Privacy Policy
Caraway Management (“Caraway,” “we,” “us,” or “our”) is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard personal information when you visit our website or engage with our services.
We handle personal data in accordance with applicable data protection laws, including the Act on the Protection of Personal Information (APPI) of Japan.
1. Information We Collect
We may collect and process the following categories of personal information:
a. Information You Provide
- Name, email address, phone number, and contact details
- Information submitted through contact forms or client inquiries
- Any additional information you voluntarily provide
b. Automatically Collected Information
- IP address
- Browser type and version
- Device information
- Pages visited and time spent on the website
- Referring URLs
This data is typically collected through cookies and similar technologies.
c. Client-Related Information
If you become a client, we may collect additional information necessary for regulatory compliance and service delivery, including identification documents, financial information, and investment objectives.
2. How We Use Your Information
We use personal information for the following purposes:
- To respond to inquiries and communicate with you
- To provide and improve our services
- To comply with legal and regulatory obligations
- To conduct client onboarding, due diligence, and risk assessments
- To monitor and analyze website usage
- To maintain the security and integrity of our systems
We process personal data only where there is a lawful basis to do so.
3. Cookies and Tracking Technologies
Our website may use cookies and similar technologies to enhance user experience and collect usage data.
You can control or disable cookies through your browser settings. However, doing so may affect the functionality of certain parts of the website.
4. Disclosure of Information
We may share your personal information with:
- Service providers and professional advisors (e.g., IT, legal, compliance)
- Regulatory authorities, courts, or government bodies where required by law
- Affiliates or partners, where necessary for service delivery
We do not sell or rent your personal information to third parties.
5. International Data Transfers
As a Tokyo-based firm, your information is generally processed within Japan. However, in certain circumstances, data may be transferred to and processed in other jurisdictions.
Where such transfers occur, we take appropriate measures to ensure that your information remains protected in accordance with applicable laws.
6. Data Retention
We retain personal information only for as long as necessary to fulfill the purposes outlined in this Policy, including to meet legal, regulatory, and compliance requirements.
Retention periods may vary depending on the nature of the information and applicable obligations.
7. Data Security
We implement appropriate technical and organizational measures to protect personal information against unauthorized access, loss, misuse, or alteration.
While we strive to safeguard your data, no method of transmission over the internet or electronic storage is completely secure.
8. Your Rights
Under applicable data protection laws, you may have the right to:
- Request access to your personal information
- Request correction or deletion of inaccurate data
- Object to or restrict certain processing activities
- Withdraw consent where processing is based on consent
To exercise these rights, please contact us using the details below.
9. Third-Party Websites
Our website may contain links to external websites. This Privacy Policy does not apply to third-party sites, and we are not responsible for their privacy practices.
We encourage you to review their policies before providing personal information.
10. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in legal, regulatory, or operational requirements.
Any updates will be posted on this page with a revised effective date.
11. Contact Us
If you have any questions about this Privacy Policy or how your personal information is handled, please contact:
Caraway Management
Tokyo, Japan
info@carawaymgmt.com