' access history to the Company Group's website or activity history by using cookies.
Customers may discontinue advertisement delivery performed by such third party using cookies by accessing an opt out page created on its website.
List of cookies used for activity history, attribute information, and advertisement delivery services provided by third parties
4-2 Delivery of advertisements provided by third-party advertisers
In order to provide appropriate advertising to customers, Gurunavi Inc. irreversibly transforms part of the personal information it possesses (e-mail addresses, etc.) into data that cannot be used to identify individuals, performs matching with third-party advertisers and delivers advertisements based on the results.
Third-party advertisers do not use this information for any purpose other than delivery of advertisements.
You can choose to enable or disable “behavioral targeting advertising” for these advertisements by third-party advertisers.
- (1)Google customer matching
The “customer matching” provided by Google is used to customize the display of advertising and content on Gurunavi’s products and services that you see on Google’s services for you and to improve convenience. Some personal information (e-mail address, etc.) is shared with Google for this purpose, and only used for the purpose of displaying Gurunavi’s advertisements on Google’s services.
Please refer to Google’s advertising help page for information on the “customer matching” system and the limited handling of data by Google.
Google (How to disable advertising) *Japanese page only
- (2)Yahoo! JAPAN data import function
Gurunavi uses the “data import function” provided by Yahoo! JAPAN to display advertisements on Yahoo! JAPAN and Yahoo! JAPAN partner sites according to usage of Gurunavi services.
Please refer to the help page for the data import function for information on the “data import function” system and the limited handling of data by Yahoo! JAPAN and Yahoo! JAPAN partner sites.
Yahoo! JAPAN (How to disable advertising) *Japanese page only
- (3)Facebook customer audience
Gurunavi uses the “customer audience” provided by Facebook to display advertisements on Facebook services according to usage of Gurunavi services.
Please refer to Facebook’s customer audience help page for information on the “customer audience” system and the limited handling of data by Facebook.
Facebook (How to disable advertising) *Japanese page only
5. Disclosure, etc. of Personal Information
5-1 Disclosure of retained personal data handled by the Company Group
- (1)You may request the Company Group to notify you of the purpose of utilization of, disclose, correct, add or delete the content of, discontinue its utilization of, erase, or discontinue its provision to a third party of, the retained personal data handled by the Company Group ("disclosure, etc.") pursuant to the Act on the Protection of Personal Information.
- (2)When requesting notification of the purpose of utilization and disclosure, you are required to pay handling fees. (For handling fees, please refer to the "Fee and payment method for request for disclosure, etc.")
- (3)You are required to pay all of the printing costs, costs of obtaining documents for identity verification, mailing costs and other costs.
- (4)Please note that we only accept the request form designated by the Company Group, and do not accept any other request form.
- (5)Disclosure of all or part of the personal data held pertaining to a request may be withheld in any of the following cases. If a decision is made to withhold disclosure, notification will be provided with the reason.
- •If there is a risk of harming life, body, property or other interests due to disclosure
- •If there is a risk of significantly impeding the appropriate execution of the Company’s business due to disclosure
- •If disclosure constitutes a violation of laws and regulations
- •If it cannot be confirmed that the request for disclosure is from the individual to whom the information pertains
- •If the Company is otherwise allowed to reject the request pursuant to applicable laws
- (6)We will properly handle personal information acquired at the time of your request to the extent necessary for such request. Please understand that we do not return documents or other materials submitted (including documents for identity verification).
5-2 Fee and payment method for request for Disclosure, Etc
In the case of request for disclosure and request for notification of the purpose of utilization:
- (1)Fee: 500 yen (including tax) per request.
- (2)Payment method: Please enclose postage stamps worth 500 yen with the request form.
- * Cost for replying in writing by simple registered mail. We will provide separate notification in event fees are required for disclosure by means other than mail.
- * If the cost of simple registered mail or the simple registered mail system is changed, the fee for request for Disclosure, Etc. will be changed accordingly.
- * If the payment is either less than the specified fee amount or not enclosed, the Company Group will notify you thereof, and return all the submitted documents. You will be requested to resubmit the documents.
- * Please understand that we do not accept requests by a person who visit our company in person.
5-3 Procedures for request
- (1)Please use the inquiry form to request disclosure, etc. We will follow up by providing information on the procedure.
If sending by mail, please download or print out the "Request form designated by the Company Group" indicated below.
After filling out the relevant items in the form, and signing and sealing the form, please enclose the "documents for identity verification" and mail them to the "Personal Information (specific personal information) Enquiry Desk." In the case of a request made by an agent on your behalf, his or her address, signature and seal are required in addition to your address and name.
1)Request form designated by the Company Group
Request for disclosure, correction or deletion of personal information
[201KB, in Japanese]
* If we are not able to proceed with the procedures because the request form leaves out necessary items or includes misprints or other imperfections, the Company Group will notify you thereof at the address indicated in the written request. Please understand that if we do not receive resubmission of the documents (including undelivered mail) within 2 weeks from such notification, we will deem that you have not requested any disclosure, etc.
2)Documents for identity verification
Please enclose copies of any two of the following. Please make sure that the copies clearly show your name and address.
- •Valid driver's license (copies of both sides are required)
- •Valid passport
- •Copy of residence certificate (only relevant entries such as address and name, which do not include your domicile of origin or personal identification number)
- •Certificate of insured person of an insurance (excluding medical records)
- •If the present address is different from the address recorded with the Company Group due to change of address or for other reasons, please submit a copy of residence certificate showing the history of address change (which do not include your personal identification number)
- •If we are unable to verify the identity because the documents for identity verification are either not enclosed or unreadable or for other reasons, the Company Group will notify you thereof, and return all the submitted documents. You are requested to resubmit the documents.
- •If an agent delegated by you makes a request for disclosure, etc., we will confirm that he or she is your agent by the power of attorney to which your registered seal is attached and your certificate of seal impression, and the agent's document for identity verification, and if your statutory agent makes a request for Disclosure, Etc., we will confirm that he or she is your statutory agent by the statutory agent's document for identity verification and a document certifying the relationship between the statutory agent and you.
- 1)Request form designated by the Company Group
- (3)Once we verify the identity, we will appropriately and promptly make a response within a reasonable period of time and to the reasonable extent.
Specific Personal Information Protection Policy
1. Name of Company
2. Compliance with Relevant Laws, Guidelines, etc.
Concerning the protection of specific personal information, the Company Group will comply with Japan’s laws, guidelines established by the national government, and other relevant standards (guidelines, etc.)
3. Matters Related to Measures for Secure Management
The Company Group will establish appropriate internal rules and security measures to prevent the disclosure, destruction, damage, loss, falsification, unauthorized access, etc. of specific personal information.
4. Appropriate Management of Specific Personal Information
The Company Group will work to ensure specific personal information is managed appropriately, implementing periodic inspections carried out by an appointed personal information manager.
5. Consultation and Complaints Contact
We will appropriately and promptly respond to complaints, opinions, and questions regarding specific personal information handled by the Company Group within a reasonable period and to a reasonable extent.
Please use the "Complaints, opinions, or enquiries regarding personal information (specific personal information)" link at the bottom of the page to contact us.
6. Intended Use of Specific Personal Information
Personal information will only be used for purposes stipulated by Japan's laws, guidelines established by the national government, and other relevant standards (guidelines, etc.)
Name of the Personal Information Manager (specific personal information)
Senior Managing Executive Officer
Complaints, Opinions, and Other Enquiries about Personal Information
Please contact us using the dedicated contact form or the following links:
- ※Click here for enquiries regarding our handling of personal information.
- ※Click here for enquiries regarding our handling of specific personal information.
- ※Click here for enquiries regarding activity history and contextual information.
- ※Please contact the following address for enquiries regarding the personal information we have obtained.
Personal Information Enquiry Desk:
Hibiya Mitsui Bldg. 11F, 1-1-2 Yurakucho, Chiyoda-ku, Tokyo 100-0006
Complaint and Consultation Desk Manager at Personal Information Enquiry Desk
Name of authorized personal information protection organization and contact for requests for complaint resolution
The name of the authorized personal information protection organization to which Gurunavi Inc. belongs and the contact for requests for complaint resolution are as follows.
Japan Consumer Credit Association
Contact for requests for complaint resolution
Consultation desk on handling of personal information (Refer to the URL below)
https://www.j-credit.or.jp/customer/personal-consult/index.html *Japanese page only
In this Policy, the "Company Group" means the following companies.
- •Gurunavi, Inc.
- •Gurunavi Promotion Community Inc.
- •Gurunavi Research Institute Inc.
- •Gurunavi Support Associe, Inc.
- *The information above will be periodically updated.
Akio Sugihara, President, Representative Director
Personal information protection policy
Established：July 1, 2004
Last updated: April 01, 2022
Specific personal information protection policy
Established：November 17, 2015
Last updated: August 31, 2021