Kurusenpai, for itself and on behalf of all current and future affiliates, subsidiaries, and partners (“Kurusenpai,” “we,” “us,” or “our”), has established this privacy policy (the “Privacy Policy”) to describe how we collect, use, disclose and transfer the information you provide by accessing or using a Kurusenpai website, Kurusenpai mobile applications or other Kurusenpai products or services on any computer, mobile phone, tablet, console or other. While this Privacy Policy is intended to generally describe our privacy practices, more detailed or more specific information may be provided in conjunction with a particular service that supplements the information available here.

Who we are

Kurusenpai gathers and processes your personal information in accordance with this Privacy Policy and in compliance with the relevant data protection regulation and laws. This notice provides you with the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data.

Our designated Data Protection Officer (“DPO”) is Shawn Stauffer, who can be contacted at contact@kurusenpai.com.

Information we collect

Kurusenpai processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We will never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this Privacy Policy.

The personal data that we collect on our website is:

  • Name;
  • Address;
  • Email;
  • Telephone number;
  • IP address;
  • Financial data for product or service purchases;
  • Browser type and version;
  • Time zone setting and location;
  • Browser plug-in types and versions; and
  • Operating system and platform.

We also provide several wearable technology products such as smart watches and smart wallets that may collect the following information:

  • device information: id, user id, device id, latitude, longitude, created at, updated at, deleted at
  • heart rate information: id, user id, number, date, start time, end time, created at, updated at, deleted at
  • license information: id, watch type, information, created at, updated at, deleted at
  • photo information: id, user id, file, thumb, path, extension, mime type, storage, created at, updated at, deleted at
  • profile information: id, user id, name, sex, height, weight, heart rate, birthday, goal, photo id, created at, updated at, deleted at
  • sleep information: id, user id, mode, duration, date, start time, created at, updated at, deleted at
  • fitness information: id, user id, steps, distance, calorie, date, start time, end time, created at, updated at, deleted at
  • user preference information: id, user id, walking running, height, weight, calories, created at, updated at
  • user information: id, email, phone, password, created at, updated at, deleted at

Data collection may be adjusted or turned off entirely in conjunction with the wearable device or a smartphone app associated with the wearable device. This data is collected to assist you with tracking exercise, sleep and other monitoring objectives, and you should not register or use these wearable devices if you do not wish to have this information collected and stored by Kurusenpai on your behalf.

We collect information through several other methods as well. First, we collect your personal information directly from you. For example, when you provide us your personal information when you make an order, fill out a form, contact our consumer support, or participate in a contest or sweepstake. Some of the devices include features that use precise location data, including

GPS signals, device sensors, wi-fi access points, and cell tower IDs – we collect this type of data if you grant us access to your location. The data collected varies depending on which device you use, and the data recorded on your device is transferred from your device to our servers when your device syncs with our applications or software.

Second, we collect your personal information passively. For example, we collect information about you over time and across different web sites when you visit this platform. We also use tracking tools like cookies and beacons. Features of our service may make use of your device attributes and settings that will allow us to determine your physical location. Such technologies may include IP address mapping, WiFi, GPS signals, cell tower positioning or other technologies. We use this information to enhance and personalize your experience and provide you with offers and services that may be of interest to you. Kurusenpai does not have control over your device or browser settings, but we do recommend enabling location services on your device or browser so you can take advantage of the location based features and functionality offered.

Finally, we may sometimes collect your personal information from third parties. For example, when you interact with us through a social media function such as a plug-in (e.g., a Facebook “like” button) then you may be permitting us to have on-going access to some information from your social network profile (such as your name, email address, your friend list, photo, age, gender, location, birthday, social networking ID, current city, the people/sites you follow, and so forth), to the extent allowed by your settings with the third party platform or site. We may also obtain information about you from a third party data aggregator, cookie technology operator, advertising network, or another type of data company.

How we use your personal data

Kurusenpai takes your privacy very seriously and will never disclose, share or sell your data without your consent; unless required to do so by law. We only retain your data for as long as is necessary and for the purposes specified in this Privacy Policy. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw this consent at any time, as is detailed further below. The purposes and reasons for processing your personal data are detailed below:

  • Provide a service or product you have requested.
  • Create an account on a service if you have requested one.
  •  Improve and personalize a service we offer and the advertising displayed through a service.
  • Respond to your inquiries, requests, and comments.
  • Allow you to participate in the interactive features of a service.
  • Provide technical support for a service.
  • Understand how a service is used so that we can improve a service provided to users.
  • Send you service-related communications, including announcements and administrative messages.
  • Send you information about products, services and promotions relating to us or other companies or organizations that we work with.
  • Combine the information we collect or receive about you for any of the foregoing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences OR by following the opt-out links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or certain other transactions.

Your rights with respect to personal information

Certain jurisdictions such as the European Union provide you with additional rights relating to your personal data. If your jurisdiction provides you with the right to do so, you may ask Kurusenpai to provide you with access to the personal information that Kurusenpai processes about you and to request information about:

  • What personal data we hold about you
  • The purposes of the processing
  • The categories of personal data concerned
  • The recipients to whom the personal data has/will be disclosed
  • How long we intend to store your personal data for
  • If we did not collect the data directly from you, information about the source of data we receive

If your jurisdiction provides you with the right to do so, and if you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.

If you reside in a jurisdiction that allows you to request erasure of your personal data, to restrict processing, or to object to any direct marketing from us, we will do so at your request. Where applicable, you may also have the right to data portability of your information and the right to be informed about any automated decision-making we may use.

If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure. You should direct any requests relating to obtaining copies of and/or deleting your personal data to our DPO using the contact information provided in the “Who we are” section above.

Who do we share your personal data with?

We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this Privacy Policy or where there is a legal requirement. In order to complete your order we may need to share some of your personal information with some fulfilment partners and couriers. Any processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this Privacy Policy, applicable data protection laws and any other appropriate confidentiality and security measures. Examples of how your information may be shared are:

  • Corporate affiliates and change of control: We may share your personal information with our corporate affiliates and if Kurusenpai itself (or part of its business) is sold or otherwise changes control, owners would have access to your personal information for the uses set out herein.
  • Service providers: We may share your personal information with suppliers who perform services on our behalf and have agreed in writing to protect and not further disclose your information.
  • Payment service providers and vendors: If you order through our website, we may share your personal information with the payment service providers you have ordered through. These third parties will process your personal information as data controllers in accordance with their own privacy policies. If you contact our consumer support, they may need to share information about your request with the relevant travel vendor in order to assist you.
  • Business partners: We may share your personal information with various business partners with whom we may jointly offer products or services, or whose products or services may be offered on our website. Some of these business providers include, Amazon, Inc., Facebook, Inc., Mailchimp, and their subsidiaries and affiliates. These business partners may use your personal information for online behavioral advertising purposes, or to offer you services or products that we believe you may be interested in. We may also share your information as otherwise described to you at the time of collection. For example, if you provide information to enter a sweepstakes, we may share your information with the promotional partners. We may also share anonymous aggregated usage information with partners.
  • Information shared in public: If you provide us a review of our products and services, you authorize us to publish it on all our web sites under the screen name you provided. You also authorize us to aggregate it with other reviews.
  • Authorities: We may disclose personal information if required by law, for example to law enforcement or other authorities. This includes court orders, subpoenas and orders arising from legal processes, and administrative or criminal investigations. We may also disclose your personal information if the disclosure is necessary for the prevention, detection or prosecution of criminal acts or to prevent other damage, or in response to a legal action or to enforce our rights and claims.
  • Anonymized data: Kurusenpai may also aggregate certain data into groupings that can no longer reasonably be associated with you through processes that are known as anonymization or de-identification. Examples of information like this include information such as how many Kurusenpai products were purchased in a particular jurisdiction or the average number of steps walked by people in a particular city. Information that is no longer associated with you personally is not subject to this Privacy Policy, and Kurusenpai reserves the right to use this information in any manner of its choosing.

Safeguarding measures

Kurusenpai takes your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorized access, alteration, disclosure or destruction and have several layers of security measures in place, including, but not limited to:

  • Restricted access
  • IT authentication
  • Firewalls
  • Anti-virus/malware

Consequences of not providing your data

You are not obligated to provide your personal information to Kurusenpai, however, as this information is required for us to provide you with certain of our services, deliver your products and for other legitimate interests, we will not be able to offer all of our services without it.

How long do we keep your data?

Kurusenpai only retains personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations.

  • We keep personal information for as long as is required by applicable law. For example, we are required under UK tax law to keep your basic personal data (name, address, contact details) for a minimum of 6 years.
  • We keep your account information, like your name, email address, and password, for as long as your account is in existence because we need it to operate your account.
  • We keep certain health-related information, like your exercise or activity data for as long as you are actively using any device we provide that tracks and submits such information to us. If you stop using all devices that track such personal information, we will keep your information until: (1) one year after you use your account settings or tools to delete the data or your account, or (2) if there is no account associated with the data you are providing us, one year after you have stopped providing us any personal information through any device that provides such information.
  • We also keep information about you and your use of our services for as long as necessary for our legitimate business interests, for legal reasons, and to prevent harm, including as described in the “How do we use your personal data” and “Who do We Share Your Personal Data With” sections.
  • Kurusenpai may also de-identify data such that it is no longer associated with you, and Kurusenpai may keep this anonymized data for as long as it chooses, in its sole discretion.

Making a complaint

Kurusenpai only processes your personal information in compliance with this Privacy Policy and in accordance with the relevant data protection laws. If, however, you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, please contact our DPO using the contact information listed in the “Who we are” section of this Privacy Policy. If you are subject to the European Union’s General Data Protection Regulation, you also have the right to lodge a complaint with the Information Commissioner’s Office which is the supervisory authority for Kurusenpai. Contact information for the Information Commissioner’s Office is available on the www.ico.org.uk website.

How cookies work

A ‘cookie’ is a small piece of data sent from a website and stored on the user’s computer by the user’s web browser while the user is browsing. When you visit a site that uses cookies for the first time, a cookie is downloaded onto your computer/mobile device so that the next time you visit that site, your device will remember useful information such as items added in the shopping cart, visited pages or logging in options.

Cookies are widely used in order to make websites work, or to work more efficiently, and our site relies on cookies to optimize user experience and for features and services to function properly.

Most web browsers allow some control to restrict or block cookies through the browser settings, however if you disable cookies you may find this affects your ability to use certain parts of our website or services. For more information about cookies visit https://www.aboutcookies.org.

Other websites

Kurusenpai is not responsible for the privacy practices or the content of any other web sites to which a Service links or which link to a Service. By clicking on a link, logo, advertisement or other item, please note that you may no longer be on a Service controlled by Kurusenpai. If the Service is being delivered through a browser, you can check what Internet site you are on by viewing the URL at the top and/or bottom of your browser. We encourage you to read the posted privacy statement of each new site or other service you are using at that time, as this Privacy Policy may not apply to such services.

Children

We do not knowingly solicit data from or market to individuals under the age of 18. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact our DPO at contact@kurusenpai.com. After notification, we will delete such information from our files within a reasonable time.