DOSI

Wallet

Privacy Policy

The purpose of this document ("Privacy Policy") is to inform you ("you" or "User") of how LINE NEXT Inc. (and in the event that the Services are provided by any company which is affiliated with LINE NEXT Inc. ("LINE NEXT Affiliate"), that LINE NEXT Affiliate) manages Personal Data (as hereinafter defined) in connection with LINE NEXT’s services (hereinafter referred to collectively as the "Services").
Please take a moment to read this Privacy Policy carefully so that you know and understand the purposes for which we collect, use and disclose your Personal Data. If you have any questions about this Privacy Policy, please submit your request by email at dl_dosi_privacy@linecorp.com.

By interacting with us, submitting information to us, or signing up for or accessing Services offered by us, you indicate your acceptance of the terms of this Privacy Policy and agree and consent to LINE NEXT Inc. (including LINE NEXT Affiliates), as well as their respective representatives and/or agents (collectively referred to herein as "the Company", "us", "we" or "our") collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to the Company's authorized service providers and relevant third parties in the manner set forth in this Privacy Policy. If you do not agree with or are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue access to or use of the Services.

1. Personal Data Collected by the Company (hereinafter the “Personal Data”)


When you access any of the Services, use the Service, or conduct any transaction through the Services, we may collect the following categories of personal data (or personal information) from you or about you:

(Information you provide us)

 • Personal information such as name, email address;
 • Transaction information relating to your use of the Service;
 • Correspondence, being information that you provide to us in correspondence, including during ongoing customer support;
 • Entity information, such as for entity/institutional customers, or any comparable government-issued identification number, and governing documents or other proof of legal existence;

(Information we collect from you automatically)
 • Device information, in particular as to the computer, device, or browser that you rely on in order to access or use the Services, operating system name and version, device manufacturer and model, language, Internet browser type and version, and the name and version of the Services you are using;
 • Online identifiers, such as your IP address and domain name—we automatically log your IP address (a number that is assigned to the computer that you use to access the Internet) in our server log files whenever you access or use the Services, along with the time of your visit and the page(s) that you visited;
 • Geo-location data;
 • Usage data, such as system activity, internal and external information related to the DOSI or other related sites you visit, clickstream information, and other data collected via cookies and similar technologies;

(Information collected from third parties)

 • We do not collect any information from third parties.

In addition to the foregoing, you may also be required to provide additional Personal Data when you, amongst others, require support, send us information for troubleshooting or other analysis, participate in a survey or our other promotional activities or solicit any other communication from us.

Personal Data you provide during the account registration process may be retained if required or permitted under applicable law, even if your registration is left incomplete or abandoned. You may request the deletion of such information where applicable.

You may decide whether or not to submit any Personal Data required by us. You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the Services you have requested.

2. Cookies and Similar Technology

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

Cookies are typically stored on your computer's hard drive. Information collected from cookies is used by us to analyze trends, to administer the Services and to evaluate their effectiveness. With this knowledge, we can provide you with a more personalized experience when using the Services and we can improve the quality of such experience by recognizing and delivering more of the most desired features and information and by resolving access difficulties. We may also use cookies and/or a technology known as web bugs or clear gifs, which are typically stored in emails to help us confirm your receipt of, and response to, our emails.

Our service providers may also place cookies on the hard drive of your device with a view to receiving information that will educate us and our service providers on different aspects, such as how you navigate on the Services. Our service providers may analyze these data with a view to allow us to better understand your interests in the Services and to better serve those interests.

Please note that data collected by use of cookies or similar technologies may be linked to and combined with any other data, including Personal Data, relating to you that we process. Data collected by the use of cookies or similar technologies may also be used to assist us in (i) meeting our compliance obligations (including under applicable anti-money laundering and terrorism prevention laws), (ii) detecting irregular, suspicious or potentially fraudulent account activities, and (iii) assessing and improving the Services and advertising campaigns.

You can choose to deactivate cookies; however, in such circumstances, you will not be able to use parts of the Services which require cookies to be active.

3. Use of Google Analytics

We may also use a tool called “Google Analytics” to collect information about your use of the Services. Google Analytics collects information such as how often Users visit the Services, what pages they visit when they do so, and what other sites they used prior to coming to the Services. We use the information we get from Google Analytics only to improve the Services. Google Analytics collects only the IP address assigned to you on the date you visit the Services, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit the Services, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to the Services is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can prevent Google Analytics from recognizing you on return visits to this site by disabling cookies on your browser.

4. Purpose for Collection, Use and Disclosure of User Personal Data

The Company may collect, use and disclose a User’s Personal Data for the following purposes:

  A. To provide the Services: We use Personal Data to provide you with Services pursuant to the DOSI Terms of Service. For example, Personal Data may be used:
  (a) to offer undisturbed and smooth Services to you (including, without limitation, software upgrades and improvements of the Services);
  (b) to ensure that the Services are functioning properly;
  (c) to administer our website and to track user movement;
  (d) for troubleshooting purposes;
  (e) to allow you to manage your account; and/or
  (f) to conduct any other activities that are required to provide the Services.

  B. To enforce the terms of the LINE NEXT Terms of Service and other agreements: We use Personal Data to enforce the LINE NEXT Terms of Service, this Privacy Policy (including relevant Addendums hereto) and other agreements with Users (collectively, the “Policies”), as well as agreements with third parties. For example, Personal Data may be used:
  (a) to detect, prevent, investigate or report actual or potential violations of the Policies or any suspected illegal activities;
  (b) in connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations;
  (c) to protect us and our operations or those of our service providers;
  (d) to protect the rights, privacy, safety and property of us and our service providers;
  (e) to prevent physical harm or financial loss or any other risk for us, any of our service providers or any other individual involved in the provision of the Services;
  (f) to allow us to pursue available remedies or limit the damages that we or our service providers may sustain; and/or
  (g) to otherwise enforce the Policies.

  C. To detect and prevent fraud: We process your Personal Data to detect and prevent fraud on your account. For example, Personal Data may be used:
  (a) to prevent any unauthorized/fraudulent use of the Services;
  (b) to prevent, detect and investigate crime and analyze and manage commercial risks and conduct investigations relating to disputes, billing or fraud; and/or
  (c) to perform identity verification when you make an inquiry or give us instructions.

  D. To protect your rights and data and seek to ensure the integrity of the Services: Maintaining the security of your account and the DOSI exchange requires us to process Personal Data, including information about your device, your account activity and other relevant information. For example, Personal Data may be used:
  (a) to prevent any data breach or circumvention of our security measures or to mitigate any possible adverse effects from such activities;
  (b) to test, assess, or otherwise evaluate the effectiveness of the technical and organizational measures (which ensure the security of the processing of your Personal Data) put into place by us or by our service providers (including our Outsourced Contractors, as defined below); and/or
  (c) to protect your rights, privacy, safety and property.

  E. To comply with legal and regulatory requirements: We process your Personal Data as required by applicable laws and regulations. For example, Personal Data may be used:
  (a) to respond to a verified request relating to a criminal investigation (e.g. subpoena, court order or substantially similar legal procedure) or alleged illegal activity or any other activity that may expose us or any of our service providers, or you, to any legal proceeding or legal liability;
  (b) to meet or comply with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on us (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations); and/or
  (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence.

  F. To provide you with customer support services: We process your Personal Data any time that you reach out to our Customer Support team with issues arising from your account or your use of the Services. For example, Personal Data may be used:
  (a) to respond to your inquiries and support needs and to fulfill any other request you may have made to us;
  (b) to notify you of any other important information regarding the Services and to contact you where necessary;
  (c) to send you administrative information, such as information concerning changes to the Policies or other announcements regarding the Services; and/or
  (d) to otherwise provide customer support services to you.

  G. To optimize and enhance the Services: We use your Personal Data to understand how our products and Services are being used and to help us improve the Services and develop new products. For example, Personal Data may be used:
  (a) to personalize your experience by presenting content tailored to your interests;
  (b) to develop new features of the Services or other products offered by us;
  (c) to allow you to participate in usability studies, surveys and product tests;
  (d) to aggregate statistical data regarding the Services;
  (e) to conduct research and analysis aimed at reviewing and improving the Services; and/or
  (f) to perform data analysis and audits for the purpose of improving or developing new features or services relating to the Services.

  H. To market our products to you: Based on your communication preferences, we may send you marketing communications (e.g., emails or mobile notifications) to inform you about our events; to deliver targeted marketing; and to provide you with promotional offers. Our marketing will be conducted in accordance with your advertising/marketing preferences and as permitted by applicable law. (See our Marketing Policy for additional information.)

  I. For other business purposes: We may use your Personal Data for additional purposes if (i) that purpose is disclosed to you before the Personal Data is collected or (ii) you consent to such use. From time to time, and as required under applicable law, we may request your permission to allow us to share your Personal Data with third parties not presently covered by this Privacy Policy, or to use your Personal Data for a purpose that is incompatible with the purposes for which it was originally collected or for which your consent was subsequently obtained. If you choose to limit the use of your Personal Data, certain features of the Services may not be available to you.

5. Sale or Other Disclosure of Personal Data

As a matter of principle, we do not sell, rent, release, disseminate, make available, transfer, exchange, share, communicate or otherwise disclose (hereinafter “disclose”) your Personal Data to third parties for their marketing purposes, or for other purposes not contemplated by this Privacy Policy or permitted under applicable law. Subject to restrictions imposed under applicable law, this shall not prejudice our right to disclose your Personal Data to others (including public authorities, law enforcement agencies, data protection authorities or regulatory agencies, government officials or any other authorized third party) for the purposes listed in this Privacy Policy, if:
 • it is necessary for the conclusion or the performance of a contract or for the provision of the Services;
 • it is necessary for the conclusion or the performance of a contract or for the provision of the Services;
 • it is required by law or by virtue of public interest;
 • it is required pursuant to a civil, criminal or regulatory inquiry, investigation, subpoena or summons;
 • it is required by virtue of your vital interest;
 • it is necessary to pursue the Company’s legitimate business purposes, including the exercise or defense of legal claims;
 • you have given your consent; or
 • it is so allowed on another legal basis.

We may provide the Personal Data to any of the LINE NEXT Affiliates if the LINE NEXT Affiliate is appointed or engaged by us to provide any part of the Services. We shall procure that the LINE NEXT Affiliates abide by this Privacy Policy so as to protect your Personal Data.

In addition, we may disclose your Personal Data to third parties in the following circumstances:

 • To service providers under contract who assist in the provision of Services or help with parts of our business operations (“Outsourced Contractors”). In such circumstances, we will take steps to ensure that each Outsourced Contractor abides by the applicable privacy laws, including by adequately assessing the qualifications and eligibility of such Outsourced Contractor, stipulating a confidentiality clause in the relevant agreement with such Outsourced Contractor, and establishing an appropriate information administration system. Our contracts require these Outsourced Contractors to only use your information in connection with the services they perform for us, and prohibit them from selling your information to anyone else.
  o Security threat detection
  o Customer support
  o Internet (e.g., ISPs)
  o Data analytics
  o Information technology
  o Advertising and marketing
  o Data processing
  o Network infrastructure
  o Data storage and document repository services

 • To companies or other entities that we plan to merge with or be acquired by, to the extent permitted under applicable law. You will receive prior notice of any change in applicable policies.

 • To companies or other entities that purchase our assets pursuant to a court-approved sale or where we are required to share your information pursuant to insolvency laws in any applicable jurisdiction.

 • To our professional advisors who provide banking, legal, compliance, insurance, accounting or other consulting services, including to complete third-party financial, technical, compliance and legal audits of our operations or to otherwise comply with our legal obligations.

 • To law enforcement officials, or other third parties when we are compelled to do so by a subpoena, court order or similar legal procedure, or when we believe in good faith that the disclosure of such Personal Data is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of the LINE NEXT Terms of Service or any other applicable Policies.

6. Shared Use of Information

During the period when you use the Services, your Personal Data may be processed and used in the form(s) of printed documents and/or electronic files or otherwise by us, the LINE NEXT Affiliates, and/or the Outsourced Contractors within and/or outside the United States.

To facilitate our global operations, we may transfer, store, and process your Personal Data within our family of companies, partners, and service providers based throughout the world, including Japan, Singapore, South Korea, the United Kingdom, the United States, and possibly other countries. We contractually obligate recipients of your Personal Data to agree to at least the same level of privacy safeguards as required under applicable data protection laws. By communicating electronically with us, you acknowledge and agree to your Personal Data being processed in this way.

7. User's Rights

You may, at any time, confirm, supplement or correct your registered Personal Data on the Services.

You may, by contacting us via the methods described at the end of this Privacy Policy, view or request a copy of your Personal Data which we have collected from your use of the Services.

You may, by contacting us via the methods described at the end of this Privacy Policy, send us a request to correct or add to your Personal Data, if you find that your Personal Data registered with us has changed or is incorrect. You may request us to delete, or discontinue collecting, processing or using your Personal Data unless we are allowed to continue to keep, process or use your Personal Data as permitted by applicable laws and regulations.

When you request access to your Personal Data (including copies of your Personal Data) that you are unable to confirm/access through the Services, we may (subject to limitations imposed under applicable law) charge you a fee for the disclosure procedures.

You can choose freely whether or not you will provide us with your Personal Data; however, you may be unable to use all or part of the Services until you have provided us with the necessary information.

8. Information for California Residents

We are required under the California Consumer Privacy Act (“CCPA”) to provide certain information to California residents about how we collect, use and share their personal information, and about rights and choices California residents may have concerning their personal information. For purposes of this section, “personal information” has the meaning provided in the CCPA (and would typically include Personal Data, as such term is used in this Privacy Policy).

  Personal information that we collect, use, and share

As a newly-launched business, we do not have a record of collection, use and sharing of personal information during the preceding 12-month period. For ease of reference, however, the chart below shows how we intend to use the categories of personal information that are expected to be collected, used and disclosed upon (or in connection with) the launch of our operations. We do not “sell” any personal information, as “selling” is defined under the CCPA.


Personal Information Category
Sources of Personal Information
Purpose of Collecting Personal Information
Disclosure of Personal Information
(A) Identifiers such as real online identifier, IP address, email address, account name, or other similar identifiersInformation you provide us; Information collected from you automatically; Information collected from third parties
Sections 4A, 4B, 4C, 4D, 4E, 4F, 4G and 4H
- Service providers
- Professional advisors
(B) Customer records such as signature
Not collected
Not applicable Not applicable
(C) Protected classifications under California and federal law, including gender, age and citizenship Not collected
Not applicable Not applicable
(D) Commercial information such as records of services purchased, obtained, or considered
Information you provide us; Information we collect from you automatically; Information collected from third parties
Sections 4A, 4C, 4D, 4E, 4F, 4G and 4H
- Service providers
- Professional advisors
(E) Biometric information
Not collected
Not applicable
Not applicable
(F) Usage Data, including Internet or other electronic network activity information (such as browsing historian search history), and other online identifiers
Information we collect from you automatically Sections 4A, 4B, 4C, 4D, 4F, 4G and 4H
- Third party identity verification services

- Service providers

- Professional advisors
(G) Geolocation data
Information we collect from you automatically
Sections 4A, 4C and 4E
- Third party identity verification services
- Service providers
(H) Sensory data, such as audio, electronic, visual information
Not collected
Not applicable
Not applicable
(I) Professional or employment-related information
Information you provide us
Sections 4C, 4E and 4H
- Third party identity verification services
- Service providers
(J) Education information (not publicly available)
Not collected
Not applicable
Not applicable
(K) Inferences about preferences, characteristics, predispositions, etc.
Not collected
Not applicable
Not applicable

  California privacy rights

California consumers have the following rights under the CCPA with respect to their personal information. Please understand, however, that these rights are not absolute, and we may decline requests as permitted under applicable law.

 • Right to Request Access. You may submit a request that we disclose the categories and specific pieces of personal information that we have collected, used or disclosed about you in the past 12 months.

 • Right to Request Deletion. You may submit a request that we delete the personal information that we have about you.

 • Right to Opt Out of Sale of Personal Information. You have the right to opt out of the sale of your personal information. We do not sell personal information of Users within the meaning of the CCPA.

 • Right Not to Receive Discriminatory Treatment. You have the right to exercise the privacy rights conferred by the CCPA without discriminatory treatment.

You may submit a request to access or delete your personal information by emailing us at dl_dosi_privacy@linecorp.com. We are legally obligated to verify your identity when you submit a request. We may request additional information from you to verify your identity. If you submit a request to delete your personal information, you will also be required to confirm the deletion request by email.

You may designate an agent to make a request under the CCPA on your behalf. Your authorized agent must submit proof that you have provided them with power of attorney pursuant to California Probate Code sections 4000 to 4465. We may deny a request from a purported authorized agent who does not provide proof of authorization to act on your behalf.

Please note that we are not obligated to provide you with a copy of your personal information more than twice in a 12-month period.

9. Anonymized and Aggregated Data

Anonymization is a data processing technique that removes or modifies personal information so that it cannot be associated with a specific individual. Except for this section, none of the other provisions of this Privacy Policy applies to anonymized or aggregated customer data (i.e., information about our customers that we combine together so that it no longer identifies or references an individual customer).

We may use anonymized or aggregated customer data for any business purpose, including to better understand customer needs and behaviors, improve our products and services, conduct business intelligence and marketing, and detect security threats. We may perform our own analytics on anonymized data or enable analytics provided by third parties. Types of data we may anonymize include transaction data, clickstream data, performance metrics, and fraud indicators.

10. Third-Party Sites and Services

If you authorize one or more third-party applications to access the Services, then information you have provided to us may be shared with those third parties. Unless you provide further authorization, these third parties are not allowed to use this information for any purpose other than to facilitate your transactions using the Services. Please note that third parties you interact with may have their own privacy policies, and we are not responsible for their operations. Information collected by third parties, which may include such things as contact details or location data, is governed by their privacy practices. In addition, information that we share with a third party based on an account connection will be used and disclosed in accordance with the third party’s privacy practices. We encourage you to learn about the privacy practices of those third parties.

11. Information Security

We maintain (and contractually require third parties we share your Personal Data with to maintain) appropriate physical, technical and administrative safeguards to protect the security and confidentiality of the Personal Data you entrust to us.

We may store and process all or part of your personal and transactional information, including certain payment information, such as your encrypted bank account and/or routing numbers, in the United States and elsewhere in the world where our facilities or our service providers are located. We protect your Personal Data by maintaining physical, electronic, and procedural safeguards in compliance with the applicable laws and regulations. For example, we use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorize access to Personal Data only for those employees who require it to fulfill their job responsibilities.

However, we cannot guarantee that loss, misuse, unauthorized acquisition, or alteration of your data will not occur. Please recognize that you play a vital role in protecting your own Personal Data. When registering with our Services, it is important to choose a password of sufficient length and complexity, to not reveal this password to any third parties, and to immediately notify us if you become aware of any unauthorized access to or use of your account.

Furthermore, we cannot ensure or warrant the security or confidentiality of information you transmit to us or receive from us by Internet or wireless connection, including email, phone, or SMS, since we have no way of protecting that information once it leaves and until it reaches us. If you have reason to believe that your data is no longer secure, please contact us using the contact information provided in this Privacy Policy.

12. Retention of Personal Data

We store your Personal Data securely throughout the life you use the Service. We will only retain your personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting obligations or to resolve disputes. While retention requirements vary by jurisdiction, information about our typical retention periods for different aspects of your Personal Data are described below.

 • Contact Information such as your name, email address and telephone number for marketing purposes is retained on an ongoing basis until you unsubscribe. Thereafter we will add your details to our suppression list to ensure we do not inadvertently market to you.
 • Recording of our telephone calls with you may be kept for a period of at least five years.
 • Information collected via technical means such as cookies, webpage counters and other analytics tools is kept for a period of up to one year from expiry of the cookie.

13. Withdrawal from the Services

If you decide not to keep using the Services, all information (including, without limitation, the Personal Data) relating to you will be handled in accordance with applicable law, this Privacy Policy, and our other applicable policies, but such deactivation shall not be considered as a withdrawal of consent for our use and disclosure of such information unless it is otherwise informed in writing.

If you withdraw your consent to any or all use of your Personal Data, depending on the nature of the request, we may not be in a position to continue to provide the Services to you.

14. A Special Note about Personal Data of Minors

We do not knowingly request to collect personal information from any person under the age of 18. If a User submitting personal information is suspected of being under the age of 18, we will require that User to close his or her account and will not allow that User to continue using the Services. We will also take steps to delete such User’s Personal Data as soon as possible.

15. Modifications to this Privacy Policy

This Privacy Policy may be revised from time to time. If we make any material change, we will notify you by email (sent to the email address specified in your account), by means of a notice on our site prior to the change becoming effective, or as otherwise required by applicable law.

You can access the latest version of this Privacy Policy at https://dosi.world/privacy. By visiting, accessing, or using the Services following any change to this Privacy Policy, you are consenting to the new Privacy Policy.

16. Inquiries and Complaints

If you have any uncertainty about this Privacy Policy or questions, complaints, access and/or correction requests or comments on the handling of Personal Data related to the Services, you should contact us via dl_dosi_privacy@linecorp.com.

17. Version

This Privacy Policy was updated on December 31, 2021


Marketing Policy

LINE NEXT Inc. (“Company”, “us”, “we” or “our”) would like to keep in touch with you about our services and offers that might interest you by email.

In addition, where permitted under the applicable law, we may collect, use and disclose Personal Data for the following additional purposes:


• providing information regarding the Services as well as advertising information from LINE NEXT;
• providing or marketing services, products and benefits to you, including but not limited to special events and promotions from us;
• administering and organizing contests, lucky draws, promotional events, competitions and marketing campaigns, and personalizing your experience at our touchpoints;
• conducting market research, analytics and surveys to enable us to understand and determine customer preferences and demographics for us to offer you products and services as well as special offers and marketing programs which may be relevant to your preferences and profile; and/or
• any other purpose reasonably related to the foregoing.

You can withdraw consent to providing Personal Data for marketing purposes by emailing us at dl_dosi_privacy@linecorp.com.