Preamble

We (“the Company”) establish this Privacy Policy regarding the handling of personal information of customers (“Users”) who use our application “Naviu” (the “App”). The Company will properly handle personal information in accordance with this Policy, in compliance with the Act on the Protection of Personal Information (“APPI”) and other applicable laws and regulations. Terms used in this Policy have the meanings given to them under the APPI.

 

Article 1 (Information Collected)

The Company may collect the following User information in connection with the App.

(1) Information relating to identity verification

• Name, username, gender, date of birth, photograph, language used, and other profile information
• Address, postal code, phone number, email address, and other contact information
• SNS information linked by the User

(2) Payment-related information

• Payment amount, date and time, order number/transaction ID, payment result, and other transaction information

The Company does not obtain or store the User’s credit card number, security code, or other card information it does not need to obtain directly, when using Apple Pay or other external payment services.

(3) Information obtained in connection with use of the Service

• Current location obtained via GPS or other means
• Information on the device used, device identifiers such as cookie IDs, browsing history, and other usage information (including IP address and access logs)
• Preference information and travel-related conditions entered by the User, saved travel plans, and visit/movement history and other travel/behavioral history
• Information about friends/companions entered by the User
• Healthcare/fitness information obtained from linked services based on the User’s permission
• Images/video captured by the User’s device camera when using AR navigation or the AI assistant, the content of conversations with the AI, and analysis results related thereto

(4) Inquiry information

• Information relating to inquiries or contact from Users to the Company

(5) Other information that the User provides to the Company in connection with use of the Service

 

Article 2 (Method of Collection)

The Company collects the information described in the preceding Article through User input/postings, acquisition through device functions or permissions, linkage with healthcare/fitness services or SNS that the User has authorized, and automatic collection arising from use of the Service. For information requiring device permissions — location, camera, microphone, and the like — the Company will request permission on the device only to the extent necessary for use of the relevant function.

 

Article 3 (Purpose of Use)

The Company will collect and use Users’ personal information within the scope of the following purposes, and will not use it for other purposes except with the User’s consent or as permitted by law.

1. Registration for the Service, identity verification when using the Service, and management of the User’s account
2. Displaying the User’s current location, providing route guidance to a destination, providing information on nearby tourist facilities/stores, and other navigation functions, based on the User’s location information
3. Analyzing the User’s location information, travel-related preferences, settings, saved travel plans, travel history, and other information, and using AI or other technology to create, propose, or optimize travel plans, destinations, routes, and experiences
4. When the User uses AR navigation, analyzing camera images to recognize objects/scenery in real space and display guidance information
5. When the User uses the AI assistant, analyzing text, images, video, voice, and other information entered or sent by the User to provide AI functions such as object/scenery recognition, answering questions, translation, and guidance
6. Obtaining and displaying healthcare/fitness information, and showing the User their own activity status
7. Providing paid services and managing contract status
8. Providing profile information, travel plans, location information, and other information that a User has chosen to make public or share, to other Users the User has designated or to persons within a set disclosure scope, for the purpose of interaction between Users, sharing of travel plans, and other social functions
9. Delivering advertisements and other information about third-party products, services, and campaigns tailored to the User’s location, travel history, and preferences
10. Providing anonymized/processed information described in Article 13 to third parties
11. Maintenance of the Service, handling of failures, ensuring security, preventing unauthorized use, and quality improvement
12. Analysis of usage status, compiling statistics, improving functions, and planning/developing new functions
13. Responding to inquiries and contacting Users
14. Conducting campaigns and surveys
15. Responding to requirements under laws and regulations

 

Article 4 (External Services, etc.)

1. To provide the Service — map/navigation functions, AR functions, AI-based creation/proposal of travel plans, the AI assistant and other AI functions, user authentication, push notifications, ad delivery, usage analysis, failure analysis, and other functions necessary to operate the Service — the Company may use APIs and other external services provided by third parties (“External Services, etc.”).
2. In connection with the use of External Services, etc., the User’s location information, device information, IP address, device identifiers, text entered by the User, travel-related preferences, travel plans/history, images/video obtained from the camera, content of conversations with AI, App usage status, crash/diagnostic information, and other information necessary to provide the relevant External Service may be sent to, or processed by, the provider of that External Service.
3. Information sent to providers of External Services, etc. may be subject to each provider’s own privacy policy or other terms. The Company will take the necessary and appropriate measures required by the APPI and other applicable laws regarding information handled through External Services. Information needed for AI functions is provided to AI providers only to the extent necessary for those functions, and is not used to train, develop, or improve AI models.
4. To the extent necessary to provide the functions in paragraph 1, the Company may entrust the handling of, or provide, Users’ personal data to providers of External Services, etc. located overseas. The main External Services used by the Company, their providers, the information transmitted, and the purpose of use are set out in the attached “List of External Transmission Destinations.” Users agree that the Company may provide personal data to such overseas providers to the extent necessary to achieve the purposes of use above.
5. Where an AI provider uses AI usage information to train, develop, or improve an AI model, the Company will clearly disclose that fact, the information subject to such use, and other necessary matters to the User, and will obtain the User’s prior consent where required by law. The Company will also review the conditions under which an AI provider uses AI usage information to train, develop, or improve an AI model, and will take necessary measures in accordance with the APPI and other applicable laws.

 

Article 5 (Information Sharing Between Users)

1. The Service may provide functions that let a User connect with other Users and view or share profiles, travel plans, and other information designated by the Company.
2. Where a User uses such a function, the Company will provide information the User has chosen to make public or share — based on the User’s consent — to other Users designated by the User or to persons within the disclosure scope of that information, to the extent necessary to provide the function.
3. Users may set or change the scope of disclosure or sharing through settings on the Service or other methods designated by the Company. However, information a User has already shared with another User may remain even after sharing is stopped, due to the recipient User’s own storage of it or other circumstances.

 

Article 6 (Incidental Capture of Third Parties)

Where the Company analyzes camera images etc. to provide navigation based on objects/scenery in real space, it may analyze — using AI or other image-analysis technology — photographs or other images the User has provided to, or allowed the Service to access.

If a third party other than the User appears in an image subject to such analysis, that third party’s face or other physical characteristics, which constitute personal information, may be incidentally and inadvertently obtained and provided to the AI provider.

 

Article 7 (Joint Use)

The Company may jointly use Users’ personal information as follows:

1. Items of data subject to joint use: the User information set out in Article 1 of this Policy
2. Scope of joint use: the following Company group companies:
   • DC LLC (合同会社DC)
   • TANGLE Inc. (株式会社TANGLE)
3. Purpose of use of jointly used data: the purposes set out in Article 3 of this Policy
4. Party responsible for managing jointly used data: [ ]

 

Article 8 (Provision to Third Parties)

The Company may provide Users’ personal information to third parties without prior consent in the following cases:

1. Where handling of personal data is outsourced to the extent necessary to achieve the purpose of use
2. Where required by law
3. Where necessary to protect a person’s life, body, or property, and obtaining consent is difficult
4. Where particularly necessary for public health or the sound development of children, and obtaining consent is difficult
5. Where cooperation with a national or local government agency (or a party entrusted by one) is necessary to carry out duties prescribed by law, and obtaining consent would impede that work
6. Where the third party is an academic research institution that needs to handle the information for academic research purposes (including where academic research is only part of the purpose), unless doing so would unjustly harm the individual’s rights or interests
7. Where otherwise permitted under the APPI or other applicable law

 

Article 9 (Safety Management Measures)

The Company will take necessary and appropriate measures to prevent leakage, loss, or damage of the personal information it handles, and to otherwise ensure its security. The Company will also provide necessary and appropriate supervision of employees and contractors who handle personal data.

 

Article 10 (User Rights)

In accordance with applicable law, Users may request notification of the purpose of use, disclosure, correction/addition/deletion, suspension of use or erasure, suspension of provision to third parties, and other actions regarding their own personal information held by the Company. Requests under this Article should be directed to the “Personal Information Inquiry Desk” described in Article 15.

 

Article 11 (Use by Minors)

If it becomes apparent that a User is under the age of 13, the Company may restrict use of the account, delete information, or take other necessary action.

 

Article 12 (Use of Anonymized Information, etc.)

In accordance with applicable law, the Company may use statistical information and other information that has been appropriately processed so a specific individual cannot be identified, for analysis, improvement, and business review of the Service, or may provide it to third parties. Where the Company creates, uses, or provides to third parties anonymized processed information or pseudonymized processed information, it will do so in accordance with the APPI and other applicable laws.

 

Article 13 (Changes to this Policy)

The Company may change the content of this Policy as necessary and will post any changes within the App. In that case, the revised Policy applies from the effective date the Company separately determines.

 

Article 14 (Contact / Business Operator Information)

Inquiries regarding this Policy or the handling of Users’ personal information should be directed to:

• Business name: [ Ashita Co ]
• Address: [JR Tokyu Meguro Building 4F, 3-1-1 Kamiosaki, Shinagawa, Tokyo 141-0021 ]
• Representative: [ Jack Mead]
• Email address: [admin@ashitaco.com ]

 

Appendix: List of External Transmission Destinations

External Service	Provider	Main Information Transmitted / Processed	Purpose of Use
Firebase Authentication	Google LLC	User authentication	Email address, User ID (UID), authentication token, sign-in method
Firebase Crashlytics	Google LLC	Crash diagnostics and app stability monitoring	Device model, OS version, crash logs, stack traces, app version, and (in some settings) IP address at time of crash
Firebase Analytics	Google LLC	App usage analysis	Device identifier (App Instance ID), device model, OS version, usage events, approximate location (estimated from IP address), session duration
Google Cloud Vertex AI (Gemini)	Google LLC	AI-based image recognition, chat, and voice processing	Images, audio, and text sent for processing (temporary only; not retained after processing on Google Cloud servers)
Google Maps Platform (Map Tiles API)	Google LLC	Map display and custom map styling	Requested tile coordinates, API key, device IP address (used for request routing), map style request content
Cesium (Cesium ion)	Cesium GS, Inc.	3D terrain and globe rendering	API token/account identifier, requested asset/tile coordinates, usage measurement data
Google Geospatial API / ARCore	Google LLC	AR navigation and high-precision geolocation (Visual Positioning System)	Camera images (used for VPS location processing), GPS coordinates, device orientation/motion data
Google Places API	Google LLC	Place search and display of visited/saved places	Place search queries, Place ID, coordinate information
Health App Integration (Apple HealthKit / Google Fit)	Apple Inc. / Google LLC	Displaying step count within the app	Step count (read-only access, based on User permission)