We, LINE Corporation (“LINE,” “we,” “us,” or “our”), believe your privacy is important.
To fulfill our commitment to respecting and protecting your privacy, we will adhere to the following principles:
1.We will inform you of the personal information that will be collected, and, where appropriate seek your consent to collect, process, use, or disclose your personal information.
2.We will identify the purposes for which we will collect and further process your personal information.
3.We will only collect information that is necessary to carry out the identified purposes of use.
4.We will use or disclose your personal information only for the purposes for which it has been collected, except with your consent, or as required or permitted by applicable law, and we will retain your information only as long as necessary to fulfill those purposes.
5.We will endeavor to ensure that your personal information is accurate, complete, and up-to-date.
6.We will implement appropriate technical and organizational measures to protect your personal information.
7.We will make our policies and practices for the handling of your personal information as transparent as is reasonably possible.
8.You will have access to your personal information and will be able to correct your personal information as appropriate in accordance with your rights under applicable law.
Please note that you can check applicable privacy policies and addendums within the respective Service.
3. Types of Personal Information We Collect
a. What Personal Information Does LINE Collect?
When you create an account and use Services, LINE collects, uses, and transfers the following types of information:
i. Information Concerning Your Account
When you create a LINE account in order to access the Services (an “Account”), LINE will ask you to provide your phone number. This information is necessary because we may send a text message via SMS to the phone number you provide, as part of our ongoing efforts to detect and deter unauthorized or fraudulent use of or abuse of Services. We may also use your registered phone number to provide you important information about Services.
Alternatively, you may choose to create an Account using your Facebook account when, for example, you do not wish to provide your phone number. In such a case, phone number provision is optional. Please note that we do not collect your Facebook password. It is necessary to provide one of the information above, in order to create an Account and use Services.
If you choose to enable the “Allow Others to Add” feature, your phone number is used to let other users who have your phone number in their address books add you as a LINE Friend, and to allow other LINE users who have your phone number to find you. Please note that you can at any time choose to enable or disable this “Allow Others to Add” feature in the App, in “Settings” > “Friends”.
ii. Device Information and Access Logs When You Use Our Service
When you use Services, we may obtain and maintain certain electronic identification or log data that is automatically provided by your device such as: device type, OS type, IP address, browser information including type and language settings, device identifier, cookie data, advertising identifier or mobile application identifier.
This information is necessary as part of our ongoing efforts to detect and deter unauthorized or fraudulent use of, or abuse of, Services, as well as to provide you with customized options, and optimize the Service for your device. Also, please note that a third party advertising identifier may be associated with your Account through our internal identifier.
b. What Other Information Might LINE Collect?
To improve the quality of Services, we provide additional functionalities, including the ability to access your Account from multiple devices, help you find friends via the Service, and to make Services more efficient, usable and enjoyable. If you choose to use such functionalities, we may ask you to provide the information below.
You may choose not to provide the following information. However, if you do so, there may be cases where you cannot use some parts of Services.
i. Email Address [OPTIONAL]
If you wish to access your Account from multiple devices (“Multiple Device Login”) or to transfer your Account from one device to another (“Account Transfer”), you will need to provide your email address and a password and/or PIN code to LINE, so that we may associate these devices with your Account. We may use your registered e-mail address to provide you with important information about the operation of Services.
Please note that if you change your mind later and decide you no longer wish to provide your email address, you can at any time remove it in the “Settings” > “Accounts” menu in the LINE App.
ii. LINE ID [OPTIONAL]
In order to make it easier for your friends to find you with in the Services, you may choose to assign a LINE identification name (a “LINE ID”) to your Account, and allow your friends to find you through your LINE ID. Alternatively, you may choose not to allow other LINE users to contact you using your LINE ID. Please note that your LINE ID is not visible to other LINE users without your consent, and your LINE ID may be a pseudonym – it does not have to be your real name.
iii. Contact Phone Numbers in Your Address Book [OPTIONAL]
To make it easier to find your friends using Services, you can enable the “Auto Add Friends” feature in the LINE App. If you choose to enable the feature, we will access the phone numbers in your mobile device’s address book, and enable you to add friends in the Services who have consented to being found via their phone number or e-mail address (the “Account Matching Service”). Once you have added a friend in the Services, you can call them or send them messages over the Services. We will access only the phone number fields in your mobile device’s address book; we do not access contact names or any information from other data fields, or we do not use this information except for purposes other than adding or recommending friends or preventing unauthorized use. You can at any time change your mind and disable the Account Matching Service by turning off this feature under “Settings” -> “Friends”. As noted above, if you choose to provide us with your phone number, other users may be able to find you using the “Auto Add Friends” feature.
If you would like to invite individual friends or contacts to connect with you using the LINE App, you may send them invitations directly via SMS or e-mail directly from your mobile device using the address book in your mobile phone. When you use the invitation function in the LINE App (“Tell a Friend Service”), we will access your address book to identify your friends. After your friend(s) have been identified, you can send invitations directly to individual friends and contact them via SMS or e-mail on your mobile device phone. LINE does not send invitations as part of the Tell a Friend Service.
iv. Location Information [OPTIONAL]
To use the LINE App, you are not required to provide your location information (“geolocation data”). However, we provide features that utilize geolocation data for your convenience and to improve your user experience.
If you wish to add nearby LINE user(s), you may want to use the “Shake It!” feature, which allows you to add nearby user(s) to your contacts by shaking your smartphone. You can start the process by choosing the feature under the “Add Friends” menu, and start shaking your smartphone along with other nearby users. Once the process is initiated, we will ask to access your geolocation data so that we can match you with nearby LINE user(s). Please note that, you can only find users who are also using the “Shake It!” feature. The successful operation of the “Shake It!” feature will result in the sharing of your LINE profile information with other nearby users of the “Shake It!” feature, and their LINE profile information will be shared with you. The personal data of users who do not initiate the “Shake It!” process will not be shared.
You may wish to receive information about nearby shops, attractions and facilities, provided by “Official Account” in the LINE App. If you choose to receive such information from an “Official Account”, we will obtain your geolocation data via your mobile phone, so that we can provide you with the relevant information.
In both cases (“Shake It!” and nearby shops, attractions and facilities), collection and use of your geolocation data is performed on an as-requested basis. LINE will only collect your geolocation data in response to a request from you, and LINE will delete the geolocation data once the relevant service has been provided to you. LINE does not aggregate your geolocation data and does not record your geolocation history.
In other cases where we collect or use your geolocation data in the course of providing an Additional Service, we will provide you with prior notice and obtain your prior consent.
Furthermore, when you do not accept sending your geolocation data by your mobile device settings, geolocation data will not be sent to us.
v. Contact Information for Customer Support [OPTIONAL]
vi. Contact Information for Promotional Events and Customer Surveys [OPTIONAL]
If you choose to participate in promotional events or surveys that LINE offers from time to time, we may request your contact details (e.g., your name, mailing address, phone number, email address, gender and date of birth) in order to confirm your participation eligibility, enable you to fill out questionnaires, and to deliver any prizes you may win, and otherwise administer the event.
vii. Payment Information [OPTIONAL]
If you choose to purchase an Additional Service or use a fee-based Additional Service and pay for such Additional Service by a means other than in-app purchases via iTunes or Google Play, we may engage a third party service provider to collect and process your credit card information. We will use your credit card information only to process your purchase or use our fee-based service. Please note that we will not retain your credit card information beyond the period necessary to facilitate the relevant payment. Your credit card settlement will be handled by appropriate third party payment agencies.
viii. Information from Websites and Applications that have Integrated our Service Plugins [OPTIONAL]
Our Services and/or third-party websites/applications may integrate our plugins such as "LINE it!" We may record your LINE login activity through the use of such plugins, or obtain the URL of websites integrating our plugin that you visit while you are logged into our Services via your browser. Data obtained in this way will be used for the purposes of identifying how our Services are used and maintaining and improving Services. Please note that your personal information will not be obtained from such websites or applications with our plugins if you are logged out of Services.
ix. Use of Information from Apple's TrueDepth API
LINE may use Apple's TrueDepth camera to collect additional information from your device's camera in order to deliver and improve features provided by LINE Services (such as the in-app camera, video calling, effects, and more). However, this information is processed in real time for delivering and improving these features only.
This information is not saved on our servers or shared with any third parties.
c. What About Information I Create About Myself and Share With Others?
i. User-Generated Content [OPTIONAL]
In addition to the information described above, you may choose to set your profile information (e.g., LINE ID, “display name,” profile picture, the phrase you choose to show under your status message, date of birth, etc.) and show who you are to other users or corporate account administrators within Services. Furthermore, you may choose to create “user-generated content” such as text and audio messages, photos, videos, geolocation data, or the contact information of your LINE friends, and share this user-generated content with other users. For some of the profile information, such as date of birth, you may choose whether or not to make it public. You may also choose how much or little of your user-generated content to share, and with whom you share it, when you create messages by selecting the recipients of your user-generated content and/or through the privacy settings in the LINE App.
Please note that the profile information and user-generated content you share with others can be copied, stored, or disseminated by the recipients and potentially accessed by unintended third party recipients due to the nature of digital data. We encourage you to be very attentive and cautious when you generate and share your personal information or content with others.
Furthermore, corporate account administrators that you have added as friends view your information and may store your data in servers located in their respective countries or regions. Please note that some of the countries or regions where your data is transferred to do not have the data protection laws at the level that is required in your country or region. If you do not wish your data to be transferred, you may at any time block such corporate accounts.
4. How We Use and Handle Your Information
a. How Does LINE Use My Information?
■for developing, providing, and improving our Services:
•to provide Services and any Additional Services to you and to allow you to transmit your user-generated content to other LINE users;
•to allow you to use your Account on multiple devices and transfer your Account to another device;
•to help you find people you know that are already LINE users so that you can connect using LINE and, subject to your prior agreement, to allow other LINE users to connect with you;
•to enable you to sync other applications offered by LINE, LINE affiliates, and LINE business partners together with your Account and to share information between the applications you use;
•to respond to requests you may make to use Additional Services;
•to enable us to provide customer support, and to respond effectively to your inquiries and claims;
•to conduct user surveys;
•to notify you of any other important information regarding Services and any Additional Services, if necessary;
•to identify winners of promotional contests, to send gifts to those winners, and to deliver purchased products and services;
•to aggregate anonymized statistical data regarding Services and any Additional Services;
•to comply with applicable laws or legal obligations;
■for maintaining the security of Services or preventing unauthorized use:
•to verify your identity;
•to monitor, detect and deter unauthorized or fraudulent use of, or abuse of, Services;
•to verify yourself or to notify you in case any unauthorized use occurred;
■for personalization or advertisement delivery:
•to improve and/or optimize Services and any Additional Services; and
•to measure the effectiveness of advertisements that we place on the Internet or in other media.
In principle, we obtain your consent when we process your personal information. If, however, permitted under applicable laws, we may handle your personal information when any of the following applies:
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; or
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).
b. How Does LINE Protect My Personal Information?
To fulfill our commitment to respecting and protecting your privacy and the confidentiality of your personal information, LINE has implemented appropriate technical and organizational security standards, including industry-standard safeguards to prevent unauthorized access or disclosure, misuse, alternation, or destruction of your information. Specifically, we received ISO/IEC 27001 certification in 2007, and SOC2, SOC3 (SysTrust) certifications for the LINE App.
Because no method of electronic transmission or method of data storage is perfect or impenetrable, we cannot guarantee that your personal information will be absolutely safe from intrusion during transmission or while stored in our systems.
To help protect your privacy and confidentiality of your personal information, 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 .
c. Where Is My Personal Information Transmitted and Stored?
To provide Services in a reliable and responsible manner, LINE processes and stores your information on secure servers located in Japan where LINE Corporation located. Data protection laws in the countries in which your information is processed may be different to data protection law in your country or region. There may be a possibility that the data protection level in Japan do not reach to data protection law in your country or region requires (EU and Japan adopted mutual adequacy decision on personal data transfers on January 23, 2019). However, all such transfers are performed in accordance with the requirements of applicable law. For example, for EEA users, where we transfer your personal information from the EEA to recipients outside the EEA and Japan, we apply safeguards in the form of the European Commission’s adequacy decision C(2019)304, and Standard Contractual Clauses in all other cases.
d. How Long Does LINE Keep My Information?
We may retain your personal information following the closure or termination of your Account if retention is reasonably necessary:
•to comply with applicable laws, regulations or legal obligations;
•to provide and complete customer support service;
•to resolve disputes between or with LINE users, for the duration of the applicable limitation period; or
•to detect and deter unauthorized or fraudulent use of, or abuse of, Services.
e. Does LINE Use Outside Service Providers or Agents?
To provide Services, it sometimes is necessary for LINE to enlist third party service providers to process user data, which may include your personal information. These service providers include payment agencies, delivery agencies, providers of customer support services, and so on. These service providers may store your data in countries or regions where do not have the data protection laws at the level that is required in your country or region (EU and Japan adopted mutual adequacy decision on personal data transfers on January 23, 2019). In such a case, we will take measures to protect your personal information such as entering into a contract regarding data protection. For example, for EEA users, where we transfer your personal information from the EEA to recipients outside the EEA, we apply safeguards in the form of the European Commission’s adequacy decision C(2019)304, and Standard Contractual Clauses in all other cases. We strictly evaluate all such third party service providers. We take reasonable steps to ensure that they have established appropriate and secure information administration and organizational control systems. We impose binding contractual obligations on such service providers to comply with applicable laws and regulations regarding the processing of personal information. We also require that they access your personal information only to the extent necessary to perform tasks in accordance with our instructions, and for no other purposes.
f. Does LINE Give My Information to Third Parties?
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 when visiting it again at a later date. Some of these cookies are necessary because otherwise the site is unable to function properly. Other cookies are convenient for the visitor: they remember your username in a secure way as well as your language preferences, for example. Cookies mean that you do not need to fill out the same information each time you visit a website.
•to help us maintain your session when you use Services and/or any Additional Service;
•to enhance security of our systems;
•to store your preferences and provide customized services to you; and
•to help us understand how people use Services and to improve them.
We also use the following third party cookies on the Website:
Most Internet browsers allow you to control whether or not to accept cookies. 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.
h. Does LINE Use Third-Party Modules?
LINE uses third party advertising agencies to place advertisements on the Internet or in other media. To measure the effectiveness of advertisements and determine how much to pay to advertising agencies, we install third-party modules within Apps. We may also install third-party modules within Apps in order to help us understand how Services and/or Additional Services are being used. Details regarding Apps in which such third-party modules will be installed can be viewed here .
5. Your Choices, Your Rights
There is a possibility that LINE may obtain personal information relating to individuals who are currently not users of Services. Please note that, regardless of whether or not you are a user of Services, you have the choices and rights set out in this section if we hold your personal information.
a. How Do I Control My Information?
Subject to applicable law (including any exemptions or derogations under such law), you may have a right to access your personal information, to have errors in your personal information rectified, to object to the processing of your personal information on legitimate grounds, data portability, etc. You can exercise some of these rights directly within the LINE App at any time. For example:
•under your “Profile” in “Settings” in the App, you can confirm and/or revise your phone number, and you can confirm and revise your display name and profile picture; and
•under “Accounts” in “Settings” in the App, you can confirm and/or revise your registered e-mail address. You can also delete your registered e-mail address or de-link your Facebook account.
To exercise any of your other rights under applicable law, you may contact us using the Contact Form . Upon verification of your identity, we will respond to your request within a reasonable period of time, and in accordance with relevant law. If you would like to send us a written request, please refer to Section 6.b for our mailing address. 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; or
・when you failed to verify your identity upon your disclosure request.
If you no longer wish to use the Service or if you no longer wish to consent to LINE’s collection and use of your personal information, you may choose to delete your entire Account directly through the LINE App. We will delete your information in accordance with Section 4.d.
If you exercise any of your rights permitted under the applicable law through the Contact Form, we may charge a fee taking into account the administrative costs of responding to the request, in accordance with the procedures defined separately.
b. What If I Change My Mind?
If you change your mind regarding how much information you wish to continue to share or disclose on Services going forward, you can always change the settings in the LINE App or withdraw your consent relating to, for example:
•your profile information (e.g., your profile picture, your display name, or a personal phrase shown under the status message);
•whether to allow other LINE users to contact you using your LINE ID;
•whether to register your e-mail address;
•whether to link your Account with your Facebook account;
•whether to block or unblock certain LINE users;
•whether to add contacts automatically using the address book in your mobile phone;
•whether to allow other LINE users, who already have your phone number, to reach you via LINE; or
•whether and with whom to share or not share your posts on your Timeline.
6. Other Important Information
a. A Special Note about Children in the United States of America or in Europe
The Service is intended for a general audience and is not directed at or intended to be used by minors under the age of 13 (under the age of 16 in Europe) (“Children”).
We understand the special necessity to protect Children's online privacy, and we do not knowingly collect any personal information from Children.
If, however, you believe we have collected any personal information from Children, then please let us know via the Contact Form . If you would like to send us a written request, please refer to Section 6.b for our mailing address.
If we learn that we have inadvertently collected personal information from Children, we will deactivate the relevant Account(s) and will take reasonable measures to promptly delete such personal information from our records.
23th Floor JR Shinjuku Miraina Tower
4-1-6 Shinjuku, Shinjuku-ku, Tokyo
If you are in the European Economic Area, you may contact the Data Protection Officer or our EU representative below or you may lodge a complaint with a supervisory authority in the European Economic Area.
<Data Protection Officer>
Attn: Data Protection Officer
23th Floor JR Shinjuku Miraina Tower
4-1-6 Shinjuku, Shinjuku-ku, Tokyo
PLANIT // LEGAL
Attn: LINE Corporation EU Representative
Neuer Wall 54, 20354 Hamburg, Germany