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APPI

Articles about "APPI"

3 articles

Is Sending Personal Data to an LLM API a Cross-Border Transfer? Reading Article 28 of Japan's APPI From the Text

If you put a prompt into an overseas LLM API, is that a cross-border provision under Article 28 of Japan's personal data protection act? The Commission's generative AI alert contains no reference to Article 28, to "a third party in a foreign country" or to cross-border transfers. Here is what the statute, Enforcement Rules 16, 17 and 18, the Guidelines and Q&A items Q7-53 and Q12-4 actually say.

2026-09-06Ryuta Hamamoto

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Which Government Can Reach Your Data Abroad? Reading the CLOUD Act, China's Intelligence Law and GDPR Article 48

US law says disclose "regardless of whether" the data sits inside or outside the country. GDPR Article 48 says a foreign order is enforceable only through an international agreement. Japan's cabinet has stated that the "based on laws" exemption covers Japanese law only. Here is what the texts actually say, and where we stand.

2026-09-06Ryuta Hamamoto

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Can You Actually Run an LLM Inside Japan? What the Providers' Own Docs Say

"Available in the Tokyo region" and "processed only in the Tokyo region" are two different claims. Read the official documentation from AWS, Microsoft and Google and a pattern shows up: the newer the model, the less likely it can stay inside Japan. Here is what the docs actually say, and which rules genuinely require domestic processing.

2026-09-05Ryuta Hamamoto