Privacy Policy

Gratiance Inc. (“Gratiance,” “we,” “us,” or “our”) is a by-introduction-only real estate brokerage incorporated in Japan, operating under Tokyo Governor License (3) No. 94967, with offices in Ebisu, Shibuya-ku, Tokyo 150-0013.

This Privacy Policy describes how we handle personal information collected through gratiance.com(the “Site”). It is written to satisfy the Act on the Protection of Personal Information of Japan (APPI), the EU and UK General Data Protection Regulation (GDPR/UK GDPR), and the California Consumer Privacy Act (CCPA) where applicable.

We collect personal information in two ways:

(a) Information you provide through the inquiry form — name, email address, telephone number (optional), country of residence, preferred language, the nature of your inquiry, your indicative budget, and any message you choose to include.

(b) Information collected automatically — through Google Analytics 4 (measurement ID G-RQ7PKCMW6W), we collect aggregated visit data: page views, session duration, approximate location (country/region only), device and browser type, the referring URL, and the occurrence of the SUBMIT_LEAD_FORM event when you submit an inquiry. We do not collect your IP address in identifiable form.

We use information you provide to:

• respond to your inquiry, in your preferred language, within one business day;
• assess whether and how we can be of service, given the privacy posture of our practice;
• communicate with you about properties, market conditions, or our process during the course of a relationship;
• comply with Japanese real-estate brokerage regulation, including anti-money-laundering and know-your-customer requirements where they apply.

We use information collected automatically to:

• measure the effectiveness of our website and any advertising we conduct;
• improve the content and structure of the Site;
• detect fraud and abuse of the inquiry form.

Where the GDPR or UK GDPR applies to you, we rely on the following lawful bases:

• Consent — when you submit an inquiry or accept analytics cookies, you consent to the processing described above. You may withdraw consent at any time (see Section 8).
• Legitimate interests — in operating a small, relationship-driven advisory practice, we have a legitimate interest in responding to inquiries, measuring the performance of our website, and maintaining accurate records of our communications. These interests are balanced against your rights and freedoms.
• Legal obligation — Japanese brokerage and anti-money-laundering law requires us to collect and retain certain information about clients.

The Site is hosted by Netlify, Inc. (San Francisco, USA). Form submissions are received and stored by Netlify Forms and forwarded to our internal inbox. Netlify is contractually committed to processing this information only on our instructions and in accordance with applicable law.

Analytics is operated by Google LLC through Google Analytics 4. A subset of our analytics events is imported into our linked Google Ads account to measure the effectiveness of advertising; no advertising-identifier or personally identifying data is shared with Google for advertising purposes at this time.

We do not sell your personal information. We do not share it with any party other than the processors described here, except where required by law or where doing so is necessary to provide the services you have requested.

Because our processors (Netlify, Google) are based in the United States, your information will be transferred outside Japan, the European Economic Area, and the United Kingdom. We rely on the Standard Contractual Clauses approved by the European Commission and the UK addendum thereto, together with our processors’ supplementary safeguards, to provide an adequate level of protection.

We retain inquiry-form submissions for as long as our relationship with you remains active and for a further seven (7) years thereafter, in line with Japanese commercial-records retention norms. Analytics data is retained for fourteen (14) months in identifiable form and indefinitely in aggregated form.

Subject to applicable law, you may:

• request access to the personal information we hold about you;
• request that it be corrected if inaccurate;
• request that it be deleted;
• object to or restrict its processing;
• request that it be transferred to you or to another controller in a structured, commonly used, machine-readable format;
• withdraw consent at any time, without affecting the lawfulness of processing carried out before withdrawal;
• lodge a complaint with the Personal Information Protection Commission of Japan, your local data-protection authority in the EU, or the Information Commissioner’s Office in the United Kingdom.

To exercise any of these rights, write to privacy@gratiance.com. We will respond within thirty (30) days.

We use TLS in transit and storage encryption at rest with our processors. Access to inquiry submissions is limited to the senior advisors named on each engagement. We do not, however, claim that any transmission of information over the internet is entirely secure.

We may update this Privacy Policy from time to time. The “Last updated” date above will reflect the most recent revision. Material changes will be communicated to existing clients by email.

Gratiance Inc.
Ebisu, Shibuya-ku, Tokyo 150-0013, Japan
privacy@gratiance.com