Privacy Policy for Europe
This privacy policy (“Privacy Policy for Europe”) explains how Ashirase, Inc. (the “Company”) may process personal data of data subjects in the European Economic Area (the “EEA”).
This Privacy Policy for Europe applies to the personal data of data subjects in the EEA that the Company processes. This Privacy Policy for Europe shall apply together with the Company’s Privacy Policy, but the former shall prevail over the latter to the extent that these policies contradict.
1. Personal data collected
The Company may collect and process personal data from the following sources in the course of its activities:
(1) Information You Provide
• Information required for account registration
In order to register an account and use the services provided by the Company (the “Services”), you must provide the following information to the Company and set a password. If such information is not provided, the Company will not be able to provide the Services.
- Email address
- Telephone number
- Date of birth
- Walking method (e.g., white cane, guide dog, etc.)
- Intended use scenarios
- Expected frequency of use
• Other member information
The Company may receive the following information from members:
- Profile information such as name (including nickname), date of birth and similar information
- Contact information such as telephone number and address
- Still image information including portrait images
• Information collected based on a member’s specific consent
The Company may collect the following information based on a member’s specific consent:
- Location information
- Camera images and video footage (collected for the purpose of correcting location information and deleted immediately after location estimation)
- VPS location information
(2) Information We Collect Automatically
• When you use the Services, the Company automatically collects the following information:
- Referrer information and IP address
- Server access log information
- Identifiers such as Cookies, ADID and IDFA
- Navigation usage history (provided that the Company obtains the user’s permission before accessing such history)
• The following information is automatically collected through the Company’s website:
- Visitors’ cookies, device information, software information and record of access to the Company’s website
(3) Information Obtained from Third Parties
- Information provided through integrations with external services: IDs used for external services and information that is permitted to be disclosed pursuant to privacy settings of such external services
- Information provided by delivery companies, system providers and other vendors: customer attributes, transaction and purchase history, and information relating to interactions with online content
- Information provided by the Company’s distributors: customer ID, name, contact information, place of use, walking history and other usage information
2. Purposes and legal basis of processing
The purposes for which the Company processes personal data and the primary legal bases for such processing are as follows:
Contact information of members, including name, nickname, email address, telephone number, password and date of birth
Purpose: Identity verification, member registration, account management, authentication, provision of the Services, communications relating to the Services, responding to inquiries, member support, and sharing location data with third parties designated by the user
Legal basis: Performance of a contract
Profile information such as occupation, still image information including portrait images, and other information voluntarily provided by members
Purpose: Management of member information, member support, responding to inquiries, and improvement of the usability of the Services
Legal basis: Consent of the data subject; Legitimate interests in properly providing and improving the Services
Walking method, intended use scenarios, expected frequency of use, and other information provided in connection with the use of the Services
Purpose: Provision of the Services, provision of functions tailored to members' usage conditions and needs, support, service improvement, and enhancement of safety and usability
Legal basis: Performance of a contract; Explicit consent of the data subject (where such information constitutes special categories of personal data under the GDPR); Legitimate interests in improving the functionality and safety of the Services
Location information, VPS location information, and information relating to use of the Services
Purpose: Determination of current location, route guidance to destinations, provision of walking assistance functions, correction of location information, improvement of positioning accuracy, enhancement of safety and usability of the Services, and sharing location information with third parties designated by the user
Legal basis: Consent of the data subject; Performance of a contract; Legitimate interests in improving the functionality and safety of the Services
Camera images and video footage
Purpose: Correction of location information, location estimation, provision of walking assistance functions, and improvement of accuracy
Legal basis: Consent of the data subject; Performance of a contract
Referrer information, IP address, server access log information, identifiers such as Cookies, ADID and IDFA, device information, software information, and records of access to the Company's website
Purpose: Provision, display and maintenance of the Services and website, access analysis, understanding usage status, troubleshooting, ensuring security, prevention of unauthorized access and misuse, improvement of the Services and website, and measurement of advertising and marketing effectiveness
Legal basis: Consent of the data subject; Legitimate interests in operating and improving the Services and website safely and appropriately
IDs used for external services and information permitted to be disclosed under privacy settings of external services
Purpose: Integration with external services, login and authentication, provision of integration functions, and enhancement of member convenience
Legal basis: Consent of the data subject; Performance of a contract; Legitimate interests in pursuing the Company's business
Customer attributes, transaction and purchase history, and information relating to interactions with online content provided by delivery companies, system providers and other vendors
Purpose: Provision of products and services, management of purchases and transactions, delivery, responding to inquiries, customer support, analysis of usage, and service improvement
Legal basis: Performance of a contract; Compliance with relevant legal obligations; Legitimate interests in transaction management, support and service improvement
Information provided by the Company's distributors
Purpose: Provision of products and services, management of purchases and contracts, delivery, warranty services, responding to inquiries, after-sales services, and coordination with distributors
Legal basis: Performance of a contract; Compliance with relevant legal obligations; Legitimate interests in managing sales and service operations and providing support to members
All personal data set out above
Purpose: Protection of the rights of the Company and data subjects
Legal basis: Compliance with relevant legal obligations; Legitimate interests in pursuing the Company's business
Information regarding walking methods and other information provided by members in connection with the use of the Services may constitute information relating to health conditions, disabilities, or other special categories of personal data under the GDPR. Where such information constitutes special categories of personal data, the Company will process such information only where the data subject has provided explicit consent or where processing is otherwise permitted under Article 9(2) of the GDPR.
3. Cookies
(1) Types of Cookies and Legal Basis
The Company’s website uses the following categories of cookies:
• Strictly Necessary Cookies
Purpose: Functions essential for operation of the website, such as maintaining login sessions.
Legal basis: Legitimate interests (cannot be opted out of).
• Analytics and Statistics Cookies
Purpose: Understanding and improving website usage, including through Google Analytics.
Legal basis: Consent.
• Marketing Cookies
Purpose: Advertising effectiveness measurement and retargeting.
Legal basis: Consent.
(2) Obtaining and Managing Consent
For cookies other than strictly necessary cookies, the Company obtains consent separately for each category through the cookie consent banner displayed upon the user’s first visit to the Company’s website. Even if consent is not provided, users may continue to use the website with non-essential cookies disabled.
(3) Withdrawal of Consent and Changes to Settings
Any consent previously granted may be withdrawn or modified at any time with future effect through the “Cookie Settings” function available on the website. Withdrawal of consent shall not affect the lawfulness of processing carried out before such withdrawal.
If you do not want your information to be collected by Google Analytics, you may also stop such collection by using the “Google Analytics Opt-out Browser Add-on.”
4. Disclosure and Sharing of Personal Data
Personal data collected by the Company will be processed by duly authorized personnel of the Company in accordance with applicable laws and regulations.
The Company may disclose or share personal data with the following categories of recipients, to the extent necessary for the purposes described in this Privacy Policy for Europe:
• Cloud service providers and other service providers;
• The Company’s affiliates and affiliated organizations;
• Distributors, resellers and other business partners;
• Third parties designated by users for the purpose of location sharing and other third parties designated by users; and
• Public authorities, courts, regulatory authorities and other public bodies where disclosure is required by applicable law.
Where such recipients process personal data on behalf of the Company, they will act as processors within the meaning of the GDPR and will process such personal data in accordance with the Company’s instructions and applicable data protection laws.
The Company may disclose your personal data (i) where required or permitted by applicable laws or regulations and (ii) when defending itself in an administrative or judicial proceeding.
5. Transfers to third countries outside the EEA
Your personal data may be transferred to third countries outside the EEA, including Japan and the United States.
In case of any transfer of personal data to a country that does not provide an adequate level of data protection under the standards of the GDPR, the Company will ensure that appropriate safeguards are in place, such as the Standard Contractual Clauses adopted by the European Commission, or will rely on another transfer mechanism permitted under applicable data protection laws.
Provided, however, that this shall not apply where the data subject has consented to the transfer, where the transfer is directly connected with the conclusion or performance of a contract, or where applicable law otherwise permits such transfer without these safeguards.
For the avoidance of doubt, Japan has been recognized by the European Commission as providing an adequate level of protection for personal data.
6. Retention period of personal data
The Company retains personal data for the following periods, except where applicable legal requirements require retention for a longer or shorter period.
• Account information: Until 31 days after account termination
• Navigation history (location information): 1 year
• Camera images (for VPS positioning): Deleted immediately after location estimation
• Application logs: 1 year
• Inquiry records: 3 years after completion of the response
• Records of consent: 5 years
7. Your rights
Data subjects in the EEA may exercise the following rights by contacting the Company using the contact information provided in this Privacy Policy for Europe.
(1) Right of access
You may obtain confirmation of whether or not your personal data is being processed and, if it is the case, to obtain access to or a copy of such personal data.
(2) Right of rectification
You may obtain the rectification in case of inaccurate personal data.
(3) Right of erasure
You may obtain the erasure of your personal data in certain circumstances.
(4) Right to restriction of processing
You may obtain the restriction of processing of your personal data in certain circumstances.
(5) Right to data portability
Where the Company processes personal data by automated means based on your consent or for the performance of a contract, you may receive your personal data or direct the Company to transmit such personal data to you or to a third party designated by you.
(6) Right to object
You may object to the processing of your personal data in certain circumstances.
(7) Right to withdrawal of your consent
You may withdraw your consent to the processing of your personal data at any time.
(8) Right to complain
You may lodge a complaint with one of the competent supervisory authorities.
8. Miscellaneous
The processing of your personal data carried out by the Company does not involve any automated decision-making that produces legal effects concerning the data subject or similarly significantly affects the data subject.
9. Contact Details
Data Controller
Name: Ashirase, Inc.
Address: 6th Floor, SF Uchikanda Building, 1-9-5 Uchikanda, Chiyoda-ku, Tokyo 101-0047, Japan
Data Protection Officer
Email Address: dpo@ashirase.com
EU Representative
We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact for the following regions:
• European Union (EU)
Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative, Prighter or make use of your data subject rights, please visit the following website: https://app.prighter.com/portal/16815971068
10. Changes to Privacy Policy for Europe
The Company may modify this Privacy Policy for Europe from time to time and will post the updated Privacy Policy for Europe with a “Last Updated” effective date of the revisions. The Company recommends that all persons concerned review this Privacy Policy for Europe periodically.
Effective as of 01 July, 2026