Privacy Policy

This Privacy Policy (“Policy”) explains how the website “Japaniche” (“the Site”), operated by GROWTH Holdings Inc. (“we”, “us”, “our”), handles personal data and related information (“Personal Information”). It is drafted with major data protection laws in mind (e.g., GDPR/UK GDPR, California CCPA/CPRA, Japan’s APPI). See Regional Addenda for jurisdiction-specific details.

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The Site displays third-party advertising and uses affiliate links, and it uses analytics, session-analysis, and consent-management tools. See 5. Cookies and Similar Technologies, 6. Tools We Use, and 7. Advertising and Affiliate Links.

1. Scope

This Policy applies to information collected through your browsing and use of the Site, submissions through our contact form, subscription to our newsletter, and our use of cookies and similar technologies. It does not apply to third-party websites we link to, including destinations reached through advertising or affiliate links.

2. Information We Collect

2.1 Information You Provide

Contact form: name (optional), email address, subject, and message contents.
Newsletter: email address, first name (optional), language preference, signup source, and signup date.

2.2 Information Collected Automatically

Device and browser information (device type, OS, browser, language settings, etc.)
Log data (access time, pages viewed, time on page, referrer URL, approximate location, processed IP information, etc.)
Cookies and similar identifiers, and your cookie consent status
Interaction data: page interactions such as scrolling, clicks, and pointer movement, recorded as aggregated heatmaps and pseudonymized session replays (see 6.6)
Advertising data: ad impressions, ad clicks, and advertising identifiers processed by Google and its partners (see 6.4)
Affiliate data: clicks on outbound links that are, or are automatically converted into, affiliate links (see 6.5)

3. Purposes of Use

Provide, operate, maintain, and improve the Site
Measure and analyze usage; optimize content and user experience
Display advertising, measure its performance, and operate affiliate links, in order to fund the Site
Deliver the newsletter and respond to inquiries
Ensure security and prevent fraud/abuse
Comply with laws and handle disputes or claims

4. Legal Bases (EU/EEA & UK)

Consent: Non-essential cookies and similar technologies, including analytics, session analysis, advertising, and affiliate measurement
Legitimate interests: Site operation, security, and prevention of fraud and abuse
Contract/performance: Responding to your requests, and delivering the newsletter you subscribed to
Legal obligation: Compliance with applicable laws and requests from authorities

5. Cookies and Similar Technologies

We use cookies, pixels, and similar technologies. Categories include:

Strictly necessary: Core functionality and security (no consent required)
Preferences: Save settings such as language (consent may be required in some regions)
Statistics/Analytics: Measure and analyze usage, including heatmaps and session replay (consent required in certain regions)
Marketing/Advertising: Serving and measuring advertising, and attributing affiliate referrals. These are in use. See 7. Advertising and Affiliate Links.

Consent Management: We use CookieYes to display a regionalized consent banner and maintain consent logs. You can review or change your choices at any time from the Cookie Settings link in the Site footer. The cookie list is kept up to date by CookieYes’s Cookie Declaration.

6. Tools We Use

6.1 Google Analytics (GA4)

Purpose: Measure and analyze Site usage.
Data examples: Event data, device information, approximate location, etc.
Notes: Measurement requests are routed through a first-party endpoint on our own domain (japaniche.org/metrics/) before being forwarded to Google. Our infrastructure therefore processes the connecting IP address in transit; it is not retained for analytics reporting, and GA4 reports do not expose full IP addresses. User identifiers are randomly generated, and user-level retention follows our GA4 admin settings (2–14 months).
Opt-out: Reject the “Statistics/Analytics” category in Cookie Settings, or use Google’s browser opt-out add-on .

6.2 Google Tag Manager (GTM)

Purpose: Manage tags centrally. GTM itself is not designed to collect personal information, but it controls the firing of configured tags.
Consent: Tag firing respects CookieYes consent status; tags in non-consented categories will not fire.

6.3 CookieYes

Purpose: Obtain and manage cookie consent; store consent logs; auto-generate the Cookie Declaration. See the CookieYes privacy policy .

6.4 Google AdSense

Purpose: Display third-party advertising on the Site.
Data: Cookies and advertising identifiers, ad impressions and clicks, approximate location, and device and browser information. Where you have consented, this may be used to personalize the ads you see based on your prior visits to this and other websites.
Notes: Google and its advertising partners act as independent controllers for this processing. See How Google uses information from sites that use our services .
Opt-out: Reject the “Marketing” category in Cookie Settings, or manage ad personalization in Google’s My Ad Center .

6.5 Travelpayouts (affiliate)

Purpose: Operate and measure affiliate links, including the automatic conversion of eligible outbound links into affiliate links.
Data: Clicks on outbound links, the referring page, device and browser information, and a pseudonymous identifier used to attribute a referral.
Notes: Operated by Travelpayouts, which may process data outside your country. See the Travelpayouts privacy policy .

6.6 Microsoft Clarity

Purpose: Understand how pages are actually used, through heatmaps and session replay.
Data: Page interactions such as scrolling, clicks, and pointer movement, together with device, browser, and approximate location. Text entered into form fields is masked by default and is not captured.
Notes: Operated by Microsoft. See the Microsoft Privacy Statement .
Opt-out: Reject the “Statistics/Analytics” category in Cookie Settings.

6.7 Resend

Purpose: Email delivery for newsletter and contact form notifications.
Data: Subscriber email, optional first name, locale, signup source, signup date; contact-form name/email/message contents.
Notes: Operated in the United States. Underlying delivery via AWS SES. See the Resend privacy policy and Section 11 for international transfers.

6.8 Cloudflare Turnstile

Purpose: Bot protection on our forms.
Data: Browser characteristics and approximate location derived from your IP address; processed by Cloudflare to issue a verification token. Cloudflare does not use this data to identify individuals.
Notes: Cloudflare may process data globally, including in the United States. See the Cloudflare privacy policy and Section 11.

6.9 Other Services

Sanity: Content management and image delivery for the Site.
Google Fonts: Web fonts are requested from Google’s servers, which receive your IP address as part of that request.
Google News / Subscribe with Google: Loaded so that readers can add Japaniche as a preferred source in Google.

These providers and partners may process data outside your country or region (see 11. International Transfers).

7. Advertising and Affiliate Links

The Site is funded by advertising and affiliate commissions. We display advertising through Google AdSense, and some outbound links on the Site are affiliate links.
Affiliate links include links we place deliberately and links that our affiliate partner converts automatically. If you make a booking or purchase through such a link, we may receive a commission at no additional cost to you.
Content produced under a commercial arrangement with a third party is labeled Sponsored or PR.
Advertising and affiliate relationships do not determine our editorial recommendations.
Where consent is required in your region, advertising and affiliate measurement technologies load only after you have consented. You can withdraw consent at any time from Cookie Settings.

8. Disclosures to Third Parties

We do not sell or rent Personal Information. We disclose Personal Information only:

When required by law or pursuant to requests from authorities
To service providers essential to Site operations (analytics, hosting, security, email delivery, bot protection, etc.), under appropriate confidentiality and security obligations
To advertising and affiliate partners that act as independent controllers, to the extent described in Sections 6 and 7 and subject to your consent where required
To protect life, property, or safety when obtaining consent is difficult

For how “sale” and “sharing” are treated under US state privacy law, see Regional Addendum B.

9. Joint Use / Co-Management

We do not jointly use Personal Information with other parties at this time. If that changes, we will update this Policy to describe the scope, items, and responsible party.

10. Retention

We retain Personal Information only as long as necessary for the purposes stated or as required by law.
Analytics user-level data follows GA4 retention settings (2–14 months).
Session replay and heatmap data is retained according to Microsoft’s published retention period for Clarity.
Newsletter subscriber data is retained until you unsubscribe; a minimal record of the unsubscribe is kept so that we can continue to honor your request.
CookieYes consent logs are retained for an appropriate period in line with legal and audit requirements.

11. International Transfers

Service providers and partners we use (e.g., Google, Microsoft, Cloudflare, Resend, Travelpayouts, Sanity) may process data in countries or regions outside your own, including outside the EU/EEA and outside Japan, and in particular in the United States. Where required, we implement appropriate safeguards such as Standard Contractual Clauses (SCCs).

12. Security

We apply technical and organizational measures—access controls, encryption, log monitoring, least-privilege access—to help protect Personal Information against unauthorized access, disclosure, loss, or damage.

13. Children’s Privacy

The Site is not directed to children. We do not knowingly collect Personal Information from children under 13 (or the age of consent in your jurisdiction) without verifiable parental consent. Advertising on the Site is likewise not directed to children.

14. Your Rights

Subject to applicable law, you may have rights to access, correct, delete, restrict or object to processing, obtain data portability, and withdraw consent.

How to exercise: Contact contact@japaniche.org. We may request additional information to verify your identity.

Cookie and advertising choices: Use the Cookie Settings link in the Site footer at any time.

Newsletter unsubscribe: You can opt out of the newsletter at any time using the unsubscribe link included in every newsletter email, or by emailing the contact above. We process unsubscribe requests promptly.

15. Automated Decision-Making

We do not engage in fully automated decision-making that produces legal or similarly significant effects. Where you have consented, the advertising shown to you may be personalized, as described in Section 7.

16. Changes to This Policy

We may update this Policy to reflect operational or legal changes. For material changes, we will provide notice on the Site. The effective date shown at the top of this Policy indicates the current version.

Regional Addenda

A. EU/EEA & UK (GDPR/UK GDPR)

Controller: GROWTH Holdings Inc., Shinjuku Miraina Tower 18F, 4-1-6 Shinjuku, Shinjuku-ku, Tokyo 160-0022, Japan
Contact: contact@japaniche.org
Independent controllers: Google (advertising) and our affiliate partner act as independent controllers for the processing described in Sections 6 and 7.
Supervisory authority: You have the right to lodge a complaint with your local supervisory authority.
International transfers: We implement appropriate safeguards (e.g., SCCs).
Consent management: You can give or withdraw consent via the CookieYes banner and Cookie Settings.

B. California and other US states (CCPA/CPRA)

Categories collected: Identifiers, internet or other electronic network activity information, approximate geolocation, usage history, and inferences drawn from that information.
Purposes: As described in Section 3.
“Sell” or “Share”: We do not sell Personal Information for money. However, because we serve advertising through Google AdSense, Personal Information may be “shared” for cross-context behavioral advertising as that term is defined under California law.
How to opt out: Use the Cookie Settings link in the Site footer and reject the “Marketing” category. This is our “Do Not Sell or Share My Personal Information” mechanism.
Rights: Right to know/access, delete, correct, opt out of sale/share, limit the use of sensitive personal information, and non-discrimination.
Authorized agents: We require proper authorization and identity verification.

C. Japan (APPI)

Business operator: GROWTH Holdings Inc., Shinjuku Miraina Tower 18F, 4-1-6 Shinjuku, Shinjuku-ku, Tokyo 160-0022, Japan
Joint use: Not conducted at present (see Section 9).
Third-party provision: As described in Section 8.
Third-party cookies: Where identifiers are transmitted to third parties such as advertising and affiliate partners, we obtain consent in accordance with the Telecommunications Business Act and the APPI.
Access to retained personal data: Requests may be made as described in Section 14.
Overseas transfers: Upon request, we will provide information about foreign regimes and recipient safeguards consistent with Section 11.