Privacy Policy
What we collect, why, and how it's handled — for enquiries, and for the advisory and facilitation work itself.
Who This Policy Covers
This policy explains how Navigate Japan Limited ("NJL", "we", "us") handles personal information in running Navigate Business, our Japan–New Zealand business advisory and facilitation service. It covers people who contact us through the Navigate Business pages of our website, our clients and their staff, and people we deal with while carrying out an engagement — such as potential partners, and the people we meet or interpret for.
Our group-wide Privacy Policy covers the general enquiry form on our main website. Where the two differ for Navigate Business work, this policy applies.
Information We Collect
| What we collect | When |
|---|---|
| Your name, company, email address, and phone number | When you submit the Navigate Business enquiry form |
| Which direction you're working in (New Zealand to Japan, or Japan to New Zealand), the service you're interested in, and what you're trying to do | When you submit the enquiry form |
| Contact details of the people involved in an engagement, and business information about your company, its plans, and its partners | During an engagement |
| Meeting notes, interpretation notes, written follow-up records, and documents you ask us to interpret or translate | During an engagement |
| Recordings of meetings | Only if everyone taking part has agreed to the recording |
| Billing details, such as your company name and billing contact | When an engagement is agreed |
We don't ask for identity documents, visa or immigration details, or bank or card numbers as part of our services. We don't use advertising cookies. Our website platform, Squarespace, uses the cookies it needs to run the site and may give us aggregated visitor statistics.
How We Use Your Information
- To reply to your enquiry, and to work out whether, and how, we can help.
- To scope, carry out, and follow up your engagement — preparing briefs, arranging and interpreting at meetings, researching potential partners, and making the introductions you've agreed to.
- To invoice you, and to meet our accounting, tax, and other legal obligations.
- To keep a simple record of the enquiries we receive — including those we decline — so we understand what kind of help businesses are looking for.
We don't sell personal information, and we don't use it for anything unrelated to the above without asking first.
The Legal Framework
As a New Zealand company, NJL is subject to the Privacy Act 2020, built around Information Privacy Principles (IPPs). Following the Privacy Amendment Act 2025, there are now 14 principles — a new principle, IPP 3A, took effect from 1 May 2026 and applies when information about someone is collected from a source other than that person. That matters for Navigate Business in particular (see Section 5).
The Privacy Act's other principles cover, among other things: collecting information only for a lawful purpose (IPP 1); collecting it fairly and directly where practical (IPPs 2–4); keeping it secure (IPP 5); letting you see and correct your own information (IPPs 6–7); keeping it accurate and not for longer than needed (IPPs 8–9); and restricting further use, disclosure, and cross-border transfer (IPPs 10–12).
Does Japanese law apply too?
In some cases, yes. Navigate Business serves Japan-based clients, so Japan's Act on the Protection of Personal Information (APPI) can apply to how we handle the personal information of people in Japan. Section 8 explains how we meet it.
Introductions and Other People
Much of our work involves people other than our client — the partner you want to meet, the people at the table, the businesses on a shortlist.
- When researching potential partners, we mainly use business information and publicly available sources, such as company websites and business directories.
- When we collect personal information about someone from another source, we take reasonable steps to let them know that we have it, why, who will receive it, how to contact us, and that they can access and correct it, as IPP 3A requires — unless an exception applies, for example where they already know or the information is publicly available.
- We share your details with a party we introduce only with your agreement, and only what the introduction needs.
- If you give us information about your staff or contacts, please make sure they know you're sharing it with us for the engagement.
Data Retention and Security
We keep enquiries only as long as we need them to respond, and for the simple record described in Section 3. We keep invoices and the other business records tax law requires for seven years, as New Zealand law requires, and other engagement records only as long as the engagement and any follow-up need them.
We take reasonable steps, consistent with IPP 5, to protect information against loss, misuse, and unauthorised access. Access is limited to the people who need it for your engagement, and specialists we engage receive only what they need, under confidentiality. If a privacy breach has caused, or is likely to cause, serious harm, we'll notify the people affected and the Office of the Privacy Commissioner, as the Privacy Act requires.
If You're in Japan
Where Japan's APPI applies to how we handle your personal information, we also handle it in line with that Act:
| Item | How we handle it |
|---|---|
| Business operator | Navigate Japan Limited, Suite 1013, Unit A Level G, 26 Hobson Street, Auckland 1010, New Zealand. Representative: Kentaro (Ken) Yonei, Managing Director. |
| Purposes of use | As listed in Section 3. |
| Providing data to third parties | Only with your consent, except where APPI allows otherwise — for example, where required by law. |
| Handling outside Japan | We handle your information in New Zealand, which has a comprehensive privacy law, the Privacy Act 2020. Some service providers we rely on, such as our website form processor, are based in other countries, including the United States. Before we provide your personal data to a third party outside Japan in a way that needs your consent under APPI — for example, when introducing you to a New Zealand business — we'll ask for it, and tell you the country, its privacy law, and how the recipient protects personal information. |
| Security measures | The measures described in Section 7, including limiting access to the people who need it and keeping specialists under confidentiality. |
| Your requests | You can ask us to disclose, correct, add to or delete, stop using or erase, or stop providing to third parties the personal data we hold about you, or to disclose our records of providing it to third parties. Contact us using Section 10; we'll verify your identity and respond without undue delay. |
Your Rights
Under the Privacy Act 2020, you can ask to see the personal information we hold about you, and ask us to correct it if it's wrong. Contact us using the details in Section 10 — we'll respond as soon as reasonably practicable, and no later than 20 working days after we receive your request. We may need to verify your identity first. If you're in Japan, you also have the rights described in Section 8.
Changes to This Policy
We may update this policy as Navigate Business grows. The version number and date at the top of this page always reflect the current version.
Contact Us and Complaints
For any question about this policy or your personal information, contact our privacy officer at info@navigatejapanltd.com, or write to Navigate Japan Limited, Suite 1013, Unit A Level G, 26 Hobson Street, Auckland 1010, New Zealand.
If you're not satisfied with our response, you have the right to complain to the Office of the Privacy Commissioner in New Zealand (privacy.org.nz).