This Privacy Policy describes how Gemini Group K.K. (株式会社GEMINI GROUP), referred to as “Gemini Group,” “we,” “us,” or “our,” collects, uses, discloses, and protects information about individuals who interact with our website, our services, and our communications. It also explains the choices available to you regarding that information.
We act as the data controller for the personal information described below. Our registered office is THE MOCK-UP BY PORTAL POINT #103, 4-8-1 Kojimachi, Chiyoda-ku, Tokyo 102-0083, Japan. You can reach us at privacy@geminigr.com.
1. Information we collect
We only collect information that we genuinely need to deliver our services, improve our work, and meet our legal obligations.
- Information you provide directly: your name, business email, company, role, phone number, and the content of any message you send us via our contact forms, email, or during engagements.
- Engagement data: meeting notes, documents, or materials that you share with us as part of a consulting engagement. We treat all engagement data as confidential.
- Subscription data: the email address you supply when you opt in to newsletters, alerts, or event invitations, and your subscription preferences.
- Technical data: IP address, browser type and version, device identifiers, referrer, pages visited, and timestamps, collected through server logs and privacy-respecting analytics.
- Cookies and similar technologies: strictly necessary cookies to keep the site working and, where applicable, analytics cookies set only with your consent.
2. How we use your information
We use the information above to:
- Respond to inquiries, proposals, and requests for proposals.
- Deliver our consulting services and communicate with clients during engagements.
- Send intelligence reports, alerts, and newsletters that you have subscribed to.
- Secure, operate, and improve our website and services, including fraud prevention.
- Comply with applicable law, including Japan’s Act on the Protection of Personal Information (APPI), and enforce our agreements.
We do not sell personal information and we do not use it for profiling or automated decision-making that has a legal or similarly significant effect on you.
3. Legal bases
Where Japanese or foreign data-protection law requires a legal basis, we rely on: your consent (for marketing emails and non-essential cookies), the performance of a contract (for client engagements), our legitimate interests (for securing our site and improving our services), and legal obligations (for bookkeeping, tax, and compliance).
4. How we share information
We do not sell, rent, or trade personal information. We share it only with:
- Service providers under written contracts that require confidentiality and limit use to our instructions, for example, email delivery, hosting, analytics, CRM, and accounting providers.
- Professional advisers: such as auditors, lawyers, and insurers, bound by professional duties of confidentiality.
- Authorities: where required by law, court order, or to protect our rights, users, or the public.
- Successors: in connection with a merger, acquisition, or restructuring, with equivalent protections in place.
5. International transfers
Some of our service providers operate outside Japan. Where we transfer personal information across borders, we do so in compliance with APPI Article 28 and equivalent laws, and we implement appropriate safeguards, including contractual clauses, data processing agreements, and vendor diligence.
6. Retention
We retain personal information only for as long as needed for the purposes set out above or as required by law. Contact-form submissions are retained for up to 24 months after last contact. Subscription data is retained until you unsubscribe or request deletion. Engagement data is retained in line with the terms of our client contracts and applicable record-keeping obligations.
7. Security
We maintain organizational, technical, and physical safeguards appropriate to the sensitivity of the information, including access controls, encryption in transit, principle-of-least-privilege for systems, and staff training on confidentiality. No method of transmission or storage is 100% secure, and we cannot guarantee absolute security.
8. Your rights and choices
Subject to applicable law, you may request to:
- Access the personal information we hold about you.
- Correct or update inaccurate information.
- Have your information deleted, subject to legal retention requirements.
- Restrict or object to specific uses.
- Withdraw consent at any time, including by using the unsubscribe link in any marketing email.
- Lodge a complaint with Japan’s Personal Information Protection Commission (PPC) or your local supervisory authority.
To exercise any of these rights, contact privacy@geminigr.com. We may need to verify your identity before acting.
9. Cookies
We use a small number of strictly necessary cookies to operate the site. Any analytics or preference cookies are set only with your consent. You can manage cookies through your browser settings and, where provided, through our on-site cookie controls.
10. Children
Our services are intended for business users. We do not knowingly collect personal information from children under 16. If you believe a child has provided us information, please contact us and we will delete it.
11. Changes
We may update this Privacy Policy to reflect changes in our practices or the law. The “Effective date” above will always reflect the latest version. Material changes will be posted prominently and, where appropriate, notified by email.
12. Contact
Gemini Group K.K., Privacy Office
THE MOCK-UP BY PORTAL POINT #103, 4-8-1 Kojimachi, Chiyoda-ku, Tokyo 102-0083, Japan
Email: privacy@geminigr.com