Effective date: June 12, 2026
NEVER RED Inc. (“NEVER RED,” “we,” “us”) respects your privacy. This Privacy Policy explains how we collect, use, share, and protect personal information when you visit the English pages of our website (neverred.co.jp/en/) or contact us. The Japanese version of our website is governed by our Japanese Privacy Policy; in case of any inconsistency regarding the Japanese site, the Japanese policy prevails.
1. Who We Are (Data Controller)
NEVER RED Inc.
SHIP, Osaki Bright Core 4F, 5-5-15 Kitashinagawa, Shinagawa-ku, Tokyo 141-0001, Japan
Email: info@neverred.co.jp
For the purposes of the EU/UK General Data Protection Regulation (“GDPR”), NEVER RED Inc. is the data controller of personal information collected through this website.
2. Information We Collect
- Information you provide. When you use our contact form, we collect your name, company or organization, email address, country/region, inquiry type, and the content of your message. When you correspond with us by email, we collect the information contained in that correspondence.
- Information collected automatically. Like most websites, our server and tools may collect technical data such as your IP address, browser type, device information, referring pages, and pages visited, including through cookies or similar technologies.
3. How We Use Your Information and Legal Bases
We use personal information for the following purposes. Where GDPR applies, the corresponding legal bases are indicated:
- Responding to your inquiries and conducting business discussions — performance of a contract or steps prior to entering into a contract (Art. 6(1)(b) GDPR), or our legitimate interest in responding to business inquiries (Art. 6(1)(f)).
- Managing ongoing business relationships, including engagements with partner firms and agencies — performance of a contract and legitimate interests.
- Improving our website and services — our legitimate interest in operating and improving our website.
- Complying with legal obligations under applicable Japanese and other laws (Art. 6(1)(c)).
We do not use your personal information for automated decision-making that produces legal or similarly significant effects, and we do not send marketing communications without your consent or request.
4. International Data Transfers
NEVER RED is located in Japan, and personal information submitted through this website is processed and stored in Japan. If you are in the European Economic Area or the United Kingdom: the European Commission and the UK Government have each recognized Japan as providing an adequate level of data protection (EU adequacy decision of 23 January 2019; UK adequacy regulations). Your personal information is additionally protected under Japan’s Act on the Protection of Personal Information (APPI).
5. How We Share Information
We do not sell personal information, and we do not share it with third parties for their own marketing purposes. We may share personal information only with:
- Service providers who support our operations (such as website hosting and email services), under obligations of confidentiality;
- Professional advisers (lawyers, accountants) where reasonably necessary;
- Public authorities where required by applicable law, regulation, or legal process.
6. Data Retention
We retain personal information only as long as necessary for the purposes described above — generally for the duration of our correspondence or business relationship and for a reasonable period thereafter — unless a longer retention period is required by applicable law.
7. Your Rights
If you are in the EEA or the UK, you have the right to request access to, rectification or erasure of, or restriction of processing of your personal information; the right to object to processing based on legitimate interests; the right to data portability; and, where processing is based on consent, the right to withdraw consent at any time. You also have the right to lodge a complaint with your local supervisory authority.
If you are a California resident, you have the right to know what personal information we collect, use, and disclose; to request deletion or correction of your personal information; and to not receive discriminatory treatment for exercising these rights (CCPA/CPRA). We do not sell or share personal information as those terms are defined under California law.
To exercise any of these rights, contact us at info@neverred.co.jp. We will respond within the timeframes required by applicable law.
8. Cookies
Our website may use cookies and similar technologies that are necessary for the site to function and, where applicable, to understand how the site is used. You can control or delete cookies through your browser settings; disabling cookies may affect some site functionality.
9. Security
We implement reasonable technical and organizational measures designed to protect personal information against unauthorized access, loss, alteration, or disclosure, in accordance with the APPI and industry practice.
10. Children
This website is intended for business audiences and is not directed to children under 16. We do not knowingly collect personal information from children.
11. Changes to This Policy
We may update this Privacy Policy from time to time. The updated version will be posted on this page with a revised effective date.
12. Contact Us
If you have any questions about this Privacy Policy or our handling of personal information, please contact:
NEVER RED Inc. — info@neverred.co.jp
SHIP, Osaki Bright Core 4F, 5-5-15 Kitashinagawa, Shinagawa-ku, Tokyo 141-0001, Japan