Privacy Policy

WAYSIDE REPORT (the “Newsletter”) is an email newsletter published by Keita Tsushima (“we”). We handle our readers’ personal information as described below.

1. Information We Collect

• The email address you enter on the registration form and the edition(s) you select (Japanese Edition or Global Edition)
• The date and time of registration and the URL of the page used for registration
• Connection information (such as IP addresses) temporarily processed by the website hosting provider for communication purposes when you browse the website
• Records of opens and link clicks in the emails we send (recorded automatically by the delivery system)
• The content of inquiry emails and the sender’s email address

Since an email address is required to deliver the Newsletter, you cannot register without providing one.

The Newsletter’s website (keitatsushima.com) does not use cookies or web analytics tools.

2. Purposes of Use

• Delivering the Newsletter and managing subscriptions, changes, and unsubscribes
• Improving the Newsletter and its delivery based on records of opens and clicks
• Responding to inquiries (we will obtain your permission before featuring any part of your inquiry in the Newsletter)
• Complying with applicable legal obligations

Records of opens and clicks are used only for statistics to improve the Newsletter and will not be used for any other purpose.

3. Service Providers and Third Parties

To the extent necessary for the purposes above, we entrust the handling of personal information to the following service providers. All of them are based in the United States, and the information is stored on their servers in the United States.

• Newsletter delivery and mailing list management: HubSpot
• Website hosting: Cloudflare
• Inquiry email: Google (Google Workspace)

Transfers to the United States are made under data processing agreements with each provider that include the EU Standard Contractual Clauses.

Except where required by law, we do not provide personal information to third parties without your consent.

4. Retention Period

We retain your information for the duration of your subscription. After you unsubscribe, we delete your information within three months, except for the minimum record necessary to prevent future delivery. Inquiry emails are deleted within one year after the inquiry has been handled.

5. Your Rights

• Unsubscribe: You can unsubscribe at any time via the link at the end of each issue.
• Access, correction, deletion, and other rights: You may exercise your rights of access, rectification, erasure, restriction of processing, data portability, and objection by contacting us using the details below. We will respond after verifying your identity.
• The legal basis for sending the Newsletter and recording opens and clicks is the consent you give at registration. You may withdraw your consent at any time (by unsubscribing); withdrawal does not affect the lawfulness of processing before withdrawal.
• As we are based in Spain, the EU General Data Protection Regulation (GDPR) applies. You may also lodge a complaint with the Spanish Data Protection Agency (AEPD) or the supervisory authority in your country of residence.

6. Security Measures

To prevent unauthorized access, loss, or leakage, we use the access controls and encryption provided by our service providers. On our side, only Keita Tsushima has access to personal information; the providers’ personnel access it only as necessary to provide their services.

7. Revisions

Any revisions to this Privacy Policy will be posted on this page. We will also announce significant changes in the Newsletter.

8. Contact

Keita Tsushima (WAYSIDE REPORT)
Ronda de Sant Pau, 47, Local 1, Barcelona, 08015, Spain
qa@keitatsushima.com

Effective date: October 18, 2026