0. Plain-language Summary (Please read first)

• JimoTravel may use your location information and app usage information (behavioral data) in order to suggest ways to avoid crowds and provide tourism information.
• We collect location information only if you allow it on your device. If you withdraw permission, collection will stop.
• The only data we provide to municipalities are aggregated and processed “statistical information” that cannot identify individuals. We do not provide information that can identify individuals to municipalities.
• To provide features such as maps, we may send the information necessary for those features to external services (e.g., map services and reverse geocoding).
• Requests for disclosure, correction, deletion, etc. can be made via “Contact Us” in the Services.

Note: This summary is provided for ease of understanding. The official terms are those set forth in the main text below.

1. Scope

1. This Policy applies to the handling of user information that the Company collects, uses, provides, etc. in connection with the use of the Services.
2. With respect to the handling of information in third-party services linked from the Services (e.g., partner business sites, external map services), the terms and privacy policy of the relevant third party will apply.

2. Definitions

Unless otherwise specified by context, the terms used in this Policy have the meanings set forth below.

1. Personal Information: Information relating to a living individual that can identify a specific individual by name, email address, etc., or that can readily be matched with other information to identify a specific individual.
2. Personal Data: Personal information that the Company has organized so that it can be searched (i.e., that constitutes a personal information database, etc.).
3. Retained Personal Data: Personal data over which the Company has the authority to disclose, correct, suspend use, etc.
4. Location Information: Information regarding a user’s current location and its history obtained via device GPS, etc.
5. Behavioral Data: Information regarding how a user uses the Services, such as views, searches, taps, dwell-time patterns, check-ins, etc. within the Services.
6. Statistical Information: Information that has been anonymized, aggregated, and processed so that individuals cannot be identified (e.g., aggregated congestion trends by area and time period).
7. Partner Municipalities: Municipalities that collaborate with the Company to achieve the purposes of the Services (e.g., congestion reduction and dispersed tourism).
8. Partner Businesses: Stores, facilities, and other businesses that provide coupons, etc. within the Services.

3. Information We Collect

To the extent necessary to provide the Services, we collect the information described below. Whether we collect such information depends on the user’s settings, the device’s permission status, and usage status.

3.1 Information You Enter or Provide

• Account-related information: email address, nickname, etc.
• Profile and settings information: language settings, date of birth, gender, interests and preferences, and other in-app settings.
• Inquiries and surveys, etc.: inquiry details, responses, feedback, etc.

Note: During initial registration or setup, the Services may ask you to register information such as language settings, date of birth, gender, and interests/preferences.

3.2 Information Collected Through External Authentication (Google / Apple)

If you register or log in using external authentication (e.g., Sign in with Google, Apple ID), we may obtain the following from the external authentication provider to the extent provided to us:

• Email address
• Display name (used as an initial value for your nickname, etc.)

Note: The authentication method and the items collected may vary depending on the specifications of your device and the provider.

3.3 Information Automatically Collected from Your Device

• Location information (real-time and history): used for congestion analysis and avoidance suggestions, etc.
• Device information: OS, device type, app version, language settings, IP address, etc.
• Device identifiers, etc.: used to detect device changes and prevent fraud (e.g., device ID, etc.).
• Usage logs: operation history, logs of views/searches, error information (crash logs, etc.).

Note: The Services are designed such that whether location information is collected may change depending on your status (e.g., collected while logged in, not collected while logged out).

3.4 Posted Information (Travel Logs, etc.)

If you post or save travel logs, etc., we handle the following:

• Photos, videos, text, comments, stickers, etc.
• Information on places you visited and itinerary-related information.
• Sharing settings (recipients, issuance/expiration of shared QR codes, etc.).

Note: Travel logs may include features such as registering photos/videos, sharing with other users, and viewing/downloading by the recipient.

4. Purposes of Use

We use the information we collect for the following purposes.

• 11. Provision and operation of the Services
  • Providing tourism information, map display, route suggestions, visualization of congestion status, and suggestions to avoid crowds
  • Creating, saving, and sharing travel logs; providing comments, stickers, etc.
• 12. Analysis for congestion reduction and dispersed tourism
  • Understanding congestion trends using location information/behavioral data, generating congestion forecasts, and improving avoidance suggestions
• 13. Account management, identity verification, and security
  • Login authentication, detecting device changes, preventing unauthorized use, and responding to violations of the Terms of Use
  • Sending one-time passwords, etc. (if necessary)
• 14. Handling inquiries and important notices
  • Responding to inquiries, contacting users regarding important matters, and notifying outages/maintenance information
• 15. Service improvement and quality enhancement
  • Usage analysis, incident analysis, UI/UX improvements, and planning/development of new features
• 16. Policy planning and effectiveness measurement by partner municipalities (statistical information only)
  • Considering measures for congestion reduction and regional dispersion and measuring effectiveness using statistical information aggregated/processed so that individuals cannot be identified (see Section 6 for details)
• 17. Providing coupons, points, incentives, etc. (including future provision)
  • Granting and eligibility determination, fraud prevention, and understanding usage status

5. Handling of Location Information (Important)

• 18. We collect location information, within the scope you have permitted in your device settings, for purposes such as providing suggestions to avoid crowds.
• 19. Collection of location information is controlled by your device’s location settings (permission on/off, accuracy, permission for background access, etc.).
• 20. The Services may be designed to control whether location information is collected depending on your status (e.g., logged in/logged out).
• 21. You can stop the collection of location information at any time using the following methods:
  • Turn off location permission for this App in your device settings.
  • Log out of this App (the Services are designed such that location information is not collected while logged out).
• 22. Location information may include inaccuracies due to GPS accuracy, network conditions, etc.

6. Provision of Information to Municipalities (Statistical Information Only)

• 23. We may provide information to Partner Municipalities to the extent that it contributes to the purposes of the Services (mitigating overtourism, avoiding congestion, and promoting dispersed tourism).
• 24. Information provided to Partner Municipalities is limited to statistical information that cannot identify individuals.
  • We provide information only after anonymizing, aggregating, and processing location information/behavioral data, etc. so that individuals cannot be identified.
  • We do not provide Personal Information (Personal Data) to municipalities (except where required by laws and regulations).
• 25. We require Partner Municipalities not to re-identify (i.e., infer or identify individuals) the statistical information we provide, and not to allow third parties to re-identify it.
• 26. If statistical information we create/provide falls under “Anonymized Processed Information” or similar categories under applicable laws, we will take necessary measures in accordance with Japan’s Act on the Protection of Personal Information (e.g., preparing required public disclosures).

7. Provision to Third Parties (In Principle, We Do Not)

• 27. We do not provide users’ Personal Data to third parties without the user’s consent.
• 28. However, this does not apply in the following cases:
  • (1) When required by laws and regulations
  • (2) When necessary to protect a person’s life, body, or property and it is difficult to obtain the user’s consent
  • (3) When particularly necessary to improve public health or promote the healthy development of children and it is difficult to obtain the user’s consent
  • (4) When cooperation with a national government body, local government, etc. is necessary and obtaining consent may hinder the relevant affairs
  • (5) When provided in connection with business succession (merger, company split, transfer of business, etc.)
• 29. Note: As described in Section 6, information provided to Partner Municipalities is limited to statistical information that cannot identify individuals.

8. Outsourcing

To the extent necessary to operate the Services, we may outsource work such as cloud operations, data analytics infrastructure, delivery infrastructure, and map functionality to external service providers.
When selecting contractors, we will enter into appropriate contracts and provide necessary supervision in accordance with Japan’s Act on the Protection of Personal Information so that necessary and appropriate security measures are implemented.

9. Use of External Services (Maps, Reverse Geocoding, etc.)

To improve convenience, the Services may use external services for map display, route display, spot information display, reverse geocoding, etc. (e.g., Google Maps-related services, reverse geocoding services).
In such cases, the following information may be sent to the external service provider to the extent necessary to provide the relevant functions:

• Location information (latitude/longitude, etc.)
• Device information (OS, device type, etc.)
• Usage logs (request information, error information, etc.)

The handling of information by the external service provider is governed by that provider’s privacy policy, etc.

10. International Data Transfers

If the servers of external service providers or contractors are located outside Japan, user information may be stored and processed outside Japan.
In accordance with Japan’s Act on the Protection of Personal Information, we will implement appropriate supervision of contractors/recipients, contractual measures, and other necessary security measures.
If we are required by law to disclose information related to international transfers, we will provide such information within a reasonable scope (please use the in-app inquiry channel).

11. Retention Period

We retain collected information for the period necessary to achieve the purposes of use, or for the period required by applicable laws and regulations, and thereafter delete or anonymize it using appropriate methods.
The handling upon withdrawal (account deletion) is described in Section 14.

12. Security Measures

We take necessary and appropriate measures to prevent leakage, loss, or damage of the information we handle and to otherwise ensure safe management. The main measures are as follows (details are partially undisclosed for security reasons).

• Organizational security management: authority management, internal rules, audits/ inspections, management of contractors
• Human security management: education/training, ensuring confidentiality obligations
• Physical security management: management of equipment/media, entry/exit control, etc.
• Technical security management: access controls, protective measures such as encryption, vulnerability countermeasures, log monitoring, etc.

13. Requests for Disclosure, etc. (User Rights)

Pursuant to Japan’s Act on the Protection of Personal Information, users may make the following requests regarding retained personal data held by the Company:

• Notification of the purpose of use
• Disclosure
• Correction, addition, or deletion
• Suspension of use or deletion
• Suspension of provision to third parties
• Disclosure of records of provision to third parties (where applicable under law)

How to make a request:

• Contact us via “Contact Us” in this App, and state that your inquiry is a “request regarding personal information.”
• We may ask you to verify your identity in a manner specified by the Company.
• Fees are generally free of charge. However, if actual costs such as postage are incurred, we may notify you in advance and ask you to bear such costs.

14. Withdrawal (Account Deletion) and Handling of Data

Users may withdraw (delete their account) via the prescribed procedure within this App.
After withdrawal, we will in principle delete data linked to the user, and it may not be recoverable (however, we may retain it for a certain period to the extent necessary for legal compliance, fraud prevention, dispute resolution, etc.).
If you had been sharing travel logs, after withdrawal the recipient may no longer be able to view them, and display/provision may be restricted.

15. Use by Minors

In principle, the Services are intended for users aged 18 or older. If we become aware that we have collected information from a person under 18, we may take appropriate measures (such as suspending use or deleting the information).

16. Changes to This Policy

We may change this Policy when necessary due to amendments to laws and regulations, changes to the Services, security improvements, etc.
In the event of important changes, we will endeavor to provide notice in an easy-to-understand manner, such as in-app notifications or posting on the web.

17. Contact

For inquiries, complaints, and requests for disclosure, etc. regarding the handling of personal information, please contact us as follows:

• Business name: Besupura Co., Ltd.
• To: JimoTravel Personal Information Inquiry Desk
• Address: Exa Space 3C, 5-18-10 Jingumae, Shibuya-ku, Tokyo, Japan
• Contact: info@jimotravel.jp (recommended)

18. Language (For International Tourists)

The official text of this Policy is Japanese. We may provide translations (English, Traditional Chinese, Simplified Chinese, Korean, etc.), but such translations are provided for reference only and the Japanese version will prevail.