GDPR Privacy Policy

GDPR Privacy Policy

The Gurunavi Group (the "Company Group"), has established the following policy to comply with the regulations of the General Data Protection Regulation (the “GDPR”) related to the processing and transfer of all information related to individuals (“personal information”) of persons identified (or who could be identified) as using the services of the Company Group and residing in the European Economic Area (the “EEA”) regardless of nationality or location.

The Personal Data We Collect from You

The Company Group may collect personal data from persons using the services of the Company Group including: name, professional affiliation, occupation, address, telephone number, e-mail address, sex, date of birth, area of residence, employment information, IP addresses, cookie information (and similar technologies, hereafter “cookies”), and website access history.

Objectives and Legal Basis for Use of Personal Data

  1. 1.

    The GDPR requires that all companies within the EEA process data in accordance with the legal basis specified below:

    • ・The data subject has given prior consent to the processing of his or her personal data
    • ・Processing is necessary for the performance of a contract to which the data subject is party or necessary prior to data subject entering into a contract
    • ・Processing is necessary for compliance with a legal obligation to which the Company Group is subject
    • ・Processing is necessary in order to protect the vital interests of the data subject or of another natural person
    • ・Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Company Group
    • ・Processing is necessary for the purposes of the legitimate interests pursued by the Company Group or by a third party
  2. 2.

    In addition, the Company Group uses personal data for the purposes and in accordance with the legal basis outlined in the table below:

    Category Purpose of Utilization Legal basis for the processing
    Customers' Personal Information ・To confirm a person’s identity (including biometric identification) when registering an account with or logging into services provided by the Company Group, and for the Company Group to provide said services Performance of a contract
    ・Contacting and informing customers via phone, mail, email etc. about the Company Group's services. Distributing questionnaire surveys and email newsletters Legitimate interests
    ・To conduct surveys which include answers related to personal information of the participant; when contacting the participant with information about the products and services of the Company Group; in sales activities towards the participant including the promotion of events Legitimate interests
    ・Restaurant reservation procedures, reservation management, contacting customers, ascertaining number of customers coming to restaurant, customer identity verification upon arrival at restaurant, and provision of personal information to the reserved restaurant Performance of a contract Legitimate interests
    ・Providing our services, ascertaining and analyzing customers' usage of our services by using customers' visiting, purchase, page-view, and activity history (hereafter "history") or location information Legitimate interests
    ・To create statistical data such that an individual cannot be identified based on their appearance and use this data to ascertain and analyze circumstances of customer visits and improve the quality of the Company Group’s services Legitimate interests
    ・Sending recommendations and direct mail to customers based on their history Legitimate interests
    ・Settlement of fees, points, etc. (personal information may be exchanged with mobile carriers, credit card companies, etc.), processing of refunds, and notification related to these. Performance of a contract Legitimate interests
    ・To inform customers about seminars, exhibitions, campaigns, competitions and the like (hereafter "events") held or co-held by the Company Group; in the participation in and application procedures for such events and in related lotteries and prize distribution; to ascertain information on participation in, and to organize/manage and conduct administrative work relating to such events. Images, videos, and sound recordings may be made at events. Personal information may also be provided to co-organizers of events, in the delivery of prizes and to a contractor entrusted with said delivery Legitimate interests
    ・Reporting customers' feedback and requests to restaurants, wedding venues, commercial facilities, beauty salons, event promoters, hotels and the like, and product distributors Legitimate interests
    ・Providing information on other companies' services introduced by the Company Group, acting as an intermediary for applications for such services, and administration and contact regarding the services Performance of a contract Legitimate interests
    ・Identity verification necessary for provision of the Company Group's services, delivery of various notices, administrative processes including fee charging, and confirmation of validity of materials used for customer identity verification Performance of a contract Legitimate interests
    ・The delivery of products or foodstuffs by the Company Group, its partner companies, organizations, producers and the like, and the creation of documents for use in delivery of goods Performance of a contract Legitimate interests
    ・The delivery of rewards for participation in market research surveys and promotions conducted by the Group Company Legitimate interests
    ・Customer guidance and consulting via phone, email, or in person Performance of a contract Legitimate interests
    ・Customer management including personality and attribute information, etc. for building smooth relations with customers. Legitimate interests
    ・Audio and video recording to improve the quality of dealing with and responding to customers Legitimate interests
    The following agency operations:
    Registration, application, reservation, application management and other operations in all services
    The sending of e-mails or messages over social media for promotional purposes
    Applications and other procedures under government systems
    Performance of a contract Legitimate interests
    ・Delivery, installation, construction, and initial setup of machinery to provide the Company Group's services, communication regarding delivery dates and other matters, and provision of personal information in the case that a contractor is entrusted with work Performance of a contract Legitimate interests
    ・Provision of guidebooks, members' magazines, VIP-only information and the like Legitimate interests
    ・Production of information magazines, communications relating to and the conducting of interviews, and promotion and advertisement of the Company Group's business Legitimate interests
    ・To research and analyze how the Company Group’s services are used and gauge customer satisfaction levels, to create statistical data such that a specific individual cannot be identified, and, through the use of this data, improve the Company Group’s marketing, website creation, development of new services, and quality of current services Legitimate interests
    ・Corrections or deletions to information registered with the Company Group's services Performance of a contract
    ・Confirmation of video recorded to serve and monitor activities of customers who visit our offices Legitimate interests
    ・Maintenance of security of the Company Group's services, investigation, reporting, and contact in the event of an incident or accident Legal obligation
    Personal Information Obtained for Compliance with Laws and Ordinances ・Exercise of rights under agreements or laws in relation to the Company Group's business, responding to claims, and appropriate implementation of business Performance of a contract Legal obligation
    Personal Information Obtained from Public Information Sources ・The Company Group's business activities including the provision of products and services, and notifying customers of events Legitimate interests
    ・Transaction screening and credit management/check Legitimate interests
    Personal Information Obtained During Recruiting Activities ・Consideration of new employees joining the Company Group, contacting candidates regarding job interviews, notifying candidates of the results of job interviews, delivery of relevant recruitment documents, settlement of expenses Legitimate interests
    ・The Company Group's overall employment activities, and provision of personal information to a third party in the case that a third party is entrusted with a portion of the work Legitimate interests
    Personal Information of Current and Former Employees ・Labor management Legitimate interests
    ・Communication with, and provision of personal information to, affiliates, companies receiving secondees, and the like Legitimate interests
    ・Payment of salaries, bonuses, and the like Legitimate interests
    ・Filing of notices or reports to governmental agencies Legitimate interests
    ・Communication for various purposes advertisement via paper, e-mail, or audio-visual means Legitimate interests
    ・Emergency contact and practice notices for and sharing of results thereof Legitimate interests
    ・Communication, sales and support activities using communication methods such as audio, images and video. Legitimate interests
    ・Ascertaining circumstances and contacting individuals following employee introductions during hiring periods Legitimate interests
    ・Replies to surveys requested by other companies Legitimate interests
    ・Field trials for registration of biometric information (venous and facial information, etc.) with biometric authentication equipment, behavior verification and development of new services. Legitimate interests
    ・Video and online monitoring for crime prevention and prevention of misconduct. Legitimate interests
    Personal Information of Shareholders ・Delivery of our business reports or any other documents distributed to shareholders and the like Legitimate interests
    ・Provision of information to shareholders, exchange of information and implementation of surveys, etc. Legitimate interests
    ・Responding to shareholders exercising their rights Legitimate interests
    ・Management of shareholders in accordance with relevant laws and ordinances Legitimate interests
    ・Provision of personal information for exercise of rights and performance of obligations in accordance with the Companies Act Legitimate interests
    Enquiry ・Any enquiries relating to the above Legitimate interests
  3. 3.

    In the event that your personal data is to be used for purposes other than those outlined above, we will notify you of the additional purposes and provide related information (retention period, your rights, etc. as defined by the GDPR).

Transfer of Personal Data Outside of the EEA

  1. 1.
    There are cases when the Company Group may transfer personal data to countries outside of the EEA. This includes transfer to third parties (to conduct data processing) such as entities of the Company Group, cloud service vendors, and service management companies. In these cases, third parties are supervised to ensure that they provide an appropriate level of protection in accordance with the GDPR when handling personal data.
  2. 2.

    By using the Company Group’s services you agree to the following:

    • ・In the event that countries outside of the EEA do not have adequate personal data protection laws, the same level of protection established by the GDPR cannot be guaranteed.
    • ・To achieve the Company Group’s use objectives, personal data may be transferred to third parties (to conduct data processing) such as entities of the Company Group, cloud service vendors, and service management companies located in countries outside of the EEA.

Protection and Management of Personal Data

  1. 1.
    The Company Group implements protection and management measures to handle personal data appropriately, striving to ensure personal data is protected from disclosure, loss, damage, theft, alteration, or unauthorized access.
  2. 2.
    To ensure appropriate handling, the Company Group oversees all management and handling of personal data, making employees aware of the importance of personal data and the risks in the event of rule violations.

Data Retention Policy

The Company Group keeps personal data for no longer than is necessary for the purposes for which the personal data is processed, and promptly erases any personal data deemed unnecessary.

Activity History, Attribute Information, and Advertisement Delivery by a Third Party

・Delivery of advertisements using cookies

  1. 1.
    The Company Group may use cookies in order to provide information that is easily accessible by, and valuable to, users. 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 on the Company Group's websites (including, but not limited to, URLs and content accessed and the order of access), and unidentifiable attribute information such as age and sex, occupation, area of residence, records of customer visits, 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.
  2. 2.
    The Company Group uses advertisement delivery services provided by third parties. In providing advertisement delivery services, such third parties may collect and use the information of users’ access history to the Company Group's website or activity history by using cookies.
    Cookies and other information acquired by such third parties will be handled in accordance with the Company Group’s privacy policy.
    Users may discontinue advertisement delivery performed by such third parties using cookies by accessing an opt-out page on the third party’s website.
  3. 3.
    The Company Group uses cookies to provide services. Users of the Company Group websites can disable cookie functions by adjusting browser settings, but as a result some or all of the website services may become unusable.

・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. 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. 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. 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

Data Subject Rights

  1. The data subject has the following rights with regard to personal data. To request further information, please contact us using the enquiry form below.

    • ・The right to request access for disclosure of purpose, type, destination, period of retention, source of acquisition, etc.
    • ・The right to request corrections
    • ・The right to have personal data erased
    • ・The right to object to the handling of personal data
    • ・The right to object to processing in certain circumstances
    • ・The right to request to move personal data from one service provider to another (data portability)
    • ・The right to withdraw consent at any time
    • ・The right to put forward a complaint at any time to the supervisory body of any country within the EEA


Please use the form below to contact us with any enquiries, requests, complaints, or questions regarding personal data.

Gurunavi, Inc.

Hibiya Mitsui Bldg. 11F, 1-1-2 Yurakucho, Chiyoda-ku, Tokyo 100-0006

Click here to make an enquiry.


  1. 1.
    In the case that personal data is not provided, some services provided by the Company Group may become unavailable.
  2. 2.
    This policy is subject to change by the Company Group. Please refer to “Last Updated” to confirm when this policy was last updated and check this page for the latest information.

Company Group

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.

Gurunavi, Inc.
Akio Sugihara, President, Representative Director

Established:October 19, 2018
Last updated : December 13, 2021

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