Privacy Policy

This Privacy Policy ("Policy") explains how Journely ("we," "our," or "Company"), operated from Japan, collects, uses, and protects your personal information in compliance with the Act on the Protection of Personal Information (APPI) and related Japanese regulations.

By using our Service, you acknowledge that you have read and understood this Policy. If you do not agree, please discontinue use immediately.

We operate in strict compliance with:

• Act on the Protection of Personal Information (APPI)
• Personal Information Protection Committee (PPC) Guidelines
• Financial Services Agency (FSA) Regulations (where applicable)
• Telecommunications Business Act
• Act on Specified Commercial Transactions

3.1 Information You Provide

• Account Information: Email address only (we follow minimal data collection principles)
• Journal Entries: Your personal investment notes, thesis, and decisions (user-entered data, NOT live account data)
• Portfolio Tracking: Positions you manually enter for tracking (NOT connected to real brokerage accounts)
• Waitlist Information: Email and referral codes for early access
• Support Communications: Inquiries and feedback you send to us

3.2 Automatically Collected Information

• Technical Data: IP address, browser type, device information
• Usage Data: Features used, time spent, interaction patterns
• Cookies: Session management and preference storage only
• Location: Country-level only for multi-currency display (USD/JPY/VND)

3.3 Information We DO NOT Collect

• Brokerage account login credentials or access tokens
• Bank account numbers or routing information
• Credit card or payment card information
• Government-issued ID numbers
• Live portfolio holdings from brokerage accounts
• Trading authorization or execution permissions
• Fund transfer or payment processing information for securities
• Income or net worth information

We use your information ONLY for:

• Service Provision: Operating the demo platform and visualization tools
• Communication: Sending service updates and responding to inquiries
• Improvement: Analyzing usage patterns to enhance user experience
• Legal Compliance: Meeting regulatory requirements
• Security: Preventing fraud and unauthorized access

We will NEVER use your information for: Providing actual investment advice, executing real trades, or selling to third parties.

5.1 We DO NOT Share Data With:

• Financial institutions or brokers
• Investment advisors or fund managers
• Marketing or advertising companies
• Data brokers or aggregators

5.2 Limited Sharing Circumstances:

• Service Providers: Only essential services (e.g., Supabase for authentication) under strict data processing agreements
• Legal Requirements: When required by Japanese law or court order
• Emergency: To protect vital interests or prevent serious harm
• Business Transfer: In case of merger/acquisition (with prior notice)

Your data is primarily stored in Japan. Any international transfers comply with APPI requirements:

• We ensure adequate protection through standard contractual clauses
• Transfers only to countries with adequate data protection laws
• Your explicit consent for specific transfers outside Japan

We implement comprehensive security measures:

• Encryption: TLS 1.3 for transmission, AES-256 for storage
• Access Control: Role-based access, multi-factor authentication
• Monitoring: 24/7 security monitoring and intrusion detection
• Employee Training: Regular security and privacy training
• Incident Response: Established breach notification procedures
• Regular Audits: Annual security assessments

You have the following rights regarding your personal information:

• Access Right: Request disclosure of your personal data
• Correction Right: Request correction of inaccurate data
• Deletion Right: Request deletion of unnecessary data
• Suspension Right: Request suspension of data use
• Portability: Receive your data in a structured format
• Objection: Object to certain processing activities

To exercise these rights, contact: hello@journely.me. We will respond within 30 days.

• Active Accounts: Retained while account is active
• Inactive Accounts: Deleted after 2 years of inactivity
• Legal Records: 5 years as required by Japanese commercial law
• Marketing Communications: Until opt-out + 6 months

We use minimal, essential cookies only:

• Essential Cookies: Authentication and security
• Preference Cookies: Language settings (EN/JA/VI)
• NO Third-Party Tracking: We don't use advertising or analytics cookies

Our Service is not intended for individuals under 20 years of age (the age of majority in Japan). We do not knowingly collect information from minors. If we discover such collection, we will immediately delete the information.

In the event of a data breach that may harm your rights and interests:

• We will notify the Personal Information Protection Committee within 72 hours
• We will notify affected users without undue delay
• We will provide details of the breach and mitigation measures

We may update this Policy to reflect legal changes or service improvements. Material changes will be notified via email at least 30 days before taking effect. Continued use after updates constitutes acceptance.

Data Controller:

Journely
Location: Tokyo, Japan
Email: hello@journely.me

If you are unsatisfied with our response, you may file a complaint with:

Personal Information Protection Committee
Website: www.ppc.go.jp
Phone: 03-6457-9680

Journely may integrate with third-party services for market data and research purposes ONLY. These integrations are READ-ONLY and educational in nature. We do NOT:

• Connect to your brokerage accounts for trading or execution
• Obtain authorization to move funds or execute trades
• Access your financial accounts for any transactional purposes
• Act as an intermediary between you and financial institutions

Third-party services we use:

• Market Data Providers: For research and educational insights only (read-only public data)
• Supabase: For secure authentication and data storage
• Analytics Services: For product improvement (anonymized data only)

All third-party integrations are subject to their respective privacy policies and terms of service.