Privacy Policy

D2C X Inc., (hereinafter “the Company”) will collect and utilize personal information such as the name, address, telephone number and e-mail address of its customers and persons employed that can identify an individual person for the operation of tsunagu Japan Travel (hereinafter “the Site”). The company is aware that the protection of customer personal information is an important duty, and has established this policy based on the Personal Information Protection Law to fulfill this duty.

The Company will comply with the Personal Information Protection Law and other related laws, and appropriately handle personal information, and will constantly strive to improve its handling of personal information.

All executive officers and employees of the company are familiarized with the duty of handling personal information.

When collecting personal information, the purpose of the use of the information will be specified and notified, and the personal information will be handled in line with the purpose of use.

In order to prevent the leakage, loss, alteration etc. of the personal information, the company will establish the necessary measures and carry out appropriate management of the information.

The Company will accept requests from its customers for the disclosure or deletion of the personal information held by the Company through prescribed methods, and respond to these requests in good faith.

Purpose of Use of the Personal Information

The purpose of use of the personal information is established as outlined below. The personal information will not be used for any purposes other than those outlined below.

  • In order for Users to be able to use the services smoothly.
  • In order to create statistical data about the usage of the Services.
  • In order to ship prizes from campaigns etc. or products.
  • For the participation in or invitation to questionairres, interviews or campaigns.
  • In order to announce information regarding the Services etc. or advertising or other information from advertising sponsors other than the Company in the form of mail magazines etc.
  • In order to communicate important information about the Service where necessary.
  • To respond to inquiries.

Limitations regarding the provision of personal information

The Company will not handle personal information in any way that exceeds the purpose of use without the permission of the customer, excluding cases where it is allowed in the Personal Information Protection Law and other laws, excluding the following cases.

  • In cases based on the law.
  • In cases where it is necessary to protect the lives, health or assets of a person, but acquiring the permission of the User is difficult.
  • In cases where it is necessary to improve public health or promote the sound development of children, but acquiring the permission of the User is difficult.
  • In cases where it is neessary to cooperate with the government organzsations or regional public organizations or persons that have been entrusted by these organizations to carry out work determined by the law, and that by acquiring the persmission of the User may cause hindrance to the execution of this work.

Changes to the purpose of use of personal information

The Company may change the purpose of use of the personal information within related and reasonable limits. In the case where the purpose of use is changed, Users will be notified and the changes announced.

Disclosure and provision to third parties

As a rule, the Company will not disclose personal information received from the Users to third parties. However, under the following cases, the Company can provide the personal information from Users without the agreement of the User to a degree that does not violate related laws.

  • Cases where it has been determined that the third party will not bring any disadvantage to the User.
  • In cases where the disclosure of personal information is requested by the court, police or other organizations holding similar authority.
  • In cases where the disclosure or provision is permitted by law.

Shared usage of information

In cases where it is necessary for the Company to carry out work in collaboration with business partners in providing the Service to the Users, the Users’ personal information may be jointly used with those business partners. In these cases, the Company will jointly use the information after announcing the name of the business partner, type of business and manager’s title.


Regarding the acquisition of the Users’ personal information by third parties outlined below, the Company accepts no responsibility, including for financial or emotional harm, and in the case of a dispute, it must be solved by the concerned business and User, and the Company will not act as an intermediary.

  • In the case the User has provided their personal information to a business or individual met through the Site, regardless of intention or error.
  • In the case a business or individual published on the Site has disclosed or leaked the information of a User met through the Site, regardless of intention or error.
  • In the case the e-mail address, ID, password etc. of a User has been acquired by a third party.
  • In the case of the leak of personal information is due to a natural disaster, communications failure, breakdown, unauthorized access, hacking, virus, or other eventuality.

Changing and deletion of personal information

Users can view, change and if required delete their personal information registered on the Site. In the case that a member requires the deletion of their personal information, it will be handled as withdrawal of membership, and the member can speedily request the deletion of their personal information by contacting the the contact specified by the Company.

Accuracy of personal information

The Users must judge the accuracy and recency of content provided on the Site themselves.

About the management of personal information

In order to prevent the loss, misappropriation, or alteration of personal information acquired by the site, the Company is carrying out appropriate security measures. Specifically, by using SSL encrypted transmission and limiting access rights controls to the personal information database, the Company is securely storing the data.

About identity verification

In response to requests for the disclosure, change or deletion of personal information, the Company will confirm the identity of the User through information that can discern the identity of the User. The Company does not accept responsibility for cases where a third party has acquired and used information that can identify the User.

Changes to the Privacy Policy

As the purpose of the policy is to appropriately manage and protect personal information, the Company can change the policy at any time. At the time the changed content of policy is published on the Site, it will be assumed that all Users and members agree to the changed policy.

Cookie Policy

About the use of cookies

For part of this website’s contents, cookies are used to improve our services and tailor them to our readers.

What is a cookie?

A cookie is a function that enables us to store information regarding your visits to our website on your computer (and other devices that can connect to the Internet, such as smartphones and tablets). By using cookies, we can obtain information on facts like the number of times you have visited a page and what pages you have visited on the computer you are using. The information obtained from using cookies do not include personal information that can identify you.

Additionally, as mentioned below, by changing the settings on your browser, you can disable cookies. However, please note that by disabling cookies, you may not be able to fully utilize the services on our website.

Analysis of website visits

This website uses Google Analytics – a web analytics service offered by Google. Google Analytics is used to analyze how the user interacted with this website through cookies issued by us. We receive the results of the analysis from Google in order to better understand how our readers interact with this website. Furthermore, of the information collected, recorded, and analyzed by Google Analytics, there is no personal information that can identify the individual.

Providing advertisements using cookies

We use advertisement services by advertisement network operators, such as Google and Facebook, as well as other advertisement agencies with whom we are partnered, to deliver advertisements when a user who has visited this website in the past visits a specific page. In such cases, cookies are used to retrieve information on your web browsing history regarding this website.

If you do not wish to receive such advertisements, visit the following websites and disable the use of cookies for each site.

Google opt out page:

Facebook opt out page:

Most web browsers automatically allow the use of cookies, but as mentioned above, it is possible to change your settings to forbid the use of cookies when needed. This can generally be found under the options or settings menu of your browser. For further information on changing your cookies setting, follow one of the links below or use your browser’s help option.

For Chrome:

For Microsoft Edge:

For Firefox:

For Safari:

If you have not changed your browser settings, by using this website, you are agreeing to the use of cookies by this website. If you do not agree to the use of cookies, you must change the settings of your browser.


In case of any inquiries regarding the privacy policy and cookie policy, or any questions, complaints or consultation regarding the handling of personal information in the Services, please contact the Company via the inquiry form.

Manager in charge of Personal Information

The personal information consultation contact (for registered information deletion and withdrawal of membership) and the manager in charge of personal information is the president of the Company.

Updated on 25. May 2018

D2CX Privacy Policy for GDPR

1. Our Privacy Statement

The protection of your personal data is of great importance to D2CX Inc (hereinafter “Us/We”). This privacy policy (hereinafter the “Policy”) therefore intends to inform you about how the D2CX Inc entities, acting as data controller, collect and process your personal data that you submit or disclose to us. We also act as data controller when we process your personal data received or obtained through third parties. We process this personal data in accordance with the applicable EU and Member State regulations on data protection, in particular the General Data Protection Regulation No 2016/679 (the “GDPR”).

This Policy concerns the handing of personal information subject to GDPR and is presented in addition to the “D2CX Privacy Policy.”

We encourage you to read this Policy carefully. If you do not wish your personal data to be used by us as set out in this Policy, please do not provide us with your personal data. Please note that in such a case, we may not be able to provide you with our services, you may not have access to and/or be able to use some features of, and your customer experience may be impacted.

2. How Do We Use Your Personal Data?

We will always process your personal data within the legal bases stipulated in the GDPR(Articles 6 and 7) by obtaining your consent, where it is necessary for the conclusion of a contract, or where there is a legitimate interest.

We may collect and process your personal data for the purposes below, which are required so that we can pursue our legitimate interests and provide you with adequate services and products:

  • to notify you about changes to our service(s);
  • to manage your customer account;
  • to provide you products and services;
  • to inform you about our policies and terms;
  • to promote safety and security, such as by monitoring fraud and investigating suspicious or potentially illegal activity or violations of our terms or policies;
  • to provide, improve, and develop our products, services, and advertising;
  • to use personal information for purposes such as data analysis, research, and audits;

Also, subject to obtaining your express prior consent, we may also collect and process your personal data for the following purposes:

  • to provide you with information which we feel may be of your interest;
  • to jointly use your personal data with third parties(partner companies) who may provide you with information about their products and services.
  • for conducting business analysis.

Please be aware that you are entitled to withdraw your consent at any time, without affecting the lawfulness of processing based on your consent before withdrawal thereof.

We will only process your data for these specified and legitimate purposes, and will not further process the data in a way that is incompatible with these purposes. If we collect personal data for one purpose and later plan to use it for a different purpose, we will always inform you of the changed purpose. We will only keep your personal data for as long as it is necessary for us to comply with our legal obligations, ensure that we provide an adequate service, and to support our business activities.

3. What Types of Personal Data Do We Use?

For the purposes specified under this Policy, we may collect the following categories of personal data:

  • Name
  • Home Address
  • Email address
  • Telephone number
  • Online identifiers (IP address / cookie identifiers)

4. Disclosure of Personal Data with Third Parties

In accordance with GDPR, we may disclose your personal data within D2C Group(,or subject to your prior consent, your personal data may be transferred to, stored by, and processed by partner companies who jointly provide our services with us and who have an appropriate contractual relationship with us to assist us in marketing to our customers. We will only disclose your personal data to our partners for the purposes of providing our services, advertising, and improving these processes.

When disclosing your personal data to the data processor, we will enter into an appropriate data processing agreement with that data processor. Furthermore, if we disclose your personal information to an organization outside the EEA, we will comply with the appropriate legal framework covering the transfer and processing of such data, i.e., customer consent, European Commission sufficiency certification, or standard contractual clauses between controllers approved by the European Commission, to ensure that we perform extraterritorial transfers of personal data lawfully.

5.Legal Compliance and Security

It may be necessary for us – by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence – to disclose your personal data. We may also disclose your personal data if we determine that, due to purposes of national security, law enforcement, or other issues of public importance, the disclosure is necessary or appropriate.

We may also disclose your personal data if we determine in good faith that disclosure is reasonably necessary to protect our rights and pursue available remedies, enforce our terms and conditions, investigate fraud, or protect our operations or users.

6. Security Measures

We process your personal data in a manner that ensures their appropriate security, including protection against unauthorized or unlawful processing, accidental loss, destruction, or damage. We use appropriate technical or organizational measures to achieve this level of protection.

We will retain your personal information for as long as it is necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted by law.

In case of doubt, we will contact the competent Data Protection Supervisory Authority in order to obtain their advice and recommendations.

7. Your Rights

You have the following rights regarding personal data collected and processed by us.

Information regarding your data processing: You have the right to obtain from us all the requisite information regarding our data processing activities that concern you.
Access to personal data: You have the right to obtain from us confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, access to the personal data and certain related information.
Rectification or erasure of personal data: You have the right to obtain from us the rectification of inaccurate personal data concerning you without undue delay, and to complete any incomplete personal data. You may also have the right to obtain from us the erasure of personal data concerning you without undue delay, when conditions laid out in the GDPR are met.
Restriction on processing of personal data: You may have the right to obtain from us the restriction of processing of personal data, when conditions laid out in the GDPR are met.
Objecting to processing of personal data: You may have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you, when conditions laid out in the GDPR are met. Data portability of personal data: You may have the right to receive your personal data in a structured, commonly-used and machine-readable format, and have the right to transmit such data to another controller without our hindrance, when conditions laid out in the GDPR are met.
Not to be subject to automated decision-making: You may have the right not to be subject to automated decision-making (including profiling) based on the processing of your personal data, insofar as this produces legal or similar effects on you, when conditions laid out in the GDPR are met.
If you intend to exercise such rights, please refer to the contact section.

If you are not satisfied with the way in which we have proceeded with any request, or if you have any complaint regarding the way in which we process your personal data, you may lodge a complaint with a Data Protection Supervisory Authority.

8. Children

We do not knowingly collect and process information on children under sixteen (16) without the permission and consent of their parent(s). If we discover that we have collected and processed the personal data of a child under sixteen (16) or the equivalent minimum age depending on the concerned jurisdiction as laid out in the GDPR, we will take steps to delete the information as soon as possible. If you become aware that a child under sixteen (16) has provided us with personal data directly, please contact us immediately by using the contact address specified under this Policy.

9. Links to Other Sites

We may propose hypertext links from the website on which this policy is stated to third-party websites or internet sources. We do not control and cannot be held liable for third parties’ privacy practices and content. Please carefully read their privacy policies to find out how they collect and process your personal data.

10. Updates to This Policy

We may revise or update this Policy from time to time. Any changes to this Policy will become effective upon posting of the revised Policy. If we make changes which we believe are significant, we will inform you through the Website to the extent possible and seek your consent where applicable.

For any questions or requests relating to this Policy, please contact us using the information below.
Tokyo Shiodome Building, 1-9-1, Higashi Shimbashi, Minato-ku, Tokyo 105-7313
Email:[email protected]

D2CX Inc.
Yasuhiro Nakanishi, Representative Director
Established on October 19, 2022

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