Last Updated: April 7th, 2021
Effective Date: April 7th, 2021
LINKBAL is committed to protecting personal data, in accordance with applicable data protection laws and regulations, including the Act on the Protection of Personal Information” (Law No. 57. 2003) and the Guidelines Concerning the Personal Information Protection Act in Japan.
However, please note that we treat data that we collect as personal data only if such data meets the definition of personal data under the applicable laws and regulations in the relevant jurisdiction or is defined as personal data in the Specific Jurisdiction Policy (hereinafter defined) .
In a jurisdiction where both you and LINKBAL reside or are located, and where LINKBAL provides products or services to you, the specific policy for that jurisdiction as set forth in the Annex hereto (the “Specific Jurisdiction Policy”) shall apply. Thus, more than one Specific Jurisdiction Policy may be applicable if you and LINKBAL reside or are located in different jurisdictions.
1. Categories of Personal Data We Collect
The categories of personal data that we collect are as set forth below, provided, however that as noted above, we treat the data we collect as personal data only if such data is defined as personal data in the Specific Jurisdiction Policy or meets the definition of personal data under the applicable laws and regulations of each jurisdiction:
- date of birth;
- place of residence;
- e-mail address;
- day off
- interests and preferences
- personality assessment (test results)
- personal photos
- annual income amount;
- your preference on discretionary items such as smoking and drinking;
- location data;
- requirements for the person you want to meet such as gender, age, place of residence, email address, day off, occupation, interests and preference, religion and race
- IP address
- cookies; and
- other categories of personal information necessary for the purposes specified in Section 2. “How We Use Your Personal Information” below (if required under applicable law, we will notify you of the categories of such personal information separately).
As described in Section 4. “How We Share Your Personal Data” below, each company of LINKBAL may collect personal data from another company of LINKBAL.
2. How We Use Your Personal Data
We use your personal data for the purposes described below. However, legal grounds to process your personal data may change subject to relevant law and regulations, so please also refer to the applicable Specific Jurisdiction Policy.
Personal data collected by us will be used for:
- providing you with our services, such as online dating event services and matching services
- fulfilling our contractual obligations in relation to transactions between you and us, including processing your orders and payments;
- communicating with you about the products, services, campaigns and events offered by LINKBAL, including responding to your enquiries and complaints and providing news and information which we think will be of interest to you;
- distributing targeting advertisement to you; and
- carrying out any other purpose described to you at the time the information was collected.
3. How We Share Your Personal Data
- sharing with digital marketing and web development agencies for digital marketing and website related activities;
- sharing with other companies or individuals (including service providers, agents, sub-contractors, and suppliers), where such sharing is necessary for providing our products, campaigns and services to you;
- sharing with our professional advisors (such as lawyers, accountants and financial advisors), to the extent necessary and only if they are bound to keep your personal data confidential;
- sharing with other members of the LINKBAL group in whatever jurisdiction they are located or based in (i.e., LINKBAL Inc., and its subsidiaries and affiliates), where such sharing is necessary for the purposes described in Section 2. “How We Use Your Personal Data” above;
- sharing with other members of the LINKBAL group in whatever jurisdiction they are located or based in, where such sharing is necessary for administrating our business;
- sharing with our distributors and retailers for providing customer services
- disclosure as part of a proposed sale, merger, acquisition, joint venture or transfer of assets;
- disclosure required by law, requested by a government entity, or necessary to prevent crime or to ensure the rights, property and/or personal safety of LINKBAL (including its officers, employees, contractors and/or agents), affiliate companies of LINKBAL Inc., our customers or any other person; and
- as otherwise permitted by applicable law.
We may also share aggregated, anonymized information that cannot reasonably be used to identify you
4. Data Transfer outside of Country
We may transfer and process any personal data you provide to us to countries where other members of the LINKBAL group are located other than your country of residence. Those countries may not have the same data protection laws as your country of residence, and your personal information will be subject to applicable foreign laws. When we transfer your information to other countries, we will implement safeguards to protect your personal data as required under each applicable local data protection law and regulation.
We will use reasonable physical, electronic and procedural measures to safeguard personal information within our organization against loss, theft, and unauthorized use, disclosure, or modification. Where such personal data is held by unrelated third parties on our behalf, we have also imposed contractual obligations on such parties to ensure the confidentiality and security of such information.
However, while we will take all reasonable measures (as required by applicable law) to protect the integrity of such information, it is your duty to keep (and take reasonable steps to keep) confidential and secure any usernames and/or passwords issued by or relating to our websites, and to inform us promptly of any possible security breaches (including unauthorized access to your personal data through our websites). We cannot be responsible for any loss, unauthorized access or alteration, or misuse which occurs due to a lack of compliance on your part of such duty.
6. Retaining Personal Data
We will periodically review the personal data held by us to ensure that such data is accurate and up to date. We will also retain your personal data only for so long as it is necessary subject to our internal policies on data retention, or applicable laws and regulations.
7. Data Subject’s Rights
To the extent required by applicable law, you may have the right to withdraw your consent for the processing of your personal data, such consent providing the legal basis for the processing of your personal data. To withdraw your consent, please contact us by using the contact details set forth in Section 11. “Contact Us” below.
To the extent required by applicable law, you may have rights regarding your personal data including, without limitation, rights of disclosure, deletion, cessation of use, and correction. To assert your rights, please contact us by using the contact details set forth in Section 11. “Contact Us” below.
We will deal with your requests above in accordance with applicable laws and, where permitted by applicable law, may charge an appropriate fee to cover the costs of dealing with the request. Any request must include sufficient details to identify you. Upon receipt of your request, we may ask you for additional information (including proof of identity) in order to deal with your request. Please note that it may also take some time to deal with the request, although we aim to deal with all requests as soon as possible. We may also charge a reasonable fee to cover our administrative costs when dealing with any requests, which fees we will inform you of in advance.
8. Cookies and similar technologies
Cookies and other similar technologies are used on certain pages of our website and third party websites. Cookies are a technology for communicating between the website’s server and the browser. Through cookies, the browser you are using can be identified, but this does not identify your personal information. With cookies, the user’s viewing history of our website is recorded, which makes using the internet more beneficial. Cookies are widespread as a standard technology of the internet, and are used by many sites for the purpose of improving customer convenience, displaying advertising to customers and collecting statistics.
- to provide services customized for individual users by referring to saved user registration information when they log in to the authentication service;
- to display, on other companies’ sites, advertising optimized based on content in which the user has shown interest and the user’s use of LINKBAL sites;
- to research numbers of users and traffic on LINKBAL sites;
- to improve LINKBAL services.
- for security purposes, to encourage users to re-enter their passwords (reauthentication) if a certain time has passed since their last use.
You can at any time delete the cookies that have been set and change your browser settings to block some or all of any other cookies that are set on your device in the future. This can be done through your browser settings.
In addition, you can visit www.aboutcookies.org, which contains comprehensive information on how to do this on a wide variety of browsers.
Moreover, you can use another online service enabling you to manage the advertising cookies set in your devices: http://www.youronlinechoices.com.
However, by blocking cookies, you may become unable to use some of the services on the site. Furthermore, depending on your usage environment (such as browser settings and internet connection), it may not be possible to block cookies in some cases.
- Google https://www.google.com/settings/u/0/ads/authenticated
- Criteo http://www.criteo.com/ja/privacy-policy
- Yahoo Security policy http://docs.yahoo.co.jp/docs/info/terms/chapter1.html
9. Direct Marketing Communications
If you no longer want to receive direct marketing communications from us, you may opt out by following the instructions contained within each email or by contacting us by using the contact details set forth in Section 11. “Contact Us” below. Please note that if you opt out of receiving direct marketing communications, we may still send you administrative messages, from which you cannot opt out.
10. Third Party Services / Websites
Our websites may also contain links to other websites. LINKBAL bears no responsibility for the privacy commitments of these websites, or any disclosures of personal data or other information submitted by you through those websites, or otherwise collected from you by those website operators. It is your duty to ensure that you are satisfied with the extent of your rights and obligations in relation to your personal data when dealing with such websites or their operators. We encourage you to review the privacy policies and any other terms and conditions of those sites.
11. Contact Us
Chief Privacy Officer: General Manager, Administration Division
Contact point for complaints and inquiries concerning personal information: LINKBAL INK. DatingToday Customer Center
Email address: email@example.com
12. Policy Changes
We do not intend to knowingly collect personal data from minors as regulated in each applicable jurisdiction. (Please note that the age may be different in each applicable jurisdiction.) We request you to ensure that you do not provide any such regulated personal data of a minor to us. However, if you have reason to believe that a minor has provided such regulated personal data to us, please contact us by using the contact details set forth in Section 11. “Contact Us”, and we will delete that information from our databases if required to do so in the applicable jurisdiction. For specific rules applicable to each relevant jurisdiction, please refer to the relevant Specific Jurisdiction Policy.