Privacy policy | Da'at Consulting

1. Introduction

We, Da'at Consulting ("we," "us," or "our"), will collect information related to individuals ("Personal Data") in providing our products, apps, services and websites (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 provide such Personal Data, and how you can manage your own Personal Data.

Our Services include services, products, ads, information providers, advertisers, ad distributors and other partners (together with our group companies, hereinafter collectively referred to as the "Partners") and for customers other than customer him/herself.

2. Applicable scope of this policy

This Policy applies to all Personal Data that we collect regardless of the country or region.

2a. Target scope

This Policy applies to all Personal Data that we collect.

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 provide 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 the subject matter of this Policy, the Individual Policies shall prevail.

In connection with the application of this Policy, we are the controller of the processing of Personal Data.

2b. Applicable policies

We will process Personal Data to the extent permitted by the Applicable Laws according to this Policy.

3. Personal Data to be collected

We will collect the Personal Data such as the following in lawful and fair manner.

Personal Data provided by you
Personal Data relating to the use of our Services
In addition to the above, Personal Data lawfully collected by us, including cases of collecting information from third parties

If you do not provide certain types of information which need to be registered for using our Services, you may not be able to use all or a part of our Services.

We may collect and use information by leveraging technologies such as association learning and differential privacy in order to better protect your privacy.

The following are some examples of the Personal Data that we will collect.

3a. Examples of Personal Data to be provided by you

We may ask you to provide us with your Personal Data by operating your device and entering information or via a document or other mediums.
The foregoing Personal Data includes, for example:

Name and email address required when filling the form(s)
Answers when cooperating with our surveys

4. Purpose of use of Personal Data

We will use the collected Personal Data (including Personal Data collected from when you use our Services and all Personal Data collected from third parties) for the following purposes:

Provision and maintenance of our Services;
Development and improvement of our Services;
Security and prevention of unauthorized use; and/or
Provision of Services 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.

This kind of use includes the associated management and use of our internal identifier of each Service assigned to users, identifiers assigned by Partner, advertising identifiers (including Identifier for Advertising (IDFA) and Google Advertising ID (AAID)), and various other identifiers and one-way encrypted (hashed) email addresses and telephone numbers.

In addition, we may collect your information from our Partners and use it in combination with our information for the purpose described in "4. Purpose of use of Personal Data", such as for sending messages from our Partners and distributing ads, as well as measuring ad effectiveness, creating and providing statistical information and for other purposes.

As information collected from our Partners, we may collect information such as your identifier (internal identifier, ad identifier etc.), hashed email address and telephone number, IP address, part of your device information (OS, etc.), your attribute information.

When we are to collect Personal Data, we will notify or publicly announce the purpose of use to users to the extent required under Applicable Laws (including the notification and public announcement of the purpose of use based on this Policy).

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 Applicable Laws. In addition, we will take appropriate measures to ensure that Personal Data is not used for any other purpose.

Notwithstanding the above, upon receiving Personal Data from a third party, if the purpose of use of such Personal Data is separately prescribed, we will use the Personal Data according to such provision to the extent permitted by Applicable Laws.

The purposes of use of Personal Data include, for example, the following.

4a. Examples of Provision and maintenance of our Services

We will use information required for providing our Services, answering your inquiries, hosting promotional events, and sending announcements regarding our Services and those of our Partners.

For example, in the following cases, we will use Personal Data for the provision and maintenance of our Services.

To verify your identity, through comparison with your registered information, when succeeding the account upon logging in or changing your device, when using certain Services which require identity verification, or when receiving inquiries from users;
To send or post messages and contents, and convey the status of the sent or posted messages, etc.;
To set or disclose profiles for building and managing connections between users in LINE, and to search for other users using the registered information, or enable such search;
To examine your status of use of our Services in order to reply to your inquiry to our customer support;
To automatically display your information, which is required for purchasing products, on the input screen; and/or
To generate appropriate sentences and images according to the contents that have been entered such as for purposes of supporting your use of our Services.

4b. Examples of Development and improvement of our Services

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.

To develop and improve our Services by surveying and analyzing your attribute information, number of users and number of viewers of our Services, and number of views and number of taps and clicks of ads which we and our Partners distribute;
To improve our Services by creating statistics and models related to the use of our Services;
To conduct surveys related to our services that we are currently providing, or may provide in the future; or
To use questions entered in the Service that generates text according to the customers’ questions and improve the model for such service.

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 by Applicable Laws.

The recipients of Personal Data include third parties such as our subcontractors and group companies 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 Service in a smooth manner, subcontractors and group companies, etc. may be added later to the recipients of Personal Data that we provide. Although all of the countries and regions that we may provide Personal Data to in the future cannot be specified, we will notify you via this Policy upon the future addition of any country or region in which the third-party recipient of Personal Data is located.

We have data center locations in the European Economic Area, countries and regions recognized by the European Commission as having sufficient levels of protection. Furthermore, Personal Data stored in our data centers may be accessed from a third country that does not have the same personal data protection legislation as European Union. Even in the event of access from such a country, we will obligate the company that accesses Personal Data to perform appropriate security management in a service agreement, etc., and will take measures such as managing and supervising that company. We will take necessary measures to ensure that Personal Data is properly protected in accordance with our security standards, such as by taking appropriate encryption measures in the access route to Personal Data.

6. Safety control of Personal Data

We develop basic policy to make effort to manage the collected Personal Data properly and take strict organizational, personal, physical and technical security measures. 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 Applicable 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.

6a. Security measures

We are taking strict organizational, personal, physical and technical 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.

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.

6b. Storage location of Personal Data

We are storing the Personal Data of users in our data centers located in European Union.

6c. Storage period of Personal Data

We collect and retain 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 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 by Applicable Laws. While we will retain the foregoing information for a minimum period, such information will subsequently be automatically deleted from our server.
Information that we collected for a specific purpose 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 LINE, 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 request the correction of your Personal Data, to the extent permitted by 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 by 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 by 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, edit your profile, set the collection, use and sharing of information, 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.

8.Use of third-party modules and Cookies

We may use tags and modules containing cookies and third-party software development kit (SDK) for fulfilling the purposes described in this Policy.

8a. Third-party modules

We may install modules of a third-party SDK in our Services, for example, for the following purposes:

to analyze the status of use of our Services; and
to distribute ads on our behalf and measure the effectiveness thereof.

With regard to your Personal Data that is processed by a third-party through a module provided by such third party, the privacy policy of such third party will apply.

8b. Cookie and other analytical tools

A cookie is a small text file that is stored on your computer when visiting a website. This text file stores information that can be read by the website operator when visiting the website again at a later date.

For example, we may use cookies and similar web tracking technologies (web beacon, pixel etc.) for the following purposes:

to store your login state, authenticate visitors, maintain sessions and take security measures;
to store language settings and latest date and time of access, and improve user-friendliness;
to provide better services by comprehending the number of accesses and the mode of use;
to distribute ads that are more interesting to you (*3); and
to measure the effectiveness of ads.

You can control whether or not to accept cookies based on browser settings or by using other tools. If, however, you deactivate cookies or limit the ability to set cookies, you may not be able to obtain the full benefit of the website or access all of its functions, which may limit your overall user experience.

8c. Information related to use of Google Analytics

In order to improve our Services, we use Google Analytics to measure our Services such as our website. Google may set cookies or read existing cookies to collect data. At such time, information such as the URL of the page that you accessed and IP address will be automatically sent to Google. We may use such information to comprehend the status of use of our Services or use such information in our Services. For the processing of data by Google in Google Analytics, please read the terms of use of Google Analytics and Google’s privacy policy.

9. Other important information

We may modify this Policy. The latest version of the Policy will always be posted on this site, and we encourage you to review the contents of the latest version of the Policy carefully. When we make any material changes to this Policy, we will notify you through reasonable means.

9a. Changes to this Policy

We may modify this Policy from time to time, and the latest version of the privacy policy will always be posted on this site. When we make any material changes to this Policy, we will notify you on our Services, or by other reasonable means. We encourage you to review the contents of the latest version of the privacy policy carefully.

Formulated on May 15, 2024