Handling of Geolocation Information, etc. Processed by Sufficient Anonymization

  • *The original of this policy shall be in Japanese and an English translation is for reference purpose only

Rakuten Mobile, Inc. (hereinafter "Rakuten Mobile" or "we") will utilize information about you (i.e., the customer) including geolocation information processed by "sufficient anonymization" to the extent necessary for fulfilling the following purposes of use, in accordance with the Guidelines for Sufficient Anonymization in Telecommunications Business formulated by five telecommunications business-related organizations including accredited personal information protection organization Japan Data Communications Association.

Use of geolocation information, etc. processed by sufficient anonymization

1. Definition of terms

The terms in this Handling of Geolocation Information, etc. Processed by Sufficient Anonymization (hereinafter "Policy") are defined as follows.

"Sufficient anonymization": This refers to a mechanism devised as a method of processing geolocation information handled by telecommunications carriers so that geolocation information cannot be linked to communications at the individual level, in order to strike a balance among the secrecy of communications, protection of privacy and social utilization.

Geolocation information: This refers to information that indicates the location where you are as the holder of the communication device you use. This includes geolocation information concerning mobile phone base stations, GPS geolocation information, geolocation information of wireless access points (WAPs), etc.

Supplementary information: This refers to information about you retained by us, which is used in combination with geolocation information.

Anonymized use: This means using geolocation information and supplementary information after "sufficient anonymization."

Anonymously processed data: This refers to data processed by "sufficient anonymization."

Privacy impact assessment: This refers to a series of activities to identify, analyze, assess, diagnose and deal with the impact of handling of information on privacy in advance.

2. Geolocation information to be used

We collect the following geolocation information (limited to the place and date/time of communication and the device ID) from the communication device you use. Of note, this may include geolocation information subject to secrecy of communications.

[Types of geolocation information]

  • Geolocation information of base station
  • Latitude, longitude and other information of the base station to which the communication device you use has connected and the time of such connection

3. Accuracy, collection frequency and ID expiry of geolocation information

We collect geolocation information on the communication device you use as follows.

  • (1) Accuracy Several hundred meters
  • (2) Collection frequency Each time communication or call is attempted
  • (3) ID expiry (ID: Your identification number)

4. Supplementary information

After combining the following supplementary information with geolocation information, we will process the information by "sufficient anonymization."

  • [1] Sex
  • [2] Age
  • [3] Address (name of municipality)

5. Purposes of use

We will use anonymously processed data for the following purposes.

  • [1] Improvement of quality of services provided by Rakuten Mobile, and planning, development and provision of new products and new services
  • [2] Marketing research and analysis related to services provided by Rakuten Mobile
  • [3] Guidance to products, services and campaigns by Rakuten Mobile and partnering companies
  • [4] Distribution and display of advertisements and questionnaires by Rakuten Mobile and partnering companies
  • [5] Provision of other information deemed useful to you and other customers, etc. by Rakuten Mobile

6. Processing method

We will execute "sufficient anonymization" of geolocation information and supplementary information by combining the following methods.

Processing methods to be used:

  • [1] Item deletion: This involves deleting personal information items contained in the personal information database, etc. subject to processing. For example, age data will be deleted from all personal information.
  • [2]Generalization: This involves replacing descriptions, etc. contained in information subject to processing with a broader concept or value. For example, "age: 70" will be replaced with "elderly person."
  • [3] Rounding: This involves replacing a value contained in the database subject to processing with a value obtained by rounding off, etc.

7. Third-party provision

In order to fulfill the purposes of use prescribed in "5. Purposes of use", we may provide anonymously processed data to Rakuten, Inc. and its subsidiaries and affiliates, as well as third parties including outsourcees.

In order to prevent such third parties from collating anonymously processed data with other information and performing other acts aimed at identifying specific individuals, we will take necessary measures such as concluding contracts with them.

8. Storage period

Geolocation information, supplementary information, and half-processed data generated in the course of "sufficient anonymization" shall be stored only for three (3) months. No particular limit is set for the storage period of anonymously processed data.

9. Information management system

For the management of geolocation information, supplementary information, half-processed data generated in the course of "sufficient anonymization," anonymously processed data and information on processing methods, we will appoint a "Information security manager" dedicated to building and implementing an in-house management system in an appropriate manner.

We will also conduct a privacy impact assessment with respect to processing methods, management and operation system, etc. and release the results to the public separately.

Inquiry counter and cease of anonymized use

1. Inquiry counter

  • If you have any inquiries about anonymized use or would like to make a request to cease anonymized use, please contact the following inquiry counter.

  • Rakuten Mobile Communication Center

    TEL: 050-5434-4653

  • Operating hours: From 9:00 to 20:00 (open seven days a week, 365 days a year)

2. Cease of anonymized use

If you would like to make a request to cease the anonymized use of your customer information by Rakuten Mobile stated in this Policy, please make the request to Rakuten Mobile Communication Center stated in "1. Inquiry counter" above. We will cease the anonymized use of information about you as soon as possible, and to the extent possible, delete such information (excluding anonymously processed data).

However, please understand that from the time of receiving your request, the number of days prescribed by us will be required to complete the procedures to cease anonymized use.

In cases where we have received your request to reverse the procedures taken by you to cease anonymized use, we will resume the anonymized use of your customer information in accordance with the provisions of this Policy after obtaining your consent again. Again, please acknowledge that from the time of receiving your request, the number of days prescribed by us will be required to complete the procedures to resume anonymized use.

Revised: April 8, 2020