LINE PLUS CORPORATION PRIVACY POLICY
1. Introduction
We consider personal data protection as one of the most important principles in the management of the Company. We will comply with laws and regulations applicable in all countries and regions where we engage in our business (such laws and regulations hereinafter collectively referred to as “Applicable Laws”) and strive to protect personal data adequately pursuant to this Policy.
This Policy explains the types of personal data collected by us, how we use and share such personal data, and how you (also referred to as “user”) can manage your personal data.
We put your personal data first. Our practices for personal data protection are on the basis of the following core principles:
We design the Services by bearing the protection of your personal data in mind;
We commit to transparency in processing your personal data. We strive to provide a clear and definite explanation regarding our practices for personal data protection to help you better understand the same; and
We use our best efforts to protect personal data. We continuously evaluate information security risks, as well as test and monitor our security practices to prevent such risks.
2. Scope of Application of This Policy
2.a. Subject Scope
Through our Services, you may connect to other websites, devices, applications, and other functions (“External Sites, Etc.”) which are operated separately by external parties following their own privacy policies or notices. Unless the External Sites, Etc. are owned or controlled by us, we shall not be responsible for the relevant content, use of your personal data, or their personal data protection practices. If you connect to any External Sites, Etc. through our Services, your personal data may be collected and used by such External Sites, Etc. and be governed by the privacy policies of such External Sites, Etc., which shall be irrelevant to us, and as such, please review the policies of the External Sites, Etc. carefully, especially upon your first visit to those External Sites, Etc
2.b. Language; Applicable Policy
When you use our Services, you acknowledge that this Policy applies to the collection, processing and usage of your personal data. For other specific scopes (e.g. details of the personal data to be collected), please refer to the terms of use for respective Services.
3. Personal Data to Be Collected
We collect the following personal data in a lawful and fair manner, for the purposes set forth in this Policy. Some of the following information may be essentially required for our provision of the Services to you. If such information below is not collected, all or part of our Services may not be made available:
Personal data provided by you;
Personal data in connection with the use of the Services; and
Any other personal data lawfully collected by us, including information collected through a third party.
Please see below for examples of the above-mentioned personal data.
3.a. Personal Data Provided by You
We process personal data provided by you by operating your device or through written documents and other media. The personal data collected from you may include, but not limited to, the following:
Information collected upon registration (name, phone number, email address, gender, etc. )
Responses to a survey (if any);
Identification documents provided to verify your identity;
Profile data (icon image, display name, status message, search ID, etc.); and
Contact information, such as phone number and email address upon user inquiries.
3.b. Personal Data Regarding Use of Services
3.b.1 Service Use Status
We collect, via automatic means, the information about when and how you use our Services. The information collected includes the status of use of various Services or features, such as the date and time of the use of each Service, search history within the Services and the results, purchased Services, and the content or advertisements viewed, tabbed, clicked, etc. In addition, we may also collect information regarding the use of Services through your participation in events, polls, surveys, and other content of Services (including the types of events participated by you, event participation options, and other information). We also collect transaction-related data, such as payment-related information and transaction records, etc.
3.b.2 Location Information
In some cases, we collect the location information of devices used (e.g., country- or city-level location or time zone) to provide customized content or advertisements, such as local news, based on your location information, or to provide search results optimized for you. If you do not allow the transmission of their location information in the device settings or in-app settings, the location information will not be transmitted, and device settings always take precedence over in-app settings if the two settings are different. On the other hand, even if you do not allow the transmission of your location information, we may, in some cases, estimate your approximate location by using information, such as IP address.
In some countries or regions, the comprehensive provision or use of location information might be separately requested in providing customized content or advertisements for each user, such as local news near the user’s current location. In this case, the user may arbitrarily set at will whether to provide his/her location information or the range of use thereof, etc. in the in-app settings.
3.b.3 Application, Browser, Device, and Network Information
We collect information regarding the applications, browsers, and devices (e.g., types and operating systems of the devices, app versions, OS versions, device manufacturers, browser types, languages, unique device identification numbers, cookies, and advertising identifiers, etc.) or network information (e.g., carriers or internet service providers, and IP addresses, etc.), used by you.
We may combine this information with other user-related information collected.
3.c. Personal Data Collected from Third Parties
3.c.1 Personal Data Collected from Related Companies
We may collect your personal data in accordance with the terms or policies of related companies(as defined in 5. Provision of Personal Data section below, which can be found in the “List of Related Companies”, "Related Companies"). For the privacy policies applicable to individual services provided by Related Companies, please refer to the individual services.
- Information Shared by LY Corporation (“LY”) to Us
: You agree that LY may provide your personal data that collected and generated by LY to us in South Korea. The personal data shared by LY may include, but not limited to, the following:
Profile data (icon image, display name, status message, internal identifiers, etc.);
Advertising identifiers (including Identifier for Advertising (IDFA) and Google Advertising ID (AAID)) ;
Location information; and
Attribute information.
We may collect personal data from our partners. They may be partners who operate independent services, or partners who operate services in partnership with our Services.
Information collected from partners includes, but not limited to, identifiers (internal identifiers, advertising identifiers, etc.), hashed email addresses or phone numbers, IP addresses, partial device information (e.g., OS version, etc.), attribute information, purchase history, viewing history, search history, location information, and other details of user behaviors.
3.c.3 Personal Data Uploaded by Other Users
We may collect information uploaded by other users who use the Services, which may contain your personal data, such as photos of third parties other than themselves.
3.c.4 Collection of Personal Data from Public Information
We collect public information online, such as from official websites of companies disclosed on the internet, to use it for our Services. Even such information includes any personal data, the information might be displayed for search results.
3.c.5 Information Directly Collected from Third-Party Services
In addition to login records collected from plug-ins of third-party websites or applications, we may also collect URL information from websites visited while logged in to our Services by associating them with your accounts, if such websites are equipped with a plug-in feature and we will be obtaining the relevant information from such third-party websites or applications. Using such collected information, we learn your usage of our Services, to maintain and improve the Services, and seek to ensure security and prevent any abuse.
4. Purpose of Use of Personal Data
In addition, we and Related Companies may collect user-related information from partners to send advertisements, measure the impact of advertisements, and prepare and provide statistical data, and may use such information in combination with the information retained by us.
Examples of the purposes of using personal data are included below.
4.a. Provision and Maintenance of Services
To verify identity and qualification;
To create accounts;
To process claims or make payments for the purchase of products and use of paid services, etc.;
To manage sweepstakes events (also known as giveaways or raffles), contests, polls, surveys, and other events supposed to be participated by you, which we may [L1] rely on other legal basis than consent to process your personal data;
To aggregate anonymized statistical data regarding the Services;
To handle your inquiries and requests by checking the status of use of Services, etc. and effectively responding thereto; and
To notify you of any other important information relating to the Services and to contact you, if necessary.
4.b. Development and Improvement of Services and Content
To learn how you interact with the Services in order to improve the platform and develop new features;
To improve the Services by creating statistics or models regarding the use of the Services;
To provide new developments in the future and improve the quality and relevance of the Services; and
To obtain platform-wide feedback and provide customer services (e.g. satisfaction surveys).
4.c. Prevention of Abuse and Compliance with Applicable Laws
To detect and prevent spam, fraud, abuse, or fraudulent use of the Services, and to contact you to verify fact-findings;
To keep track of the content of reports and illegal posts, and to monitor and implement our compliance with legal agreements; and
To comply with the Applicable Laws or legal obligations.
4.d. Provision of Better and More Optimized Content to Users
To provide recommendations and information tailored to the specific interests of you; and
To send information regarding recommendations that might be of interest to you, including offers personalized based on the information in relation to your accounts.
4.e. Marketing Related Activities
With your separate consent or other legal basis, where applicable, we will share your personal data with any of the Related Companies and third parties, for Related Companies, us and third parties may:
To transmit the marketing information, advertisements that are highly relevant to you, and/or promotional proposals provided or offered by us, Related Companies, or third parties, as the case may be;
To match personal data with other data collected for other purposes and from other sources (including third parties) in connection with the provision, marketing or offering of products and services by Related Companies;
To conduct market research, analytics, and surveys to enable us to understand and determine customer preferences and demographics for us to offer users products and our services as well as special offers and marketing programs which may be relevant to users’ preferences and profiles;
To administer and organize contests, lucky draws, promotional events, competitions and marketing campaigns, and personalizing users’ experience; and
To optimize and promote the services provided by Related Companies.
5. Provision of Personal Data
We transfer, disclose, or otherwise provide your personal data as explained below. Receiving parties include third parties, such as entrustees and Related Companies located in countries or regions other than those of your place of residence:
- Disclosure by the Data Subject: Public information, such as posts or comments on bulletin boards accessible by unspecified or multiple users, or profile data set to be public, will be available to third parties other than you. Due to the nature of digital data, such public information is likely to be copied, stored or distributed by viewers, thereby being accessed by unintended third parties. In case you are setting up your profile data or posting on our Services, please be aware of its content or scope of disclosure. In addition, even if you delete your service account, we will maintain public information, such as reviews, comments, and display names, to ensure the continued provision of Services.
On the other hand, we may provide public information regarding you to a third party. Any public information provided by us to a third party may be posted on the services of such third party. - Entrustment of Work: We may entrust a third party (including Related Companies) with certain tasks necessary for the provision of Services (e.g., infrastructure establishment and operation, development, payment, delivery, and customer support, etc.). In doing so, we may transfer or disclose all or any part of your personal data to companies and individuals who function on our behalf.
These entities have the authority to access and use only the minimum personal data necessary to provide our Services, and we ensure that these service providers process your information in accordance with this Policy and the Applicable Laws. - Related Companies: Other than Entrustment of Work, we may share the personal data mentioned in “3. Personal data to be Collected” among Related Companies which can be found in the “List of Related Companies”. The purposes of sharing personal data are the same as those specified in “4. Purpose of Use of Personal data".
- Provision of Services: In any of the following cases, we may, to the extent permitted by the Applicable Laws and/or with your consent, provide personal data, excluding information that can directly identify specific users (e.g., name and address), to third parties, including our partners, to the extent necessary:
Where such provision is necessary to provide the Services or to improve the quality thereof (including where necessary for advertising and promotional activities in relation to the Services);
Where such provision is necessary for us to review new Services;
Where such provision is necessary to prevent illegal use of the Services; and
Where the personal data is provided to research institutes for investigation, research or analysis.
- Compliance; Cooperation with Public Agencies: We may disclose personal data to law enforcement agencies (e.g., the police) or third parties (e.g., courts of justice) in order to comply with legal procedures in accordance with the Applicable Laws in certain cases where, e.g., it is requested pursuant to legal procedures, such as warrants, or where there is a threat to the body or property .
- Protection of the Company and Others: We may disclose your personal data in the case where we find that investigation, prevention or taking measures is necessary in relation to illegal activities, suspected fraud, circumstances relating to potential threats to the safety of individuals, and breaches of our terms or this Policy, or where such personal data is used as evidence of litigation concerning our Services.
- Professional Advisors: Provision of information may be necessary to be advised by attorneys, business consultants, accountants, or information security and forensic experts on the operation of the Services.
- Third Parties Authorized by Users or Legally Permitted: This applies to any potential or actual acquirers or investors and professional advisors in relation to proposed merger, acquisition or investment regarding all or part of our business. We will use our best efforts to ensure that the terms of this Policy apply to personal data after transfer or that you receive notice of any changes to the processing of personal data.
6. Overseas Transfer of Personal Data
We are a controller who shares personal data in accordance with the Applicable Laws. Subject to this Policy, your use of our Services includes the transmission, storage, and processing of personal data in and outside of your country of residence.
- Service Provider: In providing the Services, we may store your personal data outside of the countries or regions of your residence. In particular, your personal data is stored in data centers in South Korea and Japan.
Some of the receiving parties of information who share your personal data within the Services may be located in the US, the Philippines, and other countries, other than the countries in which your personal data was originally collected. - Related Companies: South Korea, Japan, Taiwan, Thailand, Hong Kong, Vietnam, and Indonesia etc. are the countries and regions to/from which personal data may be transferred to.
By continuing to use the Services, you agree that we may transfer your information overseas.
7. Retention Period of Personal Data
We collect and retain your personal data for the following period in order to provide the Services, to achieve the purposes of use specified in this Policy or to comply with the Applicable Laws:
During the course of providing Services to you;
For the period necessary for the purpose of data collection, unless a longer retention period is required as provided by the Applicable Laws;
During the applicable period if required in connection with laws, contracts or legal obligations of the Company; or
In case of processing of personal data for marketing purposes or with your consent, until you request the suspension of processing and thereafter for a short period of time until such request is fulfilled.
Unless you request the deletion of your accounts, we retain most of your personal data as a rule. In the event that your accounts are deleted, we retain your personal data for a certain period of time for the following purposes and then properly process such personal data in accordance with the Applicable Laws and internal regulations:
To respond to inquiries, resolve disputes, and collect fees;
To detect and deter from any illegal use or abuse of the Services; and
To comply with obligations under rules determined by the Applicable Laws.
In addition, we may retain personal data in a form that cannot identify individuals after the expiration of the retention period determined by the Applicable Laws and internal regulations has elapsed.
8. Your Choices Regarding Personal Data
We strive to provide features within the Services which allow users to manage their personal data directly. Please check for any outdated or inaccurate information on a regular basis, and update your personal data accordingly. For example, we provide the following features:
Setting and changing of personal data; and
Whether to receive marketing messages and customized advertisements.
Where permitted, we may contact you via emails, text messages, push notifications via mobile applications and/or other means. If you are unable to modify the settings on your own, please contact us by using the information specified in the "13. Inquiries“ section below to make an inquiry to us.
9. Your Rights
If you intend to exercise your rights on us, we will respond to your requests within a reasonable period of time after verifying your identity in accordance with the Applicable Laws. To file a written request, please contact us by using the information specified in the “13. Inquiries” section below.
10. Secure Management of Personal Data
Do not share your password with anyone else, and do not use the same password you use for other services. In addition, in case of any suspicious illegal use of your account or other security violations within the Services, please inform us by referring to “13. Inquiries” below.
11. Use of Third-Party Modules and Cookies
We may use tags and modules, including cookies and third-party software development kits (SDKs), to achieve the purposes explained in this Policy.
11.a. Third-Party Modules
We may install third-party SDK modules in our Services for the following purposes:
To analyze the status of use of the Services; and
To distribute advertisements on our behalf or to measure their effectiveness.
11.b. Cookies and Other Analytical Tools
We may use cookies and similar web tracking technologies (e.g., web beacons, pixels, etc.), particularly for the following purposes:
To store users’ login status, authenticate visitors, maintain sessions, and take security measures;
To improve user convenience by storing language settings and the date and time of the latest access;
To provide better Services by understanding the number of accesses and how the Services are used;
To distribute advertisements that are more relevant to users’ interests; and
To measure the effectiveness of advertising.
You may control whether to allow cookies based on your browser settings or by using other tools. However, if you disable cookies or restrict the feature of cookie settings, you may not be able to access all or part of the features of the website, which could limit overall user convenience.
11.c. Information Regarding the Use of Google Analytics
For more information on how Google collects, uses, and shares your information, please refer to see “How Google uses information from sites or apps that use our services”, “Safeguarding your data”, and ”Google Analytics Opt-out Browser Add-on”.
12. Child Privacy
We are aware of the need for higher privacy protection for personal data collected from users in certain jurisdictions, and do not intentionally collect personal data of children under a certain age (e.g., those under the age of 11 in Thailand) requiring consent as stipulated by laws in the relevant jurisdictions. If you believe that we are collecting personal data from children in those countries or regions, please inform us via the provided channels in “13. Inquiries” below. If confirmed, we will take reasonable actions to invalidate the relevant account and promptly handle such personal data in our records.
13. Inquiries
We designate the Chief Privacy Officer as follows, in order to handle your inquiries and/or complaints in connection with your personal data:
<Chief Privacy Officer>
Name: Geun Su Byeon
Division: Security Center
Position: Chief Privacy Officer
- Contact Info.: Contact Us
14. Amendment of the Company’s Privacy Policy
If there are material changes to this Policy, we will notify you via the application or other means. You can access this Policy directly from the application and website at any time. Your continued use of the Services shall be deemed as your acceptance of such changes.