Privacy Policy

Reiwa Travel Inc. ("the Company") recognizes the importance of protecting and appropriately managing the personal data of users ("Users") in connection with the provision of the chat service "NEWT Chat" ("the Service").

This Privacy Policy ("Policy") explains how the Company collects, uses, and protects personal data.

1. Scope

This Policy applies to all personal data collected or processed by the Company in relation to the use of the Service.

Other services provided by the Company may be subject to separate privacy policies.

2. Data Controller and Contact

• Data Controller: Reiwa Travel Inc.
• Address: 20-1 Sakuragaoka-cho, Shibuya-ku, Tokyo 150-0031, Japan
• Contact Email: support@reiwatravel.co.jp

3. Definition of Personal Data

"Personal Data" means any information relating to an identified or identifiable natural person, such as name, contact details, or online identifiers (e.g., IP address, device ID).

4. Data Collected

The Company may collect the following types of personal data:

• Data provided by Users: Name, company name, email address, phone number, contract information, chat content, inquiry details
• Automatically collected data: IP address, browser/OS information, usage logs, cookies, location data
• Third-party data: Status information from payment services and authentication providers

5. Purpose and Legal Basis for Processing

The purposes of use and corresponding legal bases are as follows:

• Providing and operating the Service: Performance of contract
• Managing billing, payment, and contracts: Contract / Legal obligation
• Service improvement and analytics: Legitimate interests / Consent
• Marketing and new feature notices (opt-in): Consent
• Fraud prevention and security: Legitimate interests / Legal obligation
• Compliance with legal requirements: Legal obligation

6. Third-Party Disclosure and Outsourcing

The Company does not disclose personal data to third parties except in the following cases:

• With the User's consent
• When required by law or regulation
• When outsourcing to trusted service providers (e.g., cloud hosting, payments, analytics, support)

All processors are subject to confidentiality and data protection agreements.

No joint use of data is conducted.

7. International Data Transfers

The Company may transfer or store personal data outside Japan when using cloud infrastructure or third-party providers.

In such cases, the Company ensures appropriate safeguards, such as:

• Transfers to countries or regions recognized as providing adequate protection; or
• Execution of Standard Contractual Clauses (SCCs) or implementation of Binding Corporate Rules (BCRs).

Users may request a summary of such safeguards.

8. Data Retention and Deletion

The Company retains personal data only for as long as necessary to fulfill the purpose of collection.

After the purpose is achieved, the data will be securely deleted or anonymized.

Retention periods are determined based on:

• Legal or contractual obligations
• Service operation and support requirements

Users may request deletion of their personal data (see Section 12).

The Company will respond within a reasonable scope unless retention is legally required.

9. Security Measures

The Company implements reasonable and effective technical and organizational measures to prevent unauthorized access, loss, or leakage of personal data, including:

• Data encryption during transmission and storage
• Access control and multi-factor authentication
• Security monitoring and vulnerability management
• Employee and contractor confidentiality agreements
• Privacy-by-design in product development

Security measures are reviewed and improved continuously.

10. Response to Data Breaches

If a data breach occurs, the Company will promptly:

1. Contain the incident and investigate the cause
2. Notify relevant authorities and affected users (within 72 hours where required)
3. Implement corrective and preventive measures

11. Use of Cookies

Cookies and similar technologies are used to improve user experience and analyze traffic.

Types of cookies used:

• Essential cookies: Necessary for core functionality
• Analytics cookies: Usage statistics (e.g., Google Analytics)
• Marketing cookies: Advertising optimization (used only with consent)

Users can manage or disable cookies via browser settings or consent tools.

12. User Rights

Users have the following rights under applicable laws (GDPR, CCPA, APPI, etc.):

• Access, correction, and deletion
• Restriction or suspension of processing
• Data portability (for EU residents)
• Objection to processing and withdrawal of consent

Requests may be submitted to:

• Email: support@reiwatravel.co.jp

The Company will respond promptly and in accordance with applicable laws.

13. Children's Data

The Service is not intended for individuals under 16 years of age.

Minors should not provide personal data without parental consent.

14. Compliance with Laws

The Company complies with Japan's Act on the Protection of Personal Information (APPI), the EU General Data Protection Regulation (GDPR), and the California Consumer Privacy Act (CCPA).

Additional rights under these laws apply to users in relevant regions.

15. Changes to This Policy

The Company may update this Policy in response to legal, technical, or service changes.

Material updates will be announced via in-service notices or email.

The revised Policy takes effect upon publication.

16. Contact

Reiwa Travel Inc. – Privacy Office

20-1 Sakuragaoka-cho, Shibuya-ku, Tokyo 150-0031, Japan

Email: support@reiwatravel.co.jp

17. Supervisory Authorities

If you are unsatisfied with our handling of your personal data, you may contact:

• Japan: Personal Information Protection Commission – https://www.ppc.go.jp/
• EU: Local Data Protection Authority
• US: California Attorney General (CCPA inquiries)