Legal
Privacy Policy
How we collect, use, and protect your personal data.
Kokoro Co., Ltd. (“Kokoro”, “we”, “our”) respects the privacy of individuals who visit our website and interact with us in the course of business. This Privacy Policy explains what personal data we collect, why we collect it, how we use it, and your rights in respect of it.
We operate primarily under Japanese law (Act on the Protection of Personal Information, “APPI”) and comply with applicable data protection requirements in the jurisdictions in which our clients are based, including the EU General Data Protection Regulation (“GDPR”) where relevant.
1. Data we collect
We collect personal data in the following circumstances:
- Website enquiry forms: Name, email address, company name, and the content of your message when you submit a contact form on this website.
- Business communications: Contact details, correspondence, and professional information exchanged in the course of a client relationship or a prospective engagement.
- Website usage data: Technical data collected automatically via cookies and similar technologies, including IP address, browser type, pages visited, and session duration. See our Cookie Policy for full details.
- Event and meeting data: Name, company, and contact details when you attend a Kokoro event or meet our advisers in a professional context.
We do not collect sensitive personal data (such as health information, ethnic origin, or political opinions) and do not seek it in our standard business interactions.
2. How we use your data
We use the personal data we collect for the following purposes:
- Responding to your enquiries and conducting initial scoping conversations.
- Managing client engagements, including communication, scheduling, and delivery of advisory services.
- Maintaining records required by applicable law or professional obligations.
- Improving the quality and usability of our website.
- Sending service-related communications where you are an existing or prospective client. We do not send unsolicited marketing materials.
3. Legal basis for processing
Where the GDPR or equivalent legislation applies, we rely on the following legal bases:
- Legitimate interests: Responding to business enquiries, managing client relationships, and improving our services.
- Contract performance: Processing necessary to perform services under a client agreement.
- Legal obligation: Retaining records as required by Japanese law or other applicable regulations.
- Consent: For optional cookies and analytics. You may withdraw consent at any time via our Cookie Policy page.
4. Data retention
We retain personal data only as long as necessary for the purpose for which it was collected or as required by law. Specifically:
- Enquiry records (no engagement commenced): deleted within 24 months of last contact.
- Client engagement records: retained for 7 years from the close of the engagement, in accordance with Japanese commercial and tax law.
- Website analytics data: aggregated and anonymised after 26 months.
5. Sharing your data
We do not sell, rent, or trade personal data. We may share data in limited circumstances:
- Service providers: Trusted suppliers who assist us in operating our website and business systems (e.g. cloud hosting, email services), under contractual obligations of confidentiality and data protection.
- Legal requirements: Where disclosure is required by Japanese law, court order, or regulatory authority.
- Professional advisers: Lawyers, accountants, and auditors bound by professional confidentiality obligations.
6. International transfers
Our primary operations are in Japan. Personal data may be transferred to service providers operating in other countries. Where such transfers involve data from individuals in the European Economic Area or the United Kingdom, we implement appropriate safeguards (such as Standard Contractual Clauses) to ensure equivalent protection.
7. Your rights
Depending on your location and applicable law, you may have the following rights in respect of your personal data:
- Access to the personal data we hold about you.
- Correction of inaccurate or incomplete data.
- Deletion of your data, subject to legal retention obligations.
- Restriction of or objection to processing in certain circumstances.
- Data portability (where the legal basis is consent or contract).
- Withdrawal of consent at any time, without affecting the lawfulness of processing prior to withdrawal.
To exercise any of these rights, please contact us at sales@koroko-coltd.com. We will respond within 30 days.
8. Security
We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or disclosure. These include access controls, encrypted communications, and regular review of our data handling practices. No transmission over the internet is wholly secure; we take reasonable steps to protect data but cannot guarantee absolute security.
9. Cookies
Our website uses cookies. For detailed information on what cookies we use and how to manage them, please read our Cookie Policy.
10. Children
Our website and services are directed at business professionals and organisations. We do not knowingly collect personal data from individuals under 18 years of age. If you believe we have inadvertently received data from a minor, please contact us immediately.
11. Changes to this policy
We may update this Privacy Policy periodically. When we make material changes, we will update the “Last updated” date at the top of this page. We encourage you to review this page periodically. Continued use of our website following any update constitutes acceptance of the revised policy.
12. Contact
For questions, requests, or complaints regarding this Privacy Policy or our data practices, please contact:
- Email: sales@koroko-coltd.com
- Post: Kokoro Co., Ltd., 7-16 Takara-cho, Naka-ku, Hiroshima City, Hiroshima Prefecture 730-0044, Japan
- Tel: 082-250-0117
If you are located in the EU or UK and are not satisfied with our response, you have the right to lodge a complaint with your local data protection supervisory authority.