HavenJapan K.K. · Last revised: 14 October 2026

This policy applies when we handle personal data of people in the European Economic Area, the United Kingdom or Switzerland, under the EU General Data Protection Regulation (GDPR), the UK GDPR and the Swiss Federal Act on Data Protection. It adds to our main Privacy Policy (https://havenjapan.com/privacy-policy/), which describes what we collect, who we share it with, how we keep it safe and how long we keep it. Where the two differ, this policy applies to you.

1. Controller

HavenJapan K.K. (HavenJapan株式会社), 5-9-15 Kamiuma, Setagaya-ku, Tokyo 154-0011, Building C, Japan. Corporate number 3010901057564. Representative Director: Elie Corbex. Contact: [email protected] · +81 3 6821 5356.

We have not appointed a data protection officer, as we are not required to. For any question about your data, write to [email protected].

2. What we use, why, and on what legal basis

What we do	Data	Legal basis
Answer your enquiry, prepare a proposal	Contact details, trip wishes, correspondence	Steps at your request before a contract (Art. 6(1)(b))
Take, run and look after your booking, including sharing details with hotels, guides, drivers and other providers of the services you book	Names of the party, contact details, travel details, children's ages, licence details for motorcycle days	Performance of our contract with you (Art. 6(1)(b))
Plan your trip safely around your health, allergies, dietary or access needs	Health and other special-category data you give us	Your explicit consent (Art. 9(2)(a)), which you can withdraw at any time; where needed to protect your life in an emergency, vital interests (Art. 9(2)(c))
Take payments, issue invoices, keep accounting and tax records	Payment and invoice data	Legal obligation under Japanese law (Art. 6(1)(c)) and contract (Art. 6(1)(b))
Handle complaints, claims and payment disputes	Booking records, correspondence, payment records	Our legitimate interest in defending our rights (Art. 6(1)(f))
Send news and offers about our journeys	Name, e-mail	Your consent, or, if you have booked with us, our legitimate interest in writing to past clients about similar journeys; you can object at any time (Art. 21(2))
Use photographs of you in our promotion	Photographs	Your consent (Art. 6(1)(a))
Statistics and advertising cookies	Device and browsing data	Your consent through the cookie banner (Art. 6(1)(a))

Where we rely on legitimate interest, we have weighed it against your interests; you can ask us for that assessment. Giving us your contact and travel details is needed to make a booking; without them we cannot provide the tour. We do not make decisions about you based solely on automated processing.

3. Transfers outside the EEA, UK and Switzerland

We are based in Japan. The European Commission has decided that Japan ensures an adequate level of protection for personal data transferred from the EEA (Decision (EU) 2019/419), and the United Kingdom recognises Japan in the same way. Data you send us from the EEA or the UK is therefore protected on arrival without further safeguards. Switzerland has not made the same decision for Japan: if you are in Switzerland, the data you send us is transferred to Japan because it is needed to conclude and perform your contract with us (Art. 17(1)(b) of the Swiss Federal Act on Data Protection), and is then protected as described in these policies.

Some of our service providers handle data in other countries, listed in section 5 of the main Privacy Policy. For transfers to the United States, we rely on the provider's certification under the EU-U.S. Data Privacy Framework (and its UK and Swiss extensions) where it has one, and otherwise on the European Commission's standard contractual clauses. For other countries we rely on an adequacy decision or on standard contractual clauses. You can ask us for a copy of the relevant safeguards.

Hotels, guides and other providers of the services you book in Japan receive your data because it is needed to perform your contract with us (Art. 49(1)(b)).

4. How long we keep it

As set out in section 8 of the main Privacy Policy. In short: booking and accounting records for 7 years after the end of the financial year, as Japanese tax law requires; correspondence and preferences for 3 years after your last trip; health, dietary and access information no longer than 6 months after your trip, unless needed for a claim.

5. Your rights

You have the right to:

• access your data and receive a copy (Art. 15);
• have inaccurate data corrected (Art. 16);
• have your data erased (Art. 17);
• restrict how we use it (Art. 18);
• receive the data you gave us in a portable format (Art. 20);
• object to processing based on legitimate interest, and to direct marketing at any time (Art. 21);
• withdraw your consent at any time, without affecting what was done before.

Write to [email protected]. We answer within one month, free of charge.

You also have the right to complain to a data protection supervisory authority, in particular in the country where you live or work: in the EEA, your national authority (list at https://www.edpb.europa.eu/about-edpb/about-edpb/members_en); in the UK, the Information Commissioner's Office (ico.org.uk); in Switzerland, the Federal Data Protection and Information Commissioner (edoeb.admin.ch). We would be grateful for the chance to resolve your concern first.

6. Cookies

Our cookie banner asks for your consent before any statistics or advertising cookies are set, and you can change your choice at any time. Details are in section 9 of the main Privacy Policy.

7. Changes

We may update this policy. The date at the top shows when it was last changed. If a change affects how we use data you have already given us, we will tell you before it applies.

8. Language

This policy is written in English. If it is translated, the English version prevails.

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HavenJapan K.K. · 5-9-15 Kamiuma, Setagaya-ku, Tokyo 154-0011 · [email protected]