1.Introduction
We, NATTER Corporation (“NATTER,” “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 fulfil those purposes.
5. We will endeavour to ensure that your personal information is accurate, complete, and up-to-date.
6. We will implement appropriate technical and organisational 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.
9. We will be accountable to you. We are interested in hearing your opinion regarding our compliance with these principles, this Privacy Policy, and applicable laws.
2. Scope of This Privacy Policy
a. Purpose of This Privacy Policy
This Privacy Policy explains how NATTER will process and safeguard your personal information, and the rights and choices you have with respect to your personal information. This Privacy Policy applies to: personal information you provide us when you use the NATTER communication app (“NATTER App”), optional services made available within the NATTER App, and other apps that integrate with or work in conjunction with the NATTER App (collectively “Apps”); personal information we collect when you visit websites maintained by us relating to our Apps (“Websites.” Apps and Websites are collectively referred to as “Services”); and personal information about you provided by other users of the Service. For the purpose of this Privacy Policy, NATTER is the controller.
b. What Privacy Policy Applies to Other Natter Services?
Users may request additional services from NATTER or NATTER affiliates (“Additional Services“). Because the needs and choices of each user may vary, we provide separate privacy policies or addendums to this Privacy Policy for certain Additional Services. The separate privacy policies and addendums explain the types of information we collect, their purposes of use, and other policies that may apply to the relevant Additional Services. When you choose to use an Additional Service, you will be informed of the applicable privacy policy or addendum, which supplements or modifies this Privacy Policy before you can access that Additional Service.
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 NATTER Collect?
When you create an account and use Services, NATTER collects, uses, and transfers the following types of information:
i. Information Concerning Your Account When you create a NATTER account in order to access the Services (an “Account”), NATTER will ask you to provide your phone number and/or email. This information is necessary because we may send a text message via SMS or email to the phone number or email address you provide, as part of our ongoing efforts to detect and deter unauthorised or fraudulent use of or abuse of Services. We may also use your registered phone number to provide you important information about Services.
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 unauthorised or fraudulent use of, or abuse of, Services, as well as to provide you with customised options, and optimise 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 NATTER 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. Contact Phone Numbers in Your Address Book [OPTIONAL] 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.
ii. Location Information [OPTIONAL] To use the NATTER App, you are not required to provide your location information (“geolocation data”). However, we provide features that utilise geolocation data for your convenience and to improve your user experience. If you wish to add nearby NATTER user(s), you may want to use the “Near by” feature, which allows you to find nearby user(s). 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.
iii. Contact Information for Customer Support [OPTIONAL] There may be circumstances in which you might wish to contact us to seek our customer support. If you contact us via our Contact Form , or by other means, we may obtain and maintain any information you choose to provide, including your name, contact info such as your email address, phone number, as well as information about your mobile device or personal computer such as its device type, and OS type. We will use this information to address and investigate the issues you have raised, to provide you support, and to improve our customer support service. We may process this information in connection with the assistance you have requested, the administration of your Account, and retain this information in accordance with the provisions of this Privacy Policy.
iv. Contact Information for Promotional Events and Customer Surveys [OPTIONAL] If you choose to participate in promotional events or surveys that NATTER 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.
v. Use of Information from Apple's TrueDepth API NATTER may use Apple's TrueDepth camera to collect additional information from your device's camera in order to deliver and improve features provided by NATTER 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., “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 NATTER 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 NATTER 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 NATTER Use My Information?
To provide Services and any Additional Services, NATTER, as a data controller or joint data controller, uses your personal information for the following purposes in accordance with this Privacy Policy: If, however, we provide you with more specific purpose(s) of use either at the time we ask you to provide your personal information or through other means, then such notice will take precedence over the general purposes of use stated in Section 4.a of this Privacy Policy. 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:
■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 NATTER 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 NATTER users so that you can connect using NATTER and, subject to your prior agreement, to allow other NATTER users to connect with you;
•to enable you to sync other applications offered by NATTER, NATTER affiliates, and NATTER 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 aggregate anonymised statistical data regarding Services and any Additional Services;
•to comply with applicable laws or legal obligations;
■for maintaining the security of Services or preventing unauthorised use:
•to verify your identity;
•to monitor, detect and deter unauthorised or fraudulent use of, or abuse of, Services;
•to verify yourself or to notify you in case any unauthorised use occurred;
■for personalisation or advertisement delivery:
■for personalisation or advertisement delivery:
•to improve and/or optimise Services and any Additional Services; and
•to measure the effectiveness of advertisements that we place on the Internet or in other media.
If, however, we provide you with more specific purpose(s) of use either at the time we ask you to provide your personal information or through other means, then such notice will take precedence over the general purposes of use stated in Section 4.a of this Privacy Policy. 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 NATTER Protect My Personal Information?
To fulfil our commitment to respecting and protecting your privacy and the confidentiality of your personal information, NATTER has implemented appropriate technical and organisational security standards, including industry-standard safeguards to prevent unauthorised access or disclosure, misuse, alternation, or destruction of your information. 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 unauthorised 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, NATTER processes and stores your information on secure servers located in Google.LLC data centres. 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 do not reach to data protection law in your country or region requires. 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 NATTER Keep My Information?
NATTER retains the personal information while: your Account is active; for the length of time needed to fulfil any of the applicable purposes of use described in this Privacy Policy; or to comply with applicable laws and regulations. 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 NATTER users, for the duration of the applicable limitation period; or
•to detect and deter unauthorised or fraudulent use of, or abuse of, Services.
e. Does NATTER Use Outside Service Providers or Agents?
To provide Services, it sometimes is necessary for NATTER to enlist third party service providers to process user data, which may include your personal information. These service providers include cloud computing services, notification 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. 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 organisational 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 NATTER Give My Information to Third Parties?
ther than as described in this Privacy Policy and other applicable privacy policies or addendums, NATTER will not provide your information to any third parties without your consent, unless we believe in good faith that we are required or permitted to do so under applicable laws.
g. Does NATTER Use Cookies or Other Similar Technologies?
We do not use cookies, we use local storage technologies. We use local storage technologies:
•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 customised services to you;
•to help us understand how people use Services and to improve them.
By continuing to use Services, you consent to our use of local storage technologies and similar technologies in accordance with this Privacy Policy.
5. Your Choices, Your Rights
There is a possibility that NATTER 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 NATTER 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 “Profile” 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.
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 NATTER’s collection and use of your personal information, you may choose to delete your entire Account directly through the NATTER 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 NATTER 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 NATTER users to contact you;
•whether to register your e-mail address;
•whether to block or unblock certain NATTER users;
•whether to add contacts automatically using the address book in your mobile phone;
•whether to allow other NATTER users, who already have your phone number, to reach you via NATTER; or
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.