Privacy Policy
This is a reference translation. The Japanese version prevails.
- The only information we collect is the email that reaches info@neo-graphic.com (general enquiries) or privacy@neo-graphic.com (requests and complaints about personal data), together with what we need in order to verify your identity or to post a written reply when you make a request under Section 11.
- This website consists only of static pages and does not use JavaScript. There are no input fields, no accounts, no payments and no advertising. We have not built in cookies (small records stored in your browser) or any analytics, and we do not identify individual visitors. Records used by the providers that deliver this website are described in Section 13.
- Emails are stored on a service operated by a provider located in the United States, and we aim to delete them about one year after we have replied (or about one year after receipt if we do not reply).
- This Policy covers this website only. Any application we provide is covered by a separate policy for that application.
1. Who we are, and what this Policy covers
This Policy is issued by NeoGraphic ("we", "us", "our").
Our address is Shibuya Dogenzaka Tokyu Building 2F-C, 1-10-8 Dogenzaka, Shibuya-ku, Tokyo 150-0043, Japan. Our business is the planning, development and operation of smartphone applications and web services, and the person responsible for personal data is the proprietor himself. Our name, our representative, our address and other details of the business are set out on the company page of this website (https://neo-graphic.com/company). This Policy covers your use of https://neo-graphic.com (this "website") and emails sent to the addresses given on it (the "emails you send us"). Privacy policies for our applications are set out separately for each application.
2. What we collect, and how
We collect the information contained in the emails you send us — your name, your email address, the body of the message and any attachments — together with the records that attach automatically to an email, such as the date, time and routing, including information indicating where it was sent from.
When you make a request regarding your personal data, we also collect what we need to verify your identity, and a postal address if we are to reply in writing. This website has no input fields. When you view it, your browser sends information such as your IP address to the providers that deliver the site, but we do not receive the parts of that information which would identify you as an individual (see Section 13).
Please do not include special care-required information such as medical history or beliefs, and do not attach files that are not needed for your enquiry. If you include information about someone other than yourself, please obtain that person's agreement first. For safety, we do not open password-protected archive files. Because email can be read in transit, please do not send us passwords, card numbers or bank account numbers.
3. Why we use it
We use the information we collect only for the following purposes.
- To answer your enquiry or your request regarding personal data, and to contact you about it
- To verify your identity when you make a request regarding personal data
- To respond to fraud, impersonation, nuisance or unlawful conduct, including preserving evidence and consulting the police or a lawyer
- To meet our obligations under the law
We do not quote the content of your enquiry in a reply to anyone else. If we change the purposes above, we will do so only within a scope that can reasonably be regarded as related to the original purpose, and we will publish the change on this website.
4. Sharing with others, and disclosure required by law
We do not provide your information to third parties without your consent, and we do not publish it, compile it into lists or sell it. There are a small number of exceptions.
- Where the law requires or permits it — for example a warrant, a court order or a court's request, or an inquiry from investigative authorities, a bar association or the tax authorities
- Where it is necessary to protect someone's life, body or property and it is difficult to obtain your consent
- Where we need to co-operate with a national or local government body carrying out its statutory duties, and seeking consent would risk obstructing those duties
When we receive an inquiry or a court request, we check the legal basis for it, whether the body making it is genuine, and the scope of what is being asked. We respond only to the extent necessary and appropriate, and we may decline where we have proper grounds to do so. We do not answer inquiries made orally or by telephone at the time they are made; this does not apply, however, where there is an imminent danger to someone's life or body, or where we are asked to preserve records without providing them. We do not comply with requests sent directly to us by a government body of another country other than through a procedure under Japanese law — this is our position on requests aimed at us, and does not mean that the provider storing our email (Section 5) could not be subject to a procedure under the law of the country where it is located. When we do provide information, we keep a record of the circumstances, and unless the law prohibits or restricts it or doing so would risk obstructing an investigation, we will endeavour to let you know so far as we are able. Transfers on a business succession are covered in Section 14.
5. Where your information is stored, and handling outside Japan
The emails you send us are stored on a service operated by a provider located in the United States.
That provider is located in the United States, but the country in which the equipment used for storage sits may change according to how the provider operates its service, and we are not able to identify it. We use the materials published by the Personal Information Protection Commission of Japan to understand the personal data protection regime of the United States and of any other country where our data may be stored, and we take the security measures in Section 6 in the light of that understanding. Communication with the storage provider is encrypted, although whether an email is encrypted along its entire route depends on the settings of each provider it passes through.
6. How we keep information safe
In accordance with the Act on the Protection of Personal Information of Japan (the "APPI"), we take the measures necessary and appropriate to prevent leakage, loss or damage of personal data and otherwise to keep it safe.
- Organisation: the proprietor is the only person who handles personal data, and we have a procedure in place for responding to a data breach
- People: we have no employees (if we engage any, we will supervise and train them)
- Equipment: the storage in our devices is encrypted, and the screen is locked when we are away from it
- Communications and accounts: unnecessary network traffic is blocked, multi-factor authentication is enabled on all of our principal accounts, and devices and software are kept up to date
We take reasonable measures, but we cannot guarantee the security of the route your communication travels (see Section 15).
7. How long we keep it
We aim to delete an email about one year after we have completed our reply, or about one year after receipt where we do not reply — for example unsolicited sales or automated messages.
Where the law requires us to retain information, where we have been asked to preserve or produce it or may be, or where we need it to deal with a complaint, a dispute or fraudulent conduct, we retain it until that need ends. If you ask us and we can confirm that the request is yours, we will endeavour to delete the information without waiting a year, except in the cases just described; how such a request is handled is set out in Section 11. Deletion covers the body of the message, its attachments and the record of sending and receiving. It may take a number of days to complete, and we cannot guarantee deletion by any particular time.
8. If there is a data breach
If we discover that personal data has been leaked, lost or damaged, or that this may have happened, we respond according to the circumstances.
We (i) establish the facts and prevent further harm, (ii) notify those affected, (iii) report to the Personal Information Protection Commission where that is required, (iv) investigate the cause and prevent a recurrence, and (v) publish an account on this website where the circumstances call for it. We notify you at the address you used to contact us, and where we cannot reach you we use an alternative such as publishing an account on this website. We make any report within the period the law allows. We respond in the same way if our domain or our email delivery is interfered with.
9. Impersonation, and emails that pretend to be from us
We contact you from either info@neo-graphic.com or privacy@neo-graphic.com — apart from the automatic notices that the email system itself sends, such as a delivery failure.
The sender shown on an email can be forged, and messages may arrive from domains that closely resemble ours, so please do not judge an email to be genuine by its appearance alone. The only domain we use to contact you is neo-graphic.com, and we never ask you to send us a password, a card number or a bank account number. The only situation in which we ask for a copy of an identity document is in a reply from privacy@neo-graphic.com to a request you have made. This website has no input fields; if a screen asks you to enter something, or if you receive an email that seems suspicious, please stop and let us know at info@neo-graphic.com. You may also wish to contact the police consultation line in Japan (#9110).
10. Enquiries from people under the age of majority
If you have not reached the age of majority, please contact us with the agreement of a parent or guardian.
Please do not write anything that is not needed for your enquiry, such as the name of your school, your home address, or information about your family. Where we can tell that an enquiry is from a person under the age of majority, we handle it only to the extent needed to reply, and depending on what it concerns we may ask to confirm a parent's or guardian's agreement. After we have replied, we endeavour to delete the information as a priority, without waiting for the period in Section 7. A request from a parent or guardian acting as legal representative is handled under Section 11.
11. Requests about your personal data, and complaints
You may make the following requests by emailing privacy@neo-graphic.com with "Request regarding personal data" in the subject line. There is no charge.
- Notification of the purpose of use, disclosure, correction, addition or deletion
- Suspension of use, erasure, or suspension of provision to third parties
- Disclosure of records of provision to third parties
So that we do not hand your information to anyone else, we verify your identity by asking that the request comes from the same address as your original email, and we send our reply to that same address. Only where there is no other way to verify your identity will we ask for a copy of an identity document; because we cannot guarantee the security of email in transit (Section 2), please send only the pages needed, with your family register reference and individual number blacked out. We delete the copy promptly once we have verified your identity. We ask an agent for a power of attorney, and a legal representative for a copy of a document showing their standing. If you are not able to use email, a family member or someone else may email us on your behalf, and we will discuss with you individually how to verify your identity and how to reply. If you would like our reply in writing, we will ask for a postal address and send it to you (we do not accept requests made by post).
We reply without undue delay, and we will let you know if it is going to take time. Where you ask us to suspend use, erase information or stop providing it to others, we act where there are grounds to do so, to the extent the law requires. Where we cannot comply — because we cannot verify your identity, because the request concerns information about someone else, or because the law does not permit it, such as where complying would risk harming your rights and interests or those of a third party — we tell you so without undue delay, and we also endeavour to explain why, unless doing so would risk obstructing a procedure under the law.
We hold no records of provision to third parties, because we have made no provision for which the law requires such a record to be created. We do keep a voluntary record of the circumstances of any disclosure under Section 4, and if you ask for it we will treat that as a request for disclosure. Complaints may also be sent to privacy@neo-graphic.com. We do not belong to an accredited personal information protection organisation. You may also raise a matter with the contact points published on the website of the Personal Information Protection Commission.
12. Viewing this website from outside Japan
This website is offered to people in Japan and is operated in accordance with Japanese law.
The English version of this Policy is a translation provided for reference; it is not intended as an offer of services to people outside Japan. We will deal conscientiously with an enquiry from outside Japan within the scope of the APPI, but we are not able to respond individually to rights or procedures arising under the law of another country.
13. Outside services, and links
We use Cloudflare to deliver this website and Google Fonts to display its typeface.
When you open this website, information such as your IP address and the type of browser you are using is sent to both companies. The provider delivering the site also receives the address of the page requested, and the provider of the typeface receives this website's address as the referring page, in most cases down to the domain. Each company handles that information under its own privacy policy, and each may respond to requests made under the law. The provider delivering the site may use records that remain in your browser for a period in order to keep the service secure, and these may include cookies; we have not built them in and we do not receive them.
Where this website links to an outside site, the handling of personal data there is governed by that site's operator and its own policy. We are not in a position to control it, and we suggest you check the policy of each site.
14. If we close or transfer the business
If we close the business, we will delete the emails we hold within a reasonable period.
We will keep the email addresses live for a period afterwards and post a notice on this website saying that we can no longer receive enquiries. If the business is transferred — including on incorporation — personal data may pass to the successor, and under the law the successor may not handle it beyond the scope necessary to achieve the purpose of use that applied before the transfer. We will publish notice of a transfer on this website.
15. Our approach to responsibility, governing law and courts
This Section sets out how we think about the extent of our responsibility, and our view on the law and the courts that apply. It is not intended to limit responsibility arising from our intentional acts or gross negligence, or any other responsibility that the law does not allow us to exclude.
We endeavour to keep the information on this website accurate and current, but we do not warrant all of it. Where a natural disaster, a communications failure or a failure of an outside service makes this website unavailable or delays our reply, and where a third party reads a communication in transit even though we have taken the measures in Section 6, we are unable to accept responsibility unless we have acted intentionally or with gross negligence. In any other case, whether we bear responsibility and to what extent is determined under the law, and compensation is based on the loss that would ordinarily arise.
This Policy is not a contract, so we are not asking you to agree to a choice of court. This Policy and our handling of personal data are to be interpreted under Japanese law, and for our part, to the extent the law allows, we would hope that any proceedings at first instance would be heard by the Tokyo District Court.
16. Changes to this Policy
We may revise this Policy as the law changes or as our business or operations change.
As a rule a revised Policy applies from the time we publish it on this website. For an important change, however — such as a change of contact point, of retention period or of the purposes of use — we separate the date of publication from the date it takes effect, publish it in advance, and endeavour to give notice on the home page for a reasonable period. If you would like an earlier version, write to info@neo-graphic.com and we will send it by email.
17. How to contact us
We accept contact by email (we do not accept contact by post or by telephone).
Please send general enquiries to info@neo-graphic.com, and requests, complaints or questions about personal data to privacy@neo-graphic.com, addressed to "NeoGraphic, Personal Data". A reply may take some days. We may not reply to sales or advertising messages, to automated messages, or to messages amounting to threats or defamation. This does not include opinions or criticism, or the requests and complaints covered by Section 11.
18. Japanese and English versions
The Japanese version of this Policy prevails.
The English version is a translation provided for reference and can be read from this page. Where the two differ, the Japanese version governs; the Japanese version carries the same statement. If we find an error in the translation, we will correct it promptly.