Privacy Policy
What we collect, why, and how it's handled — for enquiries, for the content we make, and for the accounts we manage on your behalf.
What's covered here
Who This Policy Covers
This policy explains how Navigate Japan Limited ("NJL", "we", "us") handles personal information in running Navigate Media, our video production, social media management and website design and management service. It covers people who contact us through the Navigate Media pages of our website, our clients and their staff, people who appear in content we produce, and people whose comments and messages we handle while managing a client's accounts.
Our group-wide Privacy Policy covers the general enquiry form on our main website. Where the two differ for Navigate Media work, this policy applies.
Information We Collect
| What we collect | When |
|---|---|
| Your name, business name, email address, and phone number | When you submit the Navigate Media enquiry form |
| The service you're interested in, your industry, links to your website or social accounts, and what you tell us about your business | When you submit the enquiry form |
| Contact details of the people we work with at your business, your brand materials, and billing details | When an engagement is agreed |
| Photos, video, and audio you supply, or that we film — which may include your staff, customers, or others | During an engagement |
| Access to your social media accounts, and the performance statistics those platforms provide | While we manage your accounts |
| Comments and direct messages from your audience | Only where your plan includes comment and message management |
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 prepare a proposal.
- To produce, schedule, and publish content, manage your accounts, and prepare your monthly performance summary.
- To invoice you, and to meet our accounting, tax, and other legal obligations.
- To show examples of published work in our portfolio, as your services agreement allows (see Section 5).
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 Media when a client supplies photos or footage of other people (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 Media serves clients in Japan, 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.
Content, Accounts, and Audiences
- People in content. We ask for consent before we film anyone. Where a client supplies photos or footage, the client is responsible for having the consent of the people in them, and we rely on the client having told them it will be shared with us and why; if that hasn't happened, we take reasonable steps to let them know, as IPP 3A requires, unless an exception applies. If you appear in content we made and want it changed or removed, contact us or the business concerned.
- Your audience. When we reply to comments and messages on a client's behalf, we act for that client and follow their instructions. We don't copy followers' information into our own records or use it for anything else.
- Platform data. The statistics we report come from the platforms themselves, and are mostly aggregated. Each platform handles its users' data under its own privacy policy.
- Account access. Login details are kept secure and used only for the agreed work. When an engagement ends, we delete any passwords we hold and stop using the accounts.
- Portfolio. Examples we show are published, non-confidential work. We'll remove content from our portfolio if the client — or anyone who appears in it — asks.
Data Retention and Security
We keep enquiries only as long as we need them to respond. Client materials, raw footage, and project files are kept while the engagement runs, and for a reasonable period afterwards in case you ask for changes, then deleted. Finished content may be kept for our records and portfolio. We keep invoices and the other business records tax law requires for seven years, as New Zealand law requires.
We take reasonable steps, consistent with IPP 5, to protect information against loss, misuse, and unauthorised access. Access is limited to the people working on your account, and freelancers 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, 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 Sections 5 and 7, including limiting access to the people working on your account and deleting passwords when an engagement ends. |
| 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 Media 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).