Privacy Policy

Last updated: 23 September 2026

1. Who We Are

This website is operated by Waterways Company Limited (formerly ALTY Co. Ltd.; "we," "us," "our"), based in Japan.

Address: 2F., Daiya bldg., 2-2-15, Hamamatsucho, Minato-ku, Tokyo, 105-0013 JAPAN
Contact: please use our Contact Form

For the purposes of the EU General Data Protection Regulation (GDPR), Waterways Company Limited is the data controller of your personal data collected through this website.

2. What Personal Data We Collect

We collect the following categories of personal data:

  • Contact Form (general inquiries, including non-EU return and defective item requests): name, email address, order number (where applicable), and the content of your message.
  • Withdrawal Form (EU statutory right of withdrawal only, accessed via "Withdraw from Contract (EU)" in the footer): name, order number, and email address.

Both forms are processed using Zoho Forms, with data stored on Zoho's servers located in Japan.

  • Order and shipping: name, shipping address, billing address, email address, and phone number (where provided).
  • Payment: processed directly by our payment provider, Stripe. We do not store your full card details on our servers.

3. How We Use Your Data and Legal Basis

Purpose Legal basis (GDPR)
Processing and delivering your order Performance of a contract (Art. 6(1)(b))
Processing payments via Stripe Performance of a contract (Art. 6(1)(b))
Responding to inquiries via the Contact Form Performance of a contract / Legitimate interest (Art. 6(1)(b)/(f))
Processing withdrawal requests via the Withdrawal Form Legal obligation (Art. 6(1)(c))
Preventing fraud and ensuring website security Legitimate interest (Art. 6(1)(f))
Complying with tax, customs, and accounting obligations Legal obligation (Art. 6(1)(c))

4. Sharing Your Data

We share personal data with the following categories of recipients, only as necessary to provide our services:

  • Zoho Corporation (form submission and storage; data stored in Japan)
  • Stripe, Inc. (payment processing)
  • Shipping carriers (for delivery of your order)
  • Tax and customs authorities, where required by law

We do not sell or share your personal data with third parties for advertising purposes.

5. International Data Transfers

Personal data collected through this website may be processed in Japan, where Waterways Company Limited is based, and where our form provider Zoho stores submitted form data. The European Commission has recognized Japan as providing an adequate level of data protection, so no additional safeguards are required for this transfer.

Some of our service providers, including Stripe, may process data in the United States. Where this involves a transfer of data outside the European Economic Area (EEA) to a country without an adequacy decision, we rely on appropriate safeguards, such as Standard Contractual Clauses or the EU-U.S. Data Privacy Framework, to protect your data.

6. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes described in this policy, including to comply with legal, tax, and accounting requirements.

7. Your Rights (EU/EEA Residents)

Under the GDPR, you have the right to:

  • Access the personal data we hold about you
  • Request correction of inaccurate data
  • Request deletion of your data
  • Restrict or object to certain processing
  • Request data portability
  • Lodge a complaint with your local data protection authority

To exercise these rights, contact us using our Contact Form.

8. Your Rights (California Residents)

Under the CCPA/CPRA, California residents have the right to:

  • Know what personal information we collect and how it is used
  • Request deletion of their personal information
  • Correct inaccurate personal information
  • Non-discrimination for exercising these rights

We do not sell or share personal information as defined under the CCPA/CPRA.

To exercise these rights, contact us using our Contact Form.

9. Cookies

This website uses cookies. For details, please see our Cookie Policy.

10. Data Security

We implement reasonable technical and organizational measures to protect your personal data. However, no method of transmission over the internet is completely secure.

11. Contact Us

Waterways Company Limited (formerly ALTY Co. Ltd.)
2F., Daiya bldg., 2-2-15, Hamamatsucho, Minato-ku, Tokyo, 105-0013 JAPAN
Contact Form

12. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated "Last updated" date.