> BowNow B2B marketing automation under GDPR: which cookies are installed, when consent is required, and how to safeguard transfers from the EEA to Japan. > > Canonical: https://www.flowconsent.com/en/services/marketing/bownow Marketing # BowNow Marketing · [Official website](https://bow-now.jp) BowNow is a Japanese B2B marketing automation platform by Cloud Circus that identifies company visitors via JavaScript tracking, scores leads and triggers marketing flows. Under GDPR and ePrivacy, prior consent is required before its tags load. [Block BowNow until consent](https://app.flowconsent.com/auth/sign-up?utm_source=flowconsent.com\&utm_medium=referral\&utm_campaign=marketing) · [Scan my site](https://www.flowconsent.com/en/scan) At a glance - Category [Marketing](https://www.flowconsent.com/en/services/marketing) - Consent Marketing - Prior consent Required - Documented cookies 3 - Third-party domains 3 - Servers Japan (Cloud Circus, Inc., based in Tokyo). Service primarily targets the Japanese B2B market. Overview ## What does BowNow do? ## **What is BowNow** BowNow is a B2B marketing automation platform developed by Cloud Circus, Inc. in Tokyo. It is widely used in Japan to identify the companies behind anonymous website visitors via reverse IP lookup, score leads, send segmented emails and trigger marketing flows based on browsing behaviour. ## **Cookies and data collected** BowNow installs first party cookies and stores identifiers in local storage to recognize visitors across sessions. It collects IP address, user agent, page views, time on site, form submissions and matches IPs against a corporate database to enrich each lead with company name, industry and size. ## **GDPR and ePrivacy implications** BowNow tracking goes beyond strictly necessary functionality and constitutes profiling. Article 5(3) of the ePrivacy Directive and Article 6(1)(a) GDPR therefore require prior, informed and granular consent before the tag loads. Reverse IP identification can also identify natural persons, especially in small companies, so the resulting data is personal data. ## **International data transfers** Data is transferred to BowNow servers in Japan. Japan has held an EU adequacy decision since 2019, so Standard Contractual Clauses are not strictly required, but the transfer must still appear in the Records of Processing. Verify which regional data centre is used and whether US sub processors are involved (e.g. for email delivery). ## **Implementing consent correctly** Block the BowNow tag in the strictly necessary state. A Consent Management Platform should load the script only after explicit opt in to the marketing or analytics category. On withdrawal, clear all BowNow cookies and stop sending events. Provide an easy way to access, rectify or erase BowNow lead data. ## **Practical compliance steps** Sign a data processing agreement with Cloud Circus, document BowNow in the Records of Processing, define a clear retention policy for lead and tracking data, list each cookie in your cookie policy, train marketing and sales teams on the legal basis used, and audit your live site to verify the cookies actually written. Compliance ## BowNow and the GDPR BowNow is classified as “Marketing”. On a site that targets European visitors, it must only load after the visitor consents, and it must be listed in your cookie policy. - Legal basis Consent (Art. 6(1)(a) GDPR) is required because BowNow installs non essential cookies and identifies visitor companies for marketing purposes. Legitimate interest may apply to lead data submitted explicitly via forms (Art. 6(1)(f)) but only with a documented balancing test. - Risk level medium - Applicable regulations GDPR, ePrivacy Directive, APPI (Japan Act on Protection of Personal Information) ### Impact assessment (DPIA) A DPIA is recommended whenever BowNow is used to score leads, profile companies or combine reverse IP identification with personal lead data. Document the company identification process, retention, and the international transfer to Japan. ### Sample text for your banner > We use BowNow to identify visiting companies and improve our B2B marketing. This installs cookies and transfers data to BowNow (Japan). You can refuse marketing cookies at any time. Cookies and trackers ## What BowNow sets and contacts - Tracking method JavaScript tracking tag installed on B2B websites to identify company visitors via reverse IP lookup, capture lead data from forms, score leads, and trigger marketing automation. Uses cookies, local storage and IP enrichment databases. - Server location Japan (Cloud Circus, Inc., based in Tokyo). Service primarily targets the Japanese B2B market. - Data transferred outside the EU Personal and pseudonymous data (cookies, IP, form submissions) is transferred to BowNow servers in Japan. Japan has an EU adequacy decision (since 2019), but the transfer must still be documented in the records of processing. ### Cookies set (3) | Name | Type | Duration | Purpose | | -------------- | ------------ | -------- | ----------------------------------------------------------------------------------------------- | | \_bownow\_uid | first\_party | 1 year | Persistent visitor identifier used to recognize visitors across sessions for B2B lead tracking. | | \_bownow\_sid | first\_party | Session | Session identifier used to associate page views and form submissions in the same visit. | | \_bownow\_lead | first\_party | 6 months | Stores lead information once a form is submitted to support marketing automation flows. | ### Third-party domains contacted (3) - `bownow.jp` - `tag.bownow.jp` - `app.bownow.jp` Questions ## Frequently asked questions about BowNow Can't find your question? Write to us, we answer fast. [Write to us](https://www.flowconsent.com/en/demo) ### What cookies does BowNow set? BowNow installs first party cookies (e.g. \_bownow\_uid, \_bownow\_sid) and stores identifiers in local storage to recognize visitors across sessions. Additional cookies appear when forms or chat are integrated into the site. ### Is consent required for BowNow? Yes. BowNow performs profiling and reverse IP identification beyond strictly necessary functions. Prior, granular and revocable consent is mandatory under Article 5(3) of the ePrivacy Directive and Article 6(1)(a) GDPR. ### What is the legal basis? Consent (Art. 6(1)(a) GDPR) for tracking and reverse IP identification. Form data submitted explicitly may rely on contract performance (Art. 6(1)(b)) or legitimate interest (Art. 6(1)(f)) with a documented balancing test. ### Are there transfers outside the EEA? Yes, data is transferred to BowNow servers in Japan. Japan benefits from an EU adequacy decision (2019), so SCC are not strictly required, but the transfer must still be documented in the records of processing. ### Is a DPIA required? A DPIA is recommended whenever BowNow performs systematic profiling, lead scoring or combines reverse IP identification with personal lead data, all of which are listed as elevated risk by EU supervisory authorities. ### How do I implement BowNow compliantly? Block the tag until consent, configure short retention for lead and tracking data, sign a DPA with Cloud Circus, publish each cookie in your cookie policy, run a regular audit of the live site and offer easy access, rectification and erasure routes for prospects. ### Are there alternatives? European B2B marketing automation platforms include Plezi, Webmecanik, Sendinblue (Brevo), Mautic (open source) and HubSpot EU. They can match BowNow features while keeping data inside the EEA. ### How do I update the cookie policy? 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