rinna Co., Ltd (the "Company") sets forth this Privacy Policy (this “Policy”) with regard to the treatment of personal data, including personal information, in the course of the performance of Service provided by the Company (the “Service”) as follows;
For the purposes of this Policy, “Personal Data” means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person, that are collected by the Company pursuant to this Policy.
The Personal Data that the Company may collect in the course of the Service is as follows, depending on the method of collection.
If the user permits the Service to associate with other services such as social networking services in relation to the user's use of the Service, the Company may collect the following information from the said other services in accordance with the conditions agreed by the user at the time of such permission:
The Company may collect information regarding the content of the user's post to the other services set forth in (1) above, the content of the user's post to the feedback on the Company's website, and access to or use of the Service by the user. The information includes the followings;
The Company will only process the Personal Data for specific, explicit and legitimate purposes. The Company shall not process the Personal Data for any further purposes than the ones the data was originally intended for, unless the new purpose is compatible with the original one. In the absence of compatibility, the processing of Personal Data for further purposes is subject to the user's prior explicit consent.
The following lists the purposes for which the Company process the user's Personal Data and the legal bases it relies on;
Purpose: | - providing, maintaining, protecting and improving the Service | |
Legal Bases: | - performance of a contract | |
- legitimate interests: ensuring the efficient and secure running of the Company's business | ||
Purpose: | - producing statistics related to the Service in a form which does not allow the identification of individuals | |
Legal Bases: | - performance of a contract | |
- legitimate interests: improving the Company's services and identifying ways to grow the Company's business | ||
Purpose: | - guidance and response to inquiries relating to the Service | |
Legal Bases: | - performance of a contract | |
- legal or regulatory obligation | ||
- legitimate interests: ensuring that the user is provided with the best client services the Company can offer | ||
Purpose: | - responding to acts that violate the Company's rules, regulations or policies relating to the Service (the “Rules”) | |
Legal Bases: | - performance of a contract | |
- legal or regulatory obligation | ||
- legitimate interests: ensuring that the Company does not deal with proceeds of criminal activities or assist in any other unlawful or fraudulent activities | ||
- public interest | ||
Purpose: | - notice of modification to the Rules or related matters | |
Legal Bases: | - performance of a contract | |
- legal or regulatory obligation | ||
- legitimate interests: ensuring the Company can notify the user about changes to the terms of business or this policy | ||
Purpose: | - distribution, display and measuring effect of advertisements | |
Legal Bases: | - legitimate interests: promoting the Company's services, identifying ways to grow the Company's business |
The user may request the Company to discontinue the collection or processing of the all or a part of the Personal Data by choosing the applicable setting as prescribed in the Service, and promptly upon such request the Company shall discontinue such collection or processing in accordance with the rules set forth separately by the Company. Certain Personal Data is necessary to be collected or processed for providing the Service, and the Company shall discontinue such collection or processing of the Personal Data only if the user withdraws from other services in Clause 1 (1) above pursuant to the procedures as set forth separately by the service providers to which it relates, and/or only if the user withdraws from the Service pursuant to the procedures as set forth separately by the Company.
Except as permitted by applicable laws or regulations, the Company shall not disclose Personal Data to any third party without the use's consent, excluding to the following third parties:
The Company reminds the user that it can at any time exercise following certain data protection rights as long as the applicable laws allow.
Any requests related to the above rights can be made by sending an email to the Data Protection Contact Point set forth below. The user will not have to pay a fee to access its Personal Data (or to exercise any of the other rights). However, the Company may charge a reasonable 80,000 Indonesian rupiah fee if the user's request is clearly unfounded, repetitive or excessive. Alternatively, the Company may refuse to comply with the use's request in these circumstances.
The Company may need to request specific information from the user to help the Company confirm the user's identity and ensure the user's right to access its Personal Data (or to exercise any of the use's other rights).
For the purpose of this Policy
rinna Co., Ltd.
Shibuya Square 39F WeWork, 24-12 Shibuya 2-chome Shibuya-ku,
Tokyo 150-6139, Japan
is responsible for the processing of the user's Personal Data as Data Controller.
For comments, questions, complaints, and other inquiries regarding the application of this Policy or for exercising the user's rights, as described in this Policy, the user can contact the Company at the Data Protection Contact Point
Data Protection Contact Point
Address: Shibuya Square 39F WeWork, 24-12 Shibuya 2-chome Shibuya-ku, Tokyo 150-6139, Japan
Department in charge of the Company: Privacy & Security Department
E-mail: privacy@rinna.co.jp
The Company will review the operation of Personal Data from time to time and strive for continuous improvement, and may make changes to this Policy as necessary. In the case of changes to the content of this Policy that are legally required to be agreed to by the user, this Policy will only apply to the user who has given consent to the changes by the method prescribed by the Company. In the event that this Policy is changed, the Company shall notify the user of timing and content of this Policy through posting on the Company's website or other appropriate method, or notifying the used of the change.
October 20, 2020