EncTalk Privacy Policy
1.Introduction
We, EncTalk Corporation (“EncTalk,”
“we,” “us,” or
“our”), will collect
information related to individuals (“Personal Data”) in providing our EncTalk communication app (“EncTalk App”) and all products, apps,
services and websites related to the EncTalk App (collectively, the “Services”). We consider the protection of
Personal Data to be one of the most important management issues as a responsibility
of an Internet content service company. We will act in compliance with the laws
and regulations applicable in countries and regions where we are conducting
business (such laws and regulations are hereinafter collectively referred to as
the “Applicable Laws”), and
will make efforts to properly protect Personal Data based on this Privacy
Policy (this “Policy”).
This “Policy” explains what
kind of Personal Data we will collect, and how we will use and share such
Personal Data, and how you can manage your own Personal Data.
2.Applicable scope of this Policy
This Policy applies to all Personal Data that is collected in relation to our Services regardless of the country or region where our Services are being used.
2.a.Target services and service provider
This Policy applies to all Personal Data that is collected in relation to our Services.
We may apply individual privacy policies or additional provisions to terms of use or this Policy (collectively, “Individual Policies”) to specific services. The Individual Policies explain what kind of Personal Data we will collect, and how we will use and share such Personal Data, for such specific services, and the other policies that are applicable to such specific services. If there is any inconsistency between the subject matter of the Individual Policies and this Policy, the Individual Policies shall prevail.
In connection with the application of this Policy, EncTalk is the controller of the processing of Personal Data.
2.b.Applicable countries and regions
We will process Personal Data only to the extent permitted under the Applicable Laws according to this Policy and only within the scope described in this Policy.
While we may provide various translations of this Policy as a reference, to the extent permitted under Applicable Laws, the Japanese version applies to users using our Services in Japan, the Korean version applies to users using our Services in Korea, and the English versionapplies to users using our Services in other countries or regions.
3.Personal Data to be collected
We will collect the following Personal Data:
●
Information that you provide to us such as your phone number that you register
at the time of creating an account, and profile information that you set at the
time of using our Services
● Information related to your status of use of our
Services such as the text, image, video and other contents that you post, and
your access log
● In cases where you create a EncTalk account using an
external SNS account, information collected from a third party such as the
identifier of the external SNS account that we will collect from that third
party
● Information related to you which is posted by other
users such as an image of your face photo posted by your friend
● Information collected externally such as information
to be collected via a EncTalk App plug-in installed in a third-party app, such
as “Like”
● Public information containing Personal Data such as
online news published on the internet
We will collect the following types of Personal Data in providing our Services. If you do not provide certain types of information such as your phone number which needs to be registered for using our Services, you may not be able to use all or a part of our Services.
3.a.Personal Data to be provided by you
3.a.i.Information to be registered at the time of creating an account
Before you start using our Services, we may ask you to provide your contact information for creating a EncTalk account (“Account”).
For example:
●
In order to create an Account, you need to register your phone number.
Please note that we assign an internal identification code (“Internal Identifier”) to each Account created by our users.
3.a.ii.Information to be registered for accessing your Account from multiple devices or transferring your Account from one device to another
If you wish to access your Account from multiple devices, or wish to transfer your Account from one device to another, you may need to register your phone number or email address in addition to the information that you registered at the time that you created your Account.
3.a.iii.Information required for communication and transaction
When you wish to use a specific service to purchase a product, make an inquiry or participate in a promotional event or survey, we may ask you to provide information required for communicating with you and conducting transactions with you depending on the nature of the transaction, and collect and store such information.
For example:
●
In order for us to answer any requests or questions that you send to our
customer support, we may ask you to provide information required for
identifying and investigating the event or resolving the problem, such as your
contact information including your phone number or email address, and details
of the trouble that you have encountered.
● If you choose to participate in surveys or
promotional events, we may ask you to provide information such as your name,
address, phone number, email address, gender, and date of birth in order to
verify your identity, enable you to participate in a drawing, and to deliver any
prizes you may win.
● If you purchase a product or a service, you will be
required to provide information for making the payment of such product or
service. Since credit card settlements are processed by appropriate third-party
payment agencies, we will not retain your credit card number or security code.
3.a.iiii.Profile and information related to your friend relationship
When you use our Services, we will collect the profile that you set, and information related to your friend relationship.
Profile information
Profile information includes information such as the icon image, display name,
status message, search ID (“EncTalk ID”) and birthday that you set or disclose in order to connect to other
users. Profile information (excluding information that you set as “private”) will be disclosed and made
available to other users and third parties such as companies operating an
official account. A EncTalk ID is an identification name set in your Account to
make it easier for your friends to find you in our Services, and your friends
can find you through your EncTalk ID. You may also choose not to allow other
users to contact you using your EncTalk ID.
Address book
We offer an “Auto Add Friends” feature which automatically adds other users as your friends in our
Services when you upload information of your friend in your address book on
your device. We will access only the phone numbers registered in your mobile
device’s address book only when you have enabled this
feature.
We will use the phone numbers in your address book only for automatically
adding your friends, recommending possible friends, and preventing unauthorized
use.
3.b.Personal Data to be collected in connection with your use of our Services
3.b.i.Status of use of our Services
We automatically collect information related to when and how you used our Services. The collected information includes the status of use of various features such as the date and time that you activated our individual apps, length of time that you used our individual services, results of searches conducted in the apps, additional services that were purchased, and contents and ads that were viewed or tapped.
Posts and reactions
to posts
In distributing your posts to other users, the contents that you posted are
sent via our server.
For example, standard contents such as emoji, stickers and location information
and non-standard contents such as text, image, video and audio that you post
are all sent via our server. In addition, external information such as the
recipient of the contents, data format, date and time of the posting, and other
information on how you are interacting with your counterparty is also recorded
in the server. URL information that you tapped or clicked in our Services is
also recorded in the server.
Furthermore, in distributing reactions or replies to the posts of other users,
we collect and use information related to how you reacted to the posts of other
users. This information includes the action that you took against the
distribution by other users, and the time and date of such action, such as
whether you viewed the text, image or video of messages that you received, and
whether you clicked “Like” for the posts of users on your EncTalk VOOM.
In principle, we will not use private posts, as such messages exchanged between
users, for any purpose other than distributing such posts. However, in certain
countries or regions (*1) for specific services, we may use a part of such
information upon obtaining your additional consent for the provision and
maintenance of services, development and improvement of services, prevention of
unauthorized use, and provision of optimized contents including ads. For
details, please refer to “Regarding Usage of Your Information”
and the terms of the individual services.
3.b.ii.Location information
We may collect the location information of your device when you share your location information with your friends, or in order for us to provide optimized search results to you. When you do not accept sending your location information by your mobile device settings, location information will not be sent to us.
Furthermore, in certain countries or regions (*2), when we provide customized contents or ads to you, such as weather forecasts and local news near the areas where you are located, we may separately ask you to generally provide your location information. In the foregoing case, you may at any time choose not to provide your location information by your EncTalk App settings.
Even when you do not accept sending your location information, we may estimate your approximate location from network information such as your IP address.
3.b.iii.Apps, browsers, devices and network information
We will collect
information related to the device, browser and the app that you are using (ad
identifier for identifying the device/browser, Cookie ID and device type, OS,
language/time zone setting, browser type, app version, etc.), and network
information (telecommunications carrier’s
name, IP address, etc.).
We may also associate the collected ad identifier with the Internal Identifier.
3.c.Personal Data collected from third parties
We may collect Personal Data from third
parties including our group companies (referring to our subsidiaries or
affiliates, wherein the definition thereof includes domestic and overseas
subsidiaries and affiliates according to the “Regulation
on Terminology, Forms, and Preparation Methods of Financial Statements” of Japan; hereinafter the same).
For example, we will collect Personal Data from third parties in the following
cases.
3.c.i.Personal Data collected from group companies
We may collect your Personal Data from our group companies according to their terms or policies. For the privacy policy that is applicable to the individual services provided by our group companies, please confirm the same in the individual services.
3.c.ii.Personal Data collected from business partners
We may collect your
Personal Data from our business partners. There are cases where we collect
Personal Data from a business partner operating its own service, and from a
business partner operating a service that is linked to our Services such as an
official account or EncTalk App login. For example, when you create your
Account using an external SNS account, we will collect the identifier of that
external SNS account.
In addition, we may obtain information such as your identifier (Internal
Identifier, ad identifier etc.), one-way encrypted (hashed) email address and
telephone number, IP address, part of your device information (OS, etc.), your
attribute information and your action history, including your purchase and
browsing history, from our business partners, in order to use the same for both
sending official account messages from our business partners and distributing
ads, as well as measuring ad effectiveness, creating and providing statistical
information and for other purposes.
3.d.Personal Data uploaded by other users
There may be cases where a certain user, in using our Services, uploads information containing Personal Data such as a photo that includes a third party other than that user, and we collect such information.
3.e.Personal Data that is directly collected from third-party services
We may collect login records from plug-ins of third-party websites and apps equipped with a plug-in feature such as “Send by EncTalk” or “Like”, and URL information of websites equipped with a plug-in feature that you visited while being logged onto the EncTalk app on your browser by associating such login records and URL information with your EncTalk Account. Such collected data will be used for understanding how you are using our Services, as well as for the maintenance and improvement, security, and prevention of unauthorized or fraudulent use or abuse, of such Services. When you are logged out of the EncTalk App, the foregoing information will be used only for the purpose of security and prevention of unauthorized or fraudulent use or abuse in a form where individuals cannot be specified.
Furthermore, in certain countries or regions, when our business partner uses our Services, we may collect the following Personal Data.
●
Information such as the access history (including date and time of access, URL,
etc.) of the website that you accessed from your browser.
For example, if our business partner has introduced our tracking service to
display ads on our Services only to users who visited a specific page of a website
operated by that business partner, we will collect the access history of that
business partner’s website, and use such information
for the optimal ad distribution on our Services. In order to perform the
foregoing optimal ad distribution, we may use cookies and associate your access
history with the ad identifier or Internal Identifier. You can delete cookies
at any time from your browser. (*3)
● History of service use on web app in which our
business partner is the service provider.
For example, if our business partner has introduced our access analyzing
service to confirm the status of use of its web app service or improve its
services, we will collect your history of use of that business partner’s services, and provide your status of use in the form of statistics
to the business partner.
When we directly collect Personal Data from services operated by a third party such as when our business partner uses our Services as described above, we request our business partner to take lawful and proper measures.
3.f.Collection of Personal Data from public information
We will collect public information, such as
online news published on the internet, for use in search services, etc.
If the collected public information contains Personal Data, we may use such information
for registration in the search engine index or display of search results.
4.Purpose of use of Personal Data
We will use Personal Data for the following
purposes:
●
Provision and maintenance of services;
● Development and improvement of services and contents;
● Prevention of unauthorized use such as unauthorized
access; and/or
● Provision of contents optimized for you.
We use Personal Data to provide our Services to users, for utilization in research and development to provide safer and better services, and to provide services that are strongly linked to users, including ads. We will not process the Personal Data we obtain beyond the scope of the purposes of use, except to the extent that consent has been obtained from you or as permitted by the Applicable Laws. In addition, we will take appropriate measures to ensure that Personal Data is not used for any other purpose. The specific uses of Personal Data are as follows.
4.a.Provision and maintenance of services
We will use information required for
providing services that you requested, answering your inquiries, and hosting
promotional events.
For example, in the following cases, we will use Personal Data for the
provision and maintenance of services.
●
To verify your identity, through comparison with your registered information,
when you log onto the EncTalk App or succeed your Account in changing your
device;
● To post messages or convey the status of “read” of posted messages;
● To confirm the history of messages viewed with a
certain device on a different device;
● To set or disclose profiles for building and managing
connections between users, and to search for other users using the registered
information, or enable such search;
● To process invoices when a user purchases a product
or uses a paid service;
● To examine your status of use of our Services in
order to reply to your inquiry to our customer support;
● To deliver any prizes you may have won in a
promotional event to your designated address; and/or
● To notify you of important changes to our Services
such as the revision of terms, planned discontinuation of services, or change
of features.
4.b.Development and improvement of services and contents
We will use Personal Data for the
development and improvement of our Services for providing better services,
products and contents to users toward the future.
For example, in the following cases, we will use Personal Data for the
development and improvement of services and contents:
●
To improve our Services by creating statistics and models related to the use of
our Services;
● To develop new services and contents by understanding
the trend from the purchase history of stickers;
● To improve the screen design by understanding the
frequency that each tab in the app is being used; or
● To conduct surveys related to our services that we
are currently providing, or may provide in the future.
4.c.Security and prevention of unauthorized use
We will use Personal Data and promote
security measures and measures against unauthorized use to maintain an environment
where our Services can be used at all times, and users can use our Services
with a sense of security on a daily basis.
For example, in the following cases, we will use Personal Data for the security
and prevention of unauthorized use:
●
To confirm whether there is any breach of terms of use, any illegal act,
unauthorized access or any other unauthorized use;
● To monitor and confirm the details of reports and
illegal postings, etc., and to develop tools for preventing unauthorized use by
ways such as analyzing the details of such reports and illegal postings, etc.;
or
● To verify facts or contact you in the event of any
unauthorized use or the possibility of any unauthorized use.
4.d.Provision of contents optimized for you
We will utilize Personal Data for providing
recommended contents, including ads, to each user.
For example, in the following cases, we will use Personal Data for providing
optimized contents to users:
●
To display recommendations of other stickers with a strong relevance with the
purchased sticker;
● When there is another user who has added as a friend
an official account that is the same as the official account that you have
added as a friend, to introduce another official account that such user has
added as a friend;
● To measure the effectiveness of the distributed ad;
or
● To send and distribute official account messages and
surveys, etc. to you by ways such as associating or combining information
obtained from our business partners, such as your identifier (Internal
Identifier, ad identifier, etc.), hashed telephone number and email address,
with your Personal Data that we possess.
Furthermore, in certain countries or regions (*3), we will use Personal Data for distributing recommended contents, such as optimized ads, to users. Such use includes the following examples:
●
To distribute information of strong relevance to your current location
regarding facilities, attractions, coupons, etc. to be provided through an
official account;
● To introduce information of events being conducted and
valuable coupons that can be used, near your current location or places where
you often visit;
● To display ads related to our business partner’s website that you accessed;
● To estimate attributes such as the gender, age group,
and interests of users from the official accounts that have been added as a
friend, purchased stickers, Services that are often used, contents that were
recently posted on EncTalk VOOM, and history of service use such as search
words that were recently used, and distribute our ads or third-party ads that
may of interest to users having similar attributes;
● To distribute our ads or third-party ads with
Personal Data such as the birthday, phone number and email address registered
by users (including cases of distributing ads of our Services on services
operated by third parties) as the key;
● To distribute ads to you by ways such as associating
or combining information obtained from our business partners, such as your
identifier (Internal Identifier, ad identifier, etc.), hashed telephone number
and email address, part of your device information (OS, etc.) and IP address,
with your Personal Data that we possess;
● To measure the effectiveness of distributed ads by
ways such as using your identifier (Internal Identifier, ad identifier, etc.),
part of your device information (OS, etc.) and IP address, etc. obtained from
our business partners; or
● To provide our business partners with statistical
information prepared by ways such as associating or combining information
obtained from our business partners, such as your identifier (Internal
Identifier, ad identifier, etc.), hashed telephone number and email address,
attribute information, and your action history, including your purchase and
browsing history, with your Personal Data that we possess, such as your
identifier (Internal Identifier, ad identifier, etc.), hashed telephone number
and email addresses, attribute information and your status of use of our
Services, including your history of accessing ads.
We are offering a detailed explanation to users residing in countries or regions where this feature is available. For details, please refer to “Optimization of services by attributes” (page is provided only in the language of the country that is offering the feature).
In principle, we obtain your consent when we process your Personal Data. If, however, permitted under Applicable Laws, we may process your Personal Data with any of the following legal basis:
(1) processing is
necessary for the performance of a contract to which you are party or in order
to take steps at your request prior to entering into a contract;
(2) processing is necessary for compliance with a legal obligation to which we
are subject (e.g., when following the information disclosure orders based upon
laws and regulations announced by government agencies);
(3) processing is necessary in order to protect vital interests of yours or of
another individual;
(4) processing is necessary to investigate, prevent and take measures against
illegal or suspected illegal acts;
(5) processing is necessary for the legitimate interests pursued by us or by a
third party, except where such interests are overridden by your privacy related
rights, interests, and freedom (including improvement of operations or systems,
prevention of fraud, maintenance of security, marketing, and research performed
by us); or
(6) processing is necessary for any purpose related to public benefits or
creation of archives of historical documents, or any purpose related to surveys
or statistics supported by proper security measures.
For example, when we process your Personal Data for the provision and maintenance
of services, development and improvement of services, and security and
prevention of unauthorized use, such processing may be pursuant to the legal
basis of legitimate interests indicated in (5) above.
5.Provision of Personal Data
We will not provide, disclose or share
Personal Data to or with third parties unless we have obtained your consent or
such provision, disclosure or sharing of Personal Data is permitted under
Applicable Laws.
We may transfer Personal Data to a third country without any data protection
laws which are equivalent to those of the country or region where you live when
we have obtained your consent or such transfer of Personal Data is permitted
under Applicable Laws.
In principle, we
will not provide Personal Data to third parties unless we have obtained your
consent or such provision of Personal Data is permitted under Applicable Laws.
However, in the following cases, we may provide Personal Data to third parties.
The recipients of Personal Data that we provide include third parties such as
our subcontractors, subsidiaries, and affiliates located in countries or
regions other than where you are residing. (Please click here to confirm
the information of the systems regarding the protection of Personal Data in the
countries or regions in which third-party recipients of Personal Data are
located.)
In order to provide our services in a smooth manner, subcontractors,
subsidiaries and affiliates, etc. may be added to the recipients of Personal
Data that we provide. We will notify you via this Policy upon the addition of
any country or region in which the third-party recipient of Personal Data is
located.
In providing Personal Data, we may transfer Personal Data to a third country without any data protection laws which are equivalent to those of the country or region where you live (as of January 23, 2019, the European Commission has determined that Japan has secured sufficient protection standards regarding Personal Data). In the foregoing case, we will adopt standard contractual clauses or other means pertaining to data protection approved in your country or region, and transfer Personal Data to a third country according to the requirements of Applicable Laws.
5.a.Public disclosure by users themselves
The profile information that you registered will be processed as public information. For details, please refer to [Profile information] of 3.a.
Messages that you posted, posts made on EncTalk VOOM and bulletin boards, and actions such as “Like” and comments to posts of other users will be made available to third parties according to your disclosure setting and address.
The foregoing information may be copied, stored or spread by the recipient, and accessed by an unintended third-party recipient, due to the nature of digital data. When setting your profile or posting on our Services, please pay attention to the contents and scope of disclosure of such post.
5.b.Subcontracting
We may subcontract certain services required
for providing our Services (e.g.: building and operation of infrastructure,
settlement, shipping, customer support, etc.) to a third party. In connection
with this, we may entrust all or a part of the Personal Data to the
subcontractor, including companies located in the following countries or
regions.
The subcontractor will access the Personal Data only to the minimum extent
required for performing the subcontracted services on our behalf, and will not
use the Personal Data beyond the scope of the subcontracted services.
We will: (i) comply with Applicable Laws and sufficiently investigate the
qualification as a subcontractor; (ii) take measures to have the subcontractor
comply with the eight (8) principles under the OECD Privacy Guidelines by ways
such as prescribing matters related to confidentiality and data protection in
the contract with the subcontractor; and (iii) thereby establish a system for
properly managing Personal Data.
Countries and regions to which Personal Data is transferred: Japan, Korea, Vietnam, Thailand, Taiwan, Indonesia and the Philippines.
5.c.Sharing of Personal Data among group companies
With respect to users using our Services in
certain countries or regions (*4), we may share, among our group companies,
including companies located in the following countries and regions, the
Personal Data indicated in “3. Personal Data to
be collected”. For example, in order
to alleviate the trouble of creating an Account in the services provided by our
group companies, our group companies may refer to the information registered
with the EncTalk App.
As the purpose of sharing Personal Data is the same as the purpose of use
described in “4. Purpose of use
of Personal Data”, for the purpose of use
of the party with which the Personal Data was shared, “EncTalk” shall be replaced with “our group company”, and “Services”
shall be replaced with “services provided by our group
company”.
EncTalk is the administrator in sharing Personal Data under the laws of Japan.
We will take measures to have our group companies with which the Personal Data
is shared comply with the eight (8) principles under the OECD Privacy
Guidelines by ways such as prescribing matters related to confidentiality and
data protection in the contract with such group company, and thereby establish
a system for properly managing Personal Data.
You can confirm our group companies in “List of Group Companies”.
In addition, please click here for the scope of our group companies to share Personal Data of users in Taiwan.
Countries and regions to which Personal Data is transferred: Japan, Taiwan, Thailand, Indonesia,Korea and Singapore.
5.d.Succession of business
If there is any transaction between companies pertaining to our business to which this Policy is applicable, such as acquisition, merger or change of business entity, Personal Data may also be transferred to the successor of the business to the extent permitted under Applicable Laws.
5.e.Provision of services and ad distribution through collaboration with other companies
In cases where you use the services of our
business partner, we may provide, to that business partner, information to be
used by the business partner for identifying you (in certain countries or
regions (*5), in addition to the Internal Identifier, including an ad
identifier, device information such as the language setting, and attribute
information).
For example,
●
When you add an official account as a friend, talk to an official account, and
enter a group talk room in which an official account is participating, minimum
information required for sending messages to you, such as the Internal
Identifier assigned to your Account and the language setting, will be sent in
order to provide our services in a smooth manner. (Please click here to confirm
the countries and regions in which the operators of official accounts receiving
information are located and the information concerning information protection
measures.) In certain services or features for some businesses, we may ask that
you provide additional Personal Data such as your email address or phone
number. In the foregoing case, we will additionally ask for your permission
regarding the provision of additional Personal Data to such businesses before
you use such services or features.
●
When our business partner is equipped with an additional service such as the EncTalk
App login function, your Internal Identifier, profile information, email
address or phone number may be shared with the business partner once you use
such additional service. In the foregoing case, we will ask for your permission
regarding the provision of Personal Data.
● In certain countries or regions (*5), we may provide
and disclose your Internal Identifier, part of your device information (ad
identifier, language setting, etc.), IP address, and your attributes to our
business partner, including companies located in the following countries or
regions, engaged in the distribution of ads, effectiveness measurement and
analysis to distribute ads with stronger relevance to you. Information such as
your name, address, and phone number, which can be used for communicating with
you or confirming your identity, will not be provided without your separate
declaration of intent. For details regarding such strongly relevant ads, please
also read “Optimization of services by attributes”.
The processing of Personal Data by our business partner shall be pursuant to the terms or policies prescribed by each business partner.
Our business partners receiving Personal Data which are located in the following countries and regions are taking measures in compliance with the eight (8) principles under the OECD Privacy Guidelines.
Countries and regions to which Personal Information is transferred: United States and Israel.
5.f.Compliance and cooperation with public agencies
If we receive a request pursuant to legal proceedings such as a warrant, or if there is imminent danger to someone’s life or property such as a suicide threat or a bomb threat, we may disclose Personal Data to third parties including law enforcement agencies such as the police, or the court, pursuant to Applicable Laws. For details regarding the disclosure of Personal Data to public agencies, please refer to our Transparency report.
6.Safety control of Personal Data
We will take strict technical and
organizational security measures in managing the collected Personal Data. In
order to continue to improve our protection of Personal Data, we will review
and bolster our internal rules and regulations in accordance with changes in
laws and social norms.
Unless you request the deletion of your Account, in principle, we will retain
most of your information. Once we receive your request to delete your Account,
we will delete your information according to Applicable Laws and internal rules
after retaining such information for a given period of time.
6.a.Security measures
We are taking strict technical and
organizational security measures in managing the collected Personal Data for
respecting and protecting your privacy and confidentiality of your Personal
Data, and preventing unauthorized access to your Personal Data. These measures
include safety control measures based on industry standards for preventing
unauthorized access to Personal Data, and disclosure, unauthorized use,
falsification or destruction of Personal Data.
For example, we are taking the following measures.
●
Provision of encryption feature of messages
● Strict access control based on a need-to-know basis
● 24/7 security monitoring
● External authentication for objectively evaluating
our security measures
● R&D of new security technologies
Furthermore, we
will never provide any means for fraudulently accessing Personal Data to a
third party.
For details regarding our security measures, please also read “Security & Privacy”.
However, because no method of electronic transmission or method of data storage
is perfect or impenetrable, we cannot guarantee that your Personal Data will be
absolutely safe from intrusion during transmission or while stored in our
systems.
To help protect your privacy and confidentiality of your Personal Data, we also
need your help. Please do not share your password with others, or use the same
passwords you use for other services. Also, please notify us in the event you
suspect any unauthorized use of your Account or any other breach of security
via our Contact Form.
6.b.Storage location of Personal Data
In providing our Services, we may store
your Personal Data outside the country or region where you reside. When that
happens, we will take measures to ensure your Personal Data is transferred
according to the applicable laws.
For details regarding the storage location of your Personal Data, please also
read “Security & Privacy”.
6.c.Storage period of Personal Data
EncTalk collects and retains Personal Data
to provide our Services according to your request, fulfill any of the
applicable purposes of use described in this Policy, or to comply with
Applicable Laws.
Unless you request the deletion of your Account, in principle, we will retain
most of your Personal Data. Once your Account is deleted, we will process your
Personal Data properly according to Applicable Laws and our internal rules
after retaining such Personal Data for a given period of time for the following
purposes:
●
to reply to inquiries;
● to resolve disputes or collect fees;
● to detect and deter fraudulent use of, or abuse of,
our Services; or
● to comply with Applicable Laws.
Otherwise, we prescribe the storage period of Personal Data according to the following standards.
●
We will not in any way use highly private information such as texts, images,
videos and audio data sent in a talk room between users for any purpose other
than the distribution of messages (including retransmission in the event of a
communication failure or synchronization of messages from multiple devices)
unless we have obtained your consent or such use is permitted under Applicable
Laws. While we will retain the foregoing information for a minimum period, such
information will subsequently be automatically deleted from our server.
● The delivery address information that we obtained for
shipping the product collected in a promotional event will be deleted after a
given period of time, for resolving disputes, after the shipment of the product
is complete. Information that we collected for a specific purpose as described
above will be promptly deleted after the lapse of a reasonable period once the
purpose of such information is fulfilled.
● If you have expressly declared your intent to store
your Personal Data, we may respect your intent and store your Personal Data for
a long period. For example, we are providing a feature, such as the Keep
feature of our EncTalk App, to users for expressly storing/deleting
information.
● If a storage period is prescribed under Applicable
Laws or the like, we will store Personal Data according to such storage period.
We may continue to retain Personal Data in a format in which individuals cannot be identified after the lapse of the storage period prescribed pursuant to Applicable Laws and our internal rules.
7.Your choices regarding Personal Data
You have rights regarding your Personal
Data processed by us, such as the right to access your Personal Data and the
right to correct your Personal Data, to the extent permitted under Applicable
Laws.
We are exerting efforts to provide, in our Services, features which enable you
to personally edit your profile, and set and manage the collection, use and
sharing of your Personal Data.
To the extent
permitted under Applicable Laws, regarding your Personal Data that we process,
you have the right to access, the right to rectification, the right to erasure,
the right to restriction of processing, the right to withdrawal of your
consent, the right to data portability, the right to confirm if we process any
Personal Data of yours, and the right to request a review of any automated
decisions that may be made as a result of the processing.
In addition, to the extent permitted under Applicable Laws, you also have the
right to object to the processing of your Personal Data that we process in
certain cases.
We are exerting efforts to provide, in our Services, features which enable you
to personally manage your Personal Data on the EncTalk App, edit your profile,
set the collection, use and sharing of your Personal Data, and set and manage
your Personal Data including the scope of disclosure of posts, opt-out of ads,
and deletion of your Account. Please periodically confirm that no old
information or inaccurate information is remaining, and properly update your
Personal Data.
Specifically, we provide the following features:
●
Confirmation and change of public profile information, and setting of the EncTalk
ID
● Setting and change of phone number and email address,
deletion of email address, and de-link of your Facebook account
● Whether to allow other users to contact you by using
your EncTalk ID
● Whether to allow other users, who already have your
phone number, to reach you via the EncTalk App
● Whether to add contacts automatically using the address
book in your device
● Whether to allow third parties to view your Personal
Data retained by your friend
We also provide the following features in certain countries or regions:
●
Whether to allow the use of information for improving our services (*1)
● Deletion of location information (*2)
● Whether to receive strongly relevant ads (*3)
If you wish to
exercise your right against us to disclose your Personal Data that cannot be
confirmed in our Services, correct or delete your Personal Data that is contrary
to facts, notify you of the purpose of use of your Personal Data, or other
rights permitted under Applicable Laws, you may contact us using the Contact Form.
After verification of your identity, we will respond to your request within a
reasonable period of time, and in accordance with relevant laws. If you would
like to send us a written request, please refer our mailing address indicated
later.
If, however, permitted under Applicable Laws, we may not be able to respond to
your request when any of the following applies:
●
disclosure is likely to harm the life, body, property, or other rights or
interests of yours or another individual;
● disclosure is likely to seriously impede the proper
execution of our business;
● disclosure violates other laws and regulations;
● when you failed to verify your identity upon your
disclosure request; or
● we are otherwise permitted under Applicable Laws to
refuse your request.
If you no longer wish to use our Services or if you withdraw your consent to EncTalk’s processing of your Personal Data which is necessary for us to provide our Services, you may choose to delete your entire Account. However, the withdrawal of your consent will not in any way affect the lawfulness of our processing of your Personal Data based on your consent that was given before the foregoing withdrawal.
If you have any requests or complaints related to our use of your Personal Data, please contact us at any time using the Contact Form.
Unless prohibited under Applicable Laws, if you exercise any of your rights hereunder, we may charge a fee, in accordance with the procedures defined separately.
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