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APPI

Bot protection under Japan's APPI

Japan's Act on the Protection of Personal Information and the EU recognize each other's protection as equivalent – which makes an EU-hosted, data-minimal CAPTCHA a natural fit for Japanese websites.

  • Entrustment without extra consent
  • EU–Japan mutual adequacy
  • Minimal data footprint

Entrustment, not disclosure

Providing data to a trustee for an outsourced purpose is not a third-party disclosure under the APPI – no additional visitor consent needed.

Mutual adequacy with the EU

Japan's PPC designates the EU as providing equivalent protection, so transfers to our EU data centers work without extra safeguards.

Purpose-limited data

Only the signals needed for bot detection are processed, and personal data is not kept beyond what the verification requires.

APPI compliance checklist

How CaptchaFox lines up with Japan's Act on the Protection of Personal Information.

  • Entrustment within the purpose of use

    Art. 27(5)(i) APPI

    Handing personal data to a trustee for bot protection does not count as third-party provision requiring consent, provided you supervise the trustee – which our contract enables.

  • Cross-border transfer covered

    Art. 28 APPI

    The Personal Information Protection Commission designates the EU as ensuring equivalent standards, so transfers to EU data centers need no additional consent or safeguards.

  • Utilization purpose respected

    Art. 18 APPI

    Data is used solely for the specified purpose – distinguishing humans from bots – and nothing beyond it.

  • Safety management measures

    Art. 23 APPI

    Early anonymization of identifying data and EU data-center security support the safety measures the APPI requires.

  • Purpose disclosure supported

    Art. 21 APPI

    We document exactly what the widget processes so you can state the utilization purpose in your privacy policy.

Frequently asked questions

Everything you need to know. Can't find your answer? Contact our support team.

Is CaptchaFox compliant with Japan's APPI?
Yes. CaptchaFox operates as your trustee under a written contract, processes only minimal data for bot detection and hosts in the EU – which Japan's PPC recognizes as providing equivalent protection.
Can Japanese websites transfer data to EU servers?
Yes. Under the mutual EU–Japan adequacy arrangement, the PPC designates EU member states as ensuring equivalent standards, so no additional consent or safeguards are required for the transfer.
Do I need visitor consent to use CaptchaFox in Japan?
Entrusting data to CaptchaFox for bot protection is not a third-party provision requiring consent under Art. 27(5)(i) APPI. The widget also sets no cookies and stores nothing on the visitor's device.
What should my privacy policy mention?
State bot protection as a utilization purpose, name CaptchaFox (Scoria Labs GmbH) as the trustee, describe the categories of data processed (the IP address and other technical signals used for bot detection) and link to the CaptchaFox end-user privacy policy.

More privacy regulations

Privacy CenterGDPRCCPA / CPRAUK GDPRSwiss nFADPLGPDDPDPAPDPAPIPLPrivacy Act (AU)

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