User Information Collected in Our Services
We collect some or all of the following information (“User Information”) from you through our services that become available to you upon installing SilentLog (“App”) and its related software, as well as through Dashboard, our web service that operates together with the App (collectively, “Services,” including affiliate services provided by our partners):
- Basic information including your name, address, date of birth, email address, gender, height, weight, profile photo or other image data, and other information you provide us when filling out our prescribed registration form;
- Information from your device including your mobile device information (IMEI, MEID, ESN, other device identification numbers, etc.), access logs, Cookies, IDFA, Advertising IDs, location information, sensor information associated with your communication device and photos and image data stored in your devices (only upon your consent); and
- Information regarding your contracts with affiliated services (“Affiliated Services”) provided by our partners including the type of service, effective date, billing and payment, vital data collected through healthcare devices, information you post or otherwise transmit through each affiliate service, usage history, your Facebook ID, information regarding coupons and points, information gathered through questionnaires and monitoring surveys, and other information we acquire through provision of the Services (e.g., application history, requests, inquiries, etc.)
How We Use User Information
We use your User Information collected through the Services for the purposes described below in an appropriate manner and only within the scope of your consent:
- To operate the systems necessary for providing the Services (and Affiliated Services upon your consent);
- To create your profile page and make available for other users to view, and to allow notifications from other users;
- To collect fees and late charges;
- To authorize your credit card for payments to Affiliated Services
- To customize information and advertisements within the Services according to your preferences;
- To provide you with information regarding the Services;
- To notify you in the event of termination, suspension or cancellation of the Services;
- To settle disputes or lawsuits;
- To respond to inquiries regarding the Services;
- To conduct marketing research and analysis;
- To create statistical data by processing information into a form that is not personally identifiable; and
- To provide, maintain and improve the Services in connection with any of the above.
Changes of Purposes
We will publicly announce to you or notify you of any changes made to the above-mentioned purposes in a manner prescribed by us; provided, however that we make changes only if we deem that such changes are reasonably related to the purposes initially prescribed.
How We Collect User Information
We collect User Information in an appropriate manner and not through misrepresentation or other improper means. If we are to acquire User Information through any means other than your use of the Services, we will publicly announce to you or notify you of such purposes of use.
Exchanging User Information with Third Parties
We may share or exchange the following User Information (including your Personal Information) with our partners or other third party content providers to the extent necessary for achieving the above-mentioned purposes:
- User Information provided to or shared with third parties: Address, date of birth, gender, height, weight, location information, and other information necessary for achieving the above-mentioned purposes.
- User Information will be provided to third parties in writing or through electronic or electromagnetic means.
- Users may submit a request to terminate our provision of their User Information to third parties. Please refer to the clauses titled “Retrieving and Modifying Your Own Information” (third paragraph) and “Inquiry” in this Policy for more details.
We may provide the Services in association with certain external services (“External Services”) such as LINE and Facebook. In such circumstances where users use particular Services that are linked to External Services, we may provide User Information to the respective providers of the External Services.
We take necessary and appropriate measures to securely manage User Information so as to prevent any leakage, loss, or damage. If we are to entrust any third party with the handling of all or part of User Information, we will conclude confidentiality agreements or other equivalent agreements with such third party in advance in accordance with the provisions of this Policy and exercise necessary and appropriate supervision over the third party to ensure security and control of the entrusted User Information.
Handling of Email Address
We make every effort to protect your email address to prevent any loss, theft, destruction, falsification, leakage, or unauthorized access, and comply with relevant laws, regulations and rules concerning Personal Information. We have taken internal measures to allow only certain authorized employees to access your email addresses. For important notices that need to be communicated to all users, we will send them out to all users.
IDFA and Related Technologies
We employ the following technologies as well as other equivalent technologies to provide the Services:
- Advertising ID: An identifier issued by Google, Inc. to identify your mobile device for targeted advertising purposes. The Advertising ID allows identification of your mobile device but does not allow identification of you as an individual. The Advertising ID function can be disabled by changing the setting of mobile devices, although the use of part or all of the Services may also be restricted as a result. (For more details, please refer to Google, Inc.’s website.)
- Cookies: A Cookie is an industry-standard technology used by web servers to identify users. Cookies allow identification of your computer but do not allow identification of you as an individual. Cookies can be disabled on certain web browsers by changing the setting, although the use of part or all of the Services may also be restricted as a result.
Information Gathering Modules
- Google Analytics by Google, Inc.
- Crittercism by Crittercism, Inc.
- Flurry by Flurry Inc.
- PartyTrack by Adways Inc.
- Facebook SDK by Facebook, Inc.
- Crashlytics by Crashlytics, Inc.
Disclosure of User Information
We do not disclose or share your Personal Information contained in User Information to any third party without your consent, except as required by the Act on the Protection of Personal Information and other relevant laws and regulations or as necessary in the following circumstances:
- When we entrust the handling of Personal Information to a third party to the extent necessary to achieve our purposes of use;
- When we entrust Personal Information of users to relevant payment service providers, credit card companies or banks for billing purposes;
- When we provide Personal Information to relevant providers of information gathering modules and External Services in accordance with the respective provisions under “Exchanging User Information with Third Parties” and “Information Gathering Modules” sections of this Policy;
- When personal information is provided to our successor in the event of a merger or a business transfer; or
- When required by applicable laws, regulations, court, police or other official bodies.
In order to conduct targeted advertising (“Targeted Advertising”), a technique to distribute advertisements according to the interests and preferences of each user based on User Information, we collect, store and use your location information, activity logs, and other account information (“Location and Account Information”) for the following purposes:
- To improve the convenience of the Services for users;
- To distribute advertisements suitable for each user;
- To utilize as statistical data;
- To provide contents recognized as beneficial to users; or
- To provide consulting services with respect to promotional activities and facilitate marketing activities of our partners and other third parties (collectively, “Partners”).
We may provide Location and Account Information and analysis reports obtained from such Location and Account Information to our Partners in a form that is not personally identifiable, only within the scope necessary for the purpose of providing services and advertisements tailored to your interests and preferences. Location and Account Information is handled by our Partners in accordance with the privacy policies and other terms and conditions prescribed by each respective Partner.
Retrieving and Modifying Your Own Information
If you wish to retrieve, modify, add to or delete your Personal Information you have provided us, you may submit a request by mail with a copy of an identity verification document (or a confirmation of an agent’s authority if requesting through an agent). Please include postage stamps for JPY 2,160 (inclusive of tax; customers submitting a request from overseas are also responsible for bearing the international mailing cost.) when requesting retrieval of your information or notice of purposes in writing.
We will disclose your Personal Information to the reasonable extent necessary in accordance with your request only after your identity is verified in the manner described above; provided, however, that we may not disclose or otherwise provide such information if we are not required to do so under the Act on the Protection of Personal Information or other relevant laws or regulations.
In the event that we receive a request to: a) terminate our use of Personal Information, b) terminate our provision of User Information to third parties, or c) delete your Personal Information, on the basis of protection under the Act on the Protection of Personal Information on grounds that your Personal Information has been used outside of the purposes of use announced to you in advance or that your Personal Information has been obtained through unlawful means, we will, upon confirming the identity of the person who has submitted such request, promptly respond to the request by terminating our use or deleting relevant information. Notwithstanding the foregoing, we may not always be able to accommodate your request if we are not required to do so under the Act on the Protection of Personal Information or other relevant laws or regulations.
We are not responsible for your disclosure of your own User Information to a third party using any function of the Services or through other means, or for making yourself personally identifiable from the information you provide us within the Services.
Although the Services may contain links to other services which are not directly operated by us, we are not in any way responsible for any contents or the protection of User Information with respect to such External Services.
Changes to this Policy
As part of our efforts for continuous improvement, we review our handling User Information from time to time and may revise this Policy without obtaining your consent in advance. A revised Policy will be effective immediately after its release on our Website unless otherwise separately specified by us; provided, however, that we will obtain your consent in a manner determined by us if we make any revisions requiring your consent under applicable laws or regulations.
If there is any discrepancy or inconsistency between the English and Japanese versions of this Policy, the Japanese version shall prevail.
For any inquiries regarding the handling of User Information, including any suggestions, questions, complaints or comments, please contact our Personal Information Help Desk at: Rei-Frontier Inc. Personal Information Help Desk Email: email@example.com (Please note that it may take some time to reply to your inquiries.)
Effective: October 6, 2014
Revised: October 15, 2014
Revised: September 22, 2015
Revised: August 7, 2017