When you install the tracking code or web conversion tracking on your own site, information is sent from visitors' browsers to Lumo. This transmission may require disclosure in your privacy policy or similar. This article explains how to think about what to include in a disclosure notice, along with a reference template you can use as is.
About This Template
This template is a reference example for creating a disclosure notice, not legal advice.
Lumo's tracking code sends information saved in a visitor's browser to an external party (Lumo). Japan's Telecommunications Business Act's external-transmission rules require businesses providing covered telecommunications services to notify users, or keep the information easily accessible to them, when information is sent from users' devices to external parties. Whether the rules apply to you, and what you must do, depends on your business and the nature of your service.
This template is a general example. Before you actually publish it, be sure to have your own legal team or an expert review the content. The final responsibility for the published wording rests with each company operating the site.
Why Disclosure Is Needed
Because the tracking code sends information saved in a visitor's browser to Lumo, you are expected to inform users of that fact and its purpose.
The tracking code and web conversion tracking send information from a visitor's browser in order to measure the effectiveness of LINE broadcasts. Since users cannot see what is being sent, it is considered good practice to clearly show, in your privacy policy or similar, the content of the information sent, its destination, and its purpose of use.
On sites that already disclose their tracking tools, you can handle this by adding Lumo's portion to that statement. On sites newly introducing measurement, take this opportunity to put a disclosure notice in place.
Information Sent and Its Purpose
Lumo's tracking code sends information for identifying visitors and information about outcomes (conversions).
| Information sent | Content | Main purpose of use |
|---|---|---|
| LINE identifier | An ID for identifying friends who visited via LINE. Saved in the browser and sent | Identifying visitors, measuring the effectiveness of LINE broadcasts |
| Conversion information | The type of outcome such as a purchase or reservation, amount, currency, order number, and so on | Recording outcomes, analyzing LINE's contribution to revenue and outcomes |
| Email address | Only when you are set up to send email. Used to identify and match visitors |
Matching outcomes on a different browser or device. Stored converted into a non-recoverable form |
The email address is sent only when you are set up to pass email in lumo.conversion(). If you don't pass it, you may remove the email address line from the disclosure notice.
Sample Wording for Your Privacy Policy
The following is sample wording to include in your privacy policy or an "external transmission policy." Adjust it to your situation (the information you actually send and where you publish it) before using it.
[About Information Transmitted Externally]
This site uses the "Lumo" measurement tag to measure the
effectiveness of the communications we send through LINE.
As a result, the following information is transmitted from your
browser to Lumo (provider: Little Help Agency LLC).
- LINE identifier
(an ID used to identify customers who visited via LINE)
- Conversion information
(the type of outcome such as a purchase or reservation,
as well as the amount, currency, order number, and so on)
- Email address
(used to identify and match customers;
stored converted into a non-recoverable form)
[Purpose of Use]
- Measuring the effectiveness of communications sent through LINE
(analyzing contribution to outcomes and revenue)
- Providing more relevant communications by identifying customers
For details on the information transmitted externally and how Lumo
handles it, please see the privacy policy established by Lumo's provider.
If you are not sending the email address, delete the lines about the email address. If you already disclose other tracking tools, add the above content to that statement.
Points to Keep in Mind When You Write It
Before you publish the disclosure notice, check a few points against your own situation.
- Match it to the information you send: State only the information you actually send—for example, remove the email address entry if you don't pass
email - Decide where to place it: Publish it somewhere users can easily find, such as within your privacy policy or on a standalone "external transmission policy" page
- Get legal review: Before publishing, have your own legal team or an expert review the wording. The extent of what you need to state depends on your site's content and operation
When you're unsure how to prepare the disclosure notice, it's easier to start by checking the disclosure notices you already publish for other tools and adding Lumo's portion in the same style.