PRIVACY POLICY
Welcome to the Privacy Policy for NetPulse-Rakuten Site Manager (collectively"we", "us", "our" or the “Service”). We provide and operate the mobile application NetPulse-Rakuten Site Manager (the“Application”). You can find more information about the Application here.
The Service is provided by Rakuten Symphony, Inc., which is part of the Rakuten Group. Rakuten Group, Inc., is based in Tokyo, Japan. More information about Rakuten is available at https://global.rakuten.com/corp/about/company.
This privacy policy explains how we collect, use,share and protect your personal data. We also explain what options and rightsyou have and how to use them.
Please note that this privacy policy does not apply to enterprise license users of the Service, or staff of Rakuten Group using the Service in the course of employment.
This Application is intended for use by adults, and the Service does not knowingly collect any personal information about consumers under 16 years of age without their consent, or, if under 13 years of age, the verified consent of a parent or guardian.
PERSONAL DATA WE COLLECT AND HOW
We collect personal data directly from you and your use of the Service, including when you register or sign-up for the Service.The section of the privacy policy details the categories of personal data we collect, and how we obtain it.
We collect and process personal data that you provide to us when you register or sign up on the Application. This contains:
For certain testing tools, we may ask for device-level permissions, such as Bluetooth access, microphone and camera. The Application will not collect, store or process any personal data from these permissions. You may choose to deny permissions, in which case the relevant Application feature may not be usable. You can also provide limited permissions to use the Application feature and subsequently revoke your permissions.
Please note that we do not collect or process personal data in the following manner:
HOW WE USE YOUR DATA AND THEBASIS ON WHICH WE USE IT
We always need a proper reason to process your data.
The basis shall be the collection of personal data for the purpose of performing our contract with you (create your account); where applicable, fulfilling our legitimate interests, only when we have a valid interest that shall not override yours (the collection of data in order to secure our Service); complying with our legal obligations; as well as, where applicable, processing personal data based on your consent (when you voluntarily request to participate in our marketing activities).
If we ask for your consent to process your personal data, you may withdraw your consent or permissions on your device settings at any time. Please note that withdrawing such permissions may result in certain Application features no longer being accessible or usable.
You can find here the information regarding the purposes for which we process the types of personal data listed above, as well as our basis for such processing operations.
We may use anonymous, statistical or aggregated information to properly operate the Service, to improve the quality of the Service, to enhance user experience, to create new services and features, to change or eliminate existing content or services, and for further internal, commercial and statistical purposes.
We may also post, disseminate, or make available to third parties such anonymous, statistical or aggregated information collected on the Service. Such information will not contain orprocess any personal identifiers.
YOUR RIGHTS AND CHOICES
The rights and choices about your data are different depending on your location. This includes the right to request:
- access to your data; either if you want to know what data we have about you;
- geta copy of your data in a machine-readable format (right to data portability);
- correct any information that is wrong;
- delete your data;
- restrict usage to the bare minimum (for example, if you ask us to delete, but we still need to keep your order history for legal reasons, like tax audits of our business);
- object to specific uses (you can opt-out of marketing e-mails);
- ask us where we got certain data about you, how we use it and with whom we share it;
- withdraw your consent easily; if you do so, the lawfulness of processing based on your consent before its withdrawal will not be affected.
Please see below the rights available under the applicable law for your region:
You can always ask us to exercise these rights without having to be afraid of discrimination. Also, you can file a complaint with your data protection authority, where applicable, if you think we mishandled your data. If you want to request any of this from us, please just get in touch with us by using the Contact section below. We will always try to find a good and easy solution together.
DATA SHARING
We share your data with:
- Service providers and business partners, who help us make our service possible (they are data processors). We ensure they only have access to such information that is strictly necessary for us to provide the Service. These parties are required to secure the data they receive and to use the data for pre-agreed purposes only, while ensuring compliance with all applicable data protection regulations.
- Law enforcement bodies where we are required to share data or with a court if necessary to enforce our claims or other legal rights.
- Asset purchasers. In case our service or our company are fully or partly purchased by another company, data will be shared. The acquiring company will be bound by this privacy policy.
Below is a list of our service providers and partners, the data we share and the countries where they are located:
Because we operate as part of a global business, the recipients referred to above may be located outside the jurisdiction in which you are located (or in which we provide the services). See the section on "International Data Transfers" below for more information.
INTERNATIONAL DATA TRANSFER
Weare a global business. That means your data will be shared to certain Rakuten Group companies around the world, as necessary for providing you with our Service. Also, we use service providers in different countries, including services rendered by other Rakuten Group companies. Data are sent to them as well as indicated in the Data Sharing section above. We have taken steps to keep your data safe. We are always watching out to ensure they are trustworthy, and we have strict contracts in place.
Inside the Rakuten Group, we have BCRs (Binding Corporate Rules), a set of privacy internal rules that we apply across all the Rakuten Group companies. The BCRs are Rakuten global standard for the protection of privacy and processing of personal data. Rakuten’s BCRs allow secure transfers of data within the Rakuten Group companies and have been approved by the relevant Data Protection Authorities in Luxembourg and the United Kingdom. You can find them here.
SECURITY
We have strict security measures in place in accordance with high security standards to ensure that your account and your data are safe with us. Some of these are technical, like password rules and monitoring of log-in patterns. Others are organizational, like having proper processes and access rules in place. We do so to prevent unauthorized access or unauthorized disclosure of your information, to maintain the accuracy of such information and, when necessary, to ensure its proper destruction.
When collecting or transferring your personal information, we employ data masking technology, and restrict access only to those persons who require it to fulfil their job responsibilities. We conduct periodic reviews of our practices to ensure that our safeguards are properly implemented and remain state of the art. We make sure to always keep up with the latest developments.
RETENTION
As long as you have the Application installed, we keep your data.
When you delete the Application from your mobile device, we will delete your personal identifiers within 12 months. After deletion, you will need to register yourself again if you wish to use the Application.
When you delete the Application, we will retain data only if we are required to do so by law, or in case we still need it for our defense in court proceedings.
We will continue to retain aggregated data without any personal identifiers.
CONTACT US
The Service is the responsible for the personal data we collect and process. Our main offices are located in Japan.
For any questions or concerns, or if you want to make use of your rights, feel free to reach out to us anytime via <rsi-Support-NetPulse@mail.rakuten.com >.
Please note that when contacting us, we may ask you for certain information to verify your identity and respond to your request appropriately.
Our data protection officer can be contacted this way. If you have any complaint, we hope we can work with you to achieve a good solution. If we are not able to, you can contact your local data protection authority.
CHANGES TO THIS PRIVACY POLICY
We may update this privacy policy from time to time.
Substantial changes will take effect 30 days after the Service has posted an initial notification on the Application. Other changes will take effect 7 days after their initial posting on the Application. However, if the Service amends this policy to comply with any legal requirements, the amendments will become effective immediately upon their initial posting, or as required.
Not withstanding preceding paragraph, the Service will seek your acceptance of revised terms of the privacy policy, if the scope of processing deviates from the scope specified in the previous policy.