Data Processing and Sharing Disclosure
This Data Processing and Sharing Disclosure (“disclosure”) sets out how personal data is processed and shared through the Navi Japan platform in connection with the services provided by Sannam S4 (“we”, “us”, “our”).
1. Purpose
Sannam S4 collects, uses, stores, and shares personal data through the Navi Japan platform in order to support students through the process of studying in Japan. This includes student counselling, application preparation and submission, communication with educational institutions, visa and immigration-related support, and the operation of the platform and related services.
This disclosure is intended to provide a clear summary of the data processing and sharing arrangements that apply to the Navi Japan platform and the services provided through it. This disclosure should be read together with the Navi Japan Privacy Notice, which provides further information about how personal data is collected, used, retained, and the rights available to individuals. Use of the Navi Japan platform may also be subject to separate Terms of Service.
2. Role of the Parties
2.1 Data Controller
Sannam S4 acts as the data controller for personal data collected and processed through the Navi Japan platform. This means we decide the purposes for which personal data is used and the main ways in which that personal data is handled in connection with the services offered through the platform.
2.2 Data Subjects
The data subjects are students using the Navi Japan platform and, where applicable, their parents or guardians whose personal data is provided as part of the student support process.
2.3 Independent Controllers
2.3.1 Educational Institutions in Japan
Educational institutions in Japan to which student applications are submitted act as independent data controllers for the personal data they receive. They process that data for their own admissions, enrolment, academic administration, and related institutional purposes.
2.3.2 Immigration and Government Authorities in Japan
Immigration offices, embassies, consulates, and other relevant government or regulatory authorities in Japan act as independent data controllers where they receive and process personal data for visa, immigration, regulatory, and legal compliance purposes.
2.4 Data Processors
Service providers engaged by us act as data processors where they process personal data only on behalf of and under the instructions of Sannam S4.
3. Categories of Personal Data
Depending on the services being provided, we may process and share the following categories of personal data through the Navi Japan platform:
3.1 Identity and personal details: This may include a student’s name, date of birth, nationality, gender, passport details, identification documents, and other personal details needed for counselling, application, or visa-related processes.
3.2 Contact information: This may include email address, telephone number, residential address, emergency contact information, and, where relevant, parent or guardian contact details.
3.3 Educational and academic information: This may include school or college details, transcripts, certificates, grades, test scores, language proficiency records, academic history, and other information needed to assess study options and support applications.
3.4 Application and supporting documents: This may include statements of purpose, references, application forms, copies of documents uploaded through the platform, and other supporting materials required by educational institutions.
3.5 Visa and immigration-related information: Where relevant, this may include passport copies, financial or sponsorship documents, proof of eligibility, visa application information, and other materials required for immigration-related procedures.
3.6 Counselling and service records: This may include records of student preferences, counselling notes, communications, appointment history, application progress, and other internal case-management information relevant to the services being provided.
3.7 Platform and administrative data: This may include limited account, usage, technical, or administrative information needed to operate the Navi Japan platform, support communications, manage documents, and maintain service delivery.
We aim to ensure that only personal data that is relevant and reasonably necessary for the relevant process is handled and shared.
4. How We Collect Personal Data
We may collect personal data:
5. Why We Use Personal Data
Navi Japan platform uses personal data to manage and support the student journey from initial counselling through to application, admission, visa support, and related services. In particular, personal data may be used for the following business activities:
5.1 Student counselling and guidance: To provide students with counselling, advice, and guidance regarding study opportunities in Japan, including identifying suitable courses, institutions, and study pathways based on the student’s profile, interests, qualifications, and goals.
5.2 Assessment of suitability and eligibility: To assess a student’s eligibility and suitability for particular courses, institutions, programmes, scholarships, language requirements, or related services, including review of academic records, application materials, and supporting documents.
5.3 Application preparation and submission: To prepare, organise, review, and submit student applications to educational institutions in Japan, including compiling required documents, checking completeness, and communicating with institutions in relation to admissions requirements, timelines, and supporting information.
5.4 Communication and case management: To communicate with students and, where appropriate, their parents or guardians, as well as with universities, colleges, language schools, agents, and relevant third parties regarding counselling, applications, admissions, enrolment, next steps, and ongoing support.
5.5 Visa and immigration-related support: To support visa guidance and related immigration processes, including preparing documentation, facilitating submissions, liaising with relevant authorities or institutions, and helping students meet immigration and regulatory requirements connected with their study plans.
5.6 Pre-departure, enrolment, and student support services: To provide pre-departure assistance, onboarding support, enrolment-related support, and other related student services connected with the transition to studying in Japan.
5.7 Records management and service administration: To create, maintain, and manage student records, respond to queries, track progress, administer services provided through the Navi Japan platform, and maintain continuity and quality of service.
5.8 Platform operation and improvement: To operate, maintain, secure, and improve the Navi Japan platform and related systems, including user account administration, document handling, service troubleshooting, and reasonable internal operational analysis to support service delivery.
5.9 Legal, regulatory, audit, and compliance purposes: To comply with applicable legal, regulatory, audit, reporting, and compliance obligations, including responding to lawful requests, maintaining appropriate records, protecting legal rights, and supporting internal governance requirements.
6. Who We Share Personal Data With
We may share personal data with the following categories of recipients:
6.1 Educational institutions in Japan
Personal data may be disclosed to universities, colleges, language schools, and other educational institutions in Japan for admissions, enrolment, scholarship review, student administration, and related academic purposes. These institutions act as independent data controllers for the personal data they receive.
6.2 Immigration and government authorities
Personal data may be disclosed to immigration authorities, embassies, consulates, and other public authorities in Japan or elsewhere where necessary for visa applications, residence procedures, regulatory compliance, fraud prevention, or where required by law.
6.3 Service providers
We may share personal data with service providers that support the Navi Japan platform and related services, such as cloud hosting providers, document storage providers, email and messaging providers, customer support tools, and analytics providers. These parties act as data processors where they process data solely on behalf of Sannam S4 and under written instructions.
6.4 Professional advisers and compliance recipients
Sannam S4 may disclose personal data to lawyers, auditors, insurers, or other advisers where reasonably necessary for legal, regulatory, insurance, or business continuity purposes.
6.5 Other disclosures required or permitted by law
Sannam S4 may disclose personal data where required by law, court order, regulatory requirement, or where necessary in connection with legal proceedings or the establishment, exercise, or defence of legal rights.
7. Conditions for disclosure
When Sannam S4 discloses personal data to another organisation, it seeks to ensure that the disclosure is justified, proportionate, and properly managed. We ensure:
- The data disclosure has a lawful and documented purpose;
- Only the minimum personal data reasonably necessary is shared;
- The identity, role, and authority of the receiving organisation are appropriately verified;
- The method of disclosure is suitable and secure for the nature of the data involved; and
- Any sensitive, confidential, or higher-risk disclosure is supported by an appropriate basis, including consent, contract, legal obligation, regulatory requirement, or another valid legal basis, as applicable
8. International Transfers
Navi Japan platform supports study applications to Japan, personal data may be transferred from India to Japan. In addition, some service providers used by Sannam S4 may store or process personal data in other countries.
Where personal data is transferred internationally, we will take reasonable steps to ensure that the personal data receives an appropriate level of protection consistent with applicable law and contractual requirements.
This may include:
- Transferring data where necessary for the performance of services requested by the student;
- Obtaining consent where appropriate;
- Entering into contractual safeguards with vendors and partners; and
- Using service providers with appropriate technical and organisational security measures.
9. How We Protect and Manage Shared Data
Where we engage a service provider to process personal data on our behalf, we ensure that the provider processes that data only within the scope of the services it has been engaged to provide and only under our instructions.
This includes:
Sannam S4 also seeks to ensure that internal handling of personal data is limited to those who require access for legitimate service, operational, or compliance purposes.
10. Artificial Intelligence and Automated Tools
11. Data Retention
Personal data shall be retained only for as long as it is reasonably required for the purposes for which it was collected, processed, or shared. Once personal data is no longer required for those purposes, we shall delete, close, anonymise, or otherwise securely dispose of the relevant records in accordance with our retention practices and any applicable legal or regulatory requirements.
12. Responsibility After Sharing
Where personal data is shared with an educational institution, immigration authority, government body, or another organisation acting in its own capacity as an independent controller, that organisation becomes responsible for how it handles the personal data after receiving it.
Where personal data is shared with a service provider acting on behalf of Sannam S4, that provider may process the personal data only within the scope of its role and subject to the arrangements put in place by Sannam S4.
13. Contact Information
Questions about this Data Processing and Sharing Disclosure, or about how personal data is processed and shared through the Navi Japan platform, should be directed to:
Privacy Office
Sannam S4 Group
Email: dataprotection@sannams4.com
