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" and the voice service "NEWT Voice" (collectively, "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
• Prospective customer data: Name, company name, and contact details provided when using our demos, requesting materials, making inquiries, or attending events and seminars
• Voice call data: Caller phone number and call content (including recordings and transcripts) when using our voice service (NEWT Voice) or phone demo
• 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 set out below for each category of data subject.

Users (customers and their personnel)

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

Prospective customers (those who use our demos, request materials, make inquiries, or attend events/seminars)

• Responding to demo use, material requests, and inquiries: Pre-contractual measures / Legitimate interests
• Providing information and proposals about our services (including contact by phone, email, or SMS): Legitimate interests / Consent
• Analyzing demo and inquiry content to improve response quality and our services: Legitimate interests
• Information about events and seminars: Legitimate interests / Consent

Prospective customers may opt out of such communications from the Company at any time (see the contact in Section 14).

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, AI processing infrastructure, telecommunications carriers, payments, analytics, support)

All processors are subject to confidentiality and data protection agreements.

No joint use of data is conducted.

7. AI Processing and Use for Model Training

Chat and voice interactions in the Service are processed automatically by AI.

• Chat and call content (including recordings and transcripts) may be processed by external AI processing infrastructure engaged by the Company in order to generate responses and improve quality. Such processors are managed in accordance with Section 6.
• Use of user data containing personal data for AI model training and improvement is governed by our Terms of Service (Article 7). Data from paid plans is not used for training without explicit prior (opt-in) consent. Data from free plans may be used for training, with an opt-out available at any time, and the Company makes reasonable efforts to anonymize or aggregate such data.
• While responses are generated automatically, the Company does not make decisions with significant effects on individuals' rights and obligations solely by automated means without human involvement.

8. Personal Data of Our Customers' End Users

Regarding personal data of individuals who chat or call through the websites or phone lines of businesses that have adopted the Service ("Customers"):

• The Company processes such data solely on behalf of and as instructed by the Customer, to the extent necessary to provide the Service.
• The privacy policy of the relevant Customer applies to the purposes of use of such data.
• End users should direct requests for access, correction, or deletion to the relevant Customer in principle. If contacted directly, the Company will coordinate with the Customer to respond.

9. 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.

10. 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

Voice call recordings and transcripts are retained under the same criteria and deleted or anonymized after the applicable period.

Users may request deletion of their personal data (see Section 14).

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

11. 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.

12. 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
3. Implement corrective and preventive measures

13. 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.

14. 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.

15. Children's Data

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

Minors should not provide personal data without parental consent.

16. 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.

17. 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.

18. Contact

Reiwa Travel Inc. – Privacy Office

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

Email: support@reiwatravel.co.jp

19. 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)