Data Processing Agreement (DPA)
The Japanese version at データ処理合意書 is the legally binding one.
This Data Processing Agreement (hereinafter referred to as the "Agreement") establishes the terms and conditions under which Grushdelta 合同会社 (hereinafter the "Processor") processes personal data on behalf of B2B clients (hereinafter the "Controller"). This Agreement is governed by the Act on the Protection of Personal Information (APPI) of Japan and related legislation.
Key Summary:
- The Processor processes data exclusively according to the Controller's instructions.
- Data retention follows the studio's archive policy (12 months).
- Sakura Internet Inc. and FormSubmit are utilized as external sub-processors.
- The Processor implements strict technical and organizational security measures.
Updated: 15 October 2026
1. Definitions and Purpose
The purpose of this Agreement is to ensure the protection of personal data processed in connection with recording, mixing, and mastering services provided by the Processor to the Controller. This Agreement supplements the Privacy Policy and clarifies legal responsibilities within B2B transactions.
2. Scope and Nature of Processing
Categories of processed data include the Controller's contact information, names of artists, and audio data (which may include biometric information) collected during recording sessions. The purpose of processing is limited to studio booking management, production of works, and delivery of final files.
3. Obligations of the Processor
The Processor shall process personal data only on the written instructions of the Controller. The Processor agrees to comply with this Agreement and the Japanese Act on the Protection of Personal Information (APPI) and shall not disclose data to third parties inappropriately. Access is restricted to authorized personnel only to maintain confidentiality.
4. Sub-processors
The Processor utilizes the following sub-processors to the extent necessary to provide the services:
- Sakura Internet Inc. (Address: Grand Front Osaka Tower A 35F, 4-20 Ofuka-cho, Kita-ku, Osaka 530-0011): Data hosting and server management.
- FormSubmit (Located in USA): Data transfer from contact forms.
The Processor ensures that these sub-processors maintain data protection standards equivalent to those set out in this Agreement.
5. Security Measures
To prevent leakage, loss, or damage of data, the Processor implements the following measures:
- Access control (password management and physical entry restrictions to the studio).
- Encryption of stored data and secure backups.
- Confidentiality training for staff involved in processing (Saki Watanabe, Kenji Hashimoto, Daiki Yamamoto).
6. Incident Notification
In the event of a data breach or unauthorized access, the Processor shall promptly notify the Controller and report the situation. Notification will occur within a reasonable timeframe after detection. If necessary, the Processor will assist in reporting the incident to the Personal Information Protection Commission (PPC).
7. Return and Erasure of Data
Upon termination of services or upon the Controller's request, the Processor shall return or erase the data. However, according to the studio's business rules, session archives are retained for a maximum of 12 months, after which they are securely deleted. For detailed terms of use, please refer to the Terms and Conditions.
8. Audit Rights and Jurisdiction
The Controller has the right to conduct audits to verify the Processor's compliance with this Agreement, provided reasonable notice is given. Any disputes regarding this Agreement shall be subject to the exclusive jurisdiction of the Fukuoka District Court in the first instance.
Supervisory Authority: Personal Information Protection Commission (PPC), 3-3-1 Kasumigaseki, Chiyoda-ku, Tokyo 100-0013, https://www.ppc.go.jp
Contact Details:
Grushdelta 合同会社 (Capital: ¥1,000,000 / Director: Saki Watanabe)
Address: Tenjin-dori 4-12, Chuo-ku, Fukuoka 810-0001
Phone: 092-796-8531 / E-mail: [email protected]