Twinkle Colony

Privacy Policy

Last updated: 27 October 2026

This policy describes how the operator of Twinkle Colony (the practice) handles personal information received through this website and in the course of advisory work, in line with Japan's Act on the Protection of Personal Information (APPI). The practice is run from Miyakonojo, Miyazaki, and the operator's legal name is disclosed on request.

1. Who is responsible

The operator of Twinkle Colony, 3-19-16 Kitaharacho, Miyakonojo, Miyazaki 885-0024, Japan. Questions and requests: info@twinkle-colony.com, +81 986-34-0486.

2. What we receive

We receive only what you send or hand over to us:

  • name, email address and message text, typed into the enquiry form or sent by email;
  • anything you tell us by phone or in a meeting about your organisation and your situation;
  • for a retention review, the service records your organisation chooses to share, and the notes we take in confidential conversations with its staff.

We do not ask for CVs, applications, government ID numbers or special-care personal information (such as health data), and we ask that none be sent. The website itself sets no cookies and uses no analytics, as the cookies page explains.

3. Why we use it

We use personal information to read and answer your enquiry, to prepare a quote, to carry out an engagement you have asked for, to keep the records that a business needs for accounting and for any dispute, and to meet legal duties. We do not use it for marketing mailings you did not ask for, and we do not build profiles.

4. Records shared by a client

Service records contain information about people who have not written to us. The organisation that shares them is responsible for having the right to do so, and we ask that names be replaced with codes before the records reach us wherever that is practical. We use such records only for the review they were shared for, and the report describes patterns, not named people.

5. Sharing with others

We do not sell personal information and do not provide it to third parties except where the law requires it or you have agreed. Email and hosting providers process data on our behalf as part of delivering the service; we choose them with care and expect them to protect it. Some providers may keep data on servers outside Japan; where that applies, we handle it as the APPI requires for transfers abroad.

6. Security

Access to what you send is limited to the operator. Records from clients are kept on protected devices, shared files are not left in open folders, and messages that are no longer needed are deleted. No method is perfectly safe, so please do not send anything through the form that you would not want to be read by a mail provider.

7. How long we keep it

Enquiries that do not lead to an engagement are kept for as long as is needed to answer them and are then deleted. For an engagement, client records are returned or deleted when the work ends, unless the agreement says otherwise; the written report and the accounting records are kept for as long as the business or the law requires.

8. Your rights

Under the APPI you may ask us to tell you what personal information about you we hold, to correct it, to stop using it or to delete it. Write to info@twinkle-colony.com. We may ask you to confirm who you are before acting, will tell you in advance if a fee applies, and will answer within a reasonable time.

8a. Conversation notes and phone calls

When we talk to your staff for a retention review, we take notes by hand or in a text file. The notes are kept apart from the records, are not shared with your management in a form that identifies the speaker, and are deleted when the report has been delivered, unless you and we have agreed in writing to keep them for a stated period. If you call the number on this site, we do not record the call.

8b. If something goes wrong

If personal information in our hands is lost or exposed in a way that could harm people, we will assess it promptly, report it to the Personal Information Protection Commission where the APPI requires, and inform the people affected and, for client records, the client.

8c. Visits to the website

We do not run analytics, so we do not know who visits or which pages they read. The only trace is whatever the hosting company records in ordinary server logs, which we do not analyse.

9. Complaints

If we have not resolved a concern, you can contact the Personal Information Protection Commission (個人情報保護委員会) of Japan.

10. The enquiry form

The form on this site is a basic form. If you want to be sure a message reached us, send it by email as well.

11. Changes

We will update this page when our handling changes and show the date at the top.