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DRAFT — not yet reviewed by a lawyer.

Privacy policy

Last updated: 29 September 2026

Who we are

Atotsugi (atotsugi.co) is an information-only newsletter run by a sole proprietor in Japan, Yosuke Komakine (駒木根陽介). We are the controller of the personal data described here. Contact: [email protected].

What we collect

We use Cloudflare Web Analytics to count visits. It does not use cookies and does not identify individual visitors.

Why we use it, and our lawful basis

We send you the sample issue and newsletter emails because you asked for them. Our lawful basis is your consent (GDPR Article 6(1)(a)), which you can withdraw at any time by unsubscribing or emailing us. For paying members we also process data to provide the subscription you bought (Article 6(1)(b)). We use the optional answers and campaign tags, in aggregate, to decide what to cover and which channels work.

Who processes it for us

These providers may process data outside Japan and the EEA, including in the United States, under their own safeguards (such as Standard Contractual Clauses). We do not sell your data or share it with sellers, brokers or succession centers.

How long we keep it

We keep your email and answers while you are subscribed and delete them within 30 days of a deletion request. Payment records are kept as long as Japanese tax law requires.

Your rights

You can ask us to access, correct or delete your data, to restrict or object to its use, or to export it. Email [email protected] and we will reply within one month. If you are in the EU or UK you can also complain to your local data protection authority. Japanese residents have equivalent rights under the Act on the Protection of Personal Information (APPI).

Changes

If we change this policy we will update the date above, and email subscribers about material changes.