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KICHI PRIVACY POLICY

Last update: 13 March 2021

This privacy policy explains in detail how we collect, use, and disclose your personal data when you use KICHI. It also informs you about the choices that you have with respect to your personal data. Please read this privacy policy carefully.         

  1. GENERAL INFORMATION

Here you can find some general information about us and the Kichi software.

1.1 About the Privacy Policy. This Kichi privacy policy (the “Privacy Policy”) governs the processing of personal data collected from individual users and entities (“you” and “your”) through the website https://learnkichi.com and the related software application ‘Kichi’(collectively, “KICHI”). The Privacy Policy does not cover any third-party websites, applications or software that integrate with KICHI or any other third-party products and services.

1.2 About KICHI. KICHI is a language learning software product that allows you to quickly read in the language you want, translate words, and remember those words.

1.3 Data controller. KICHI is owned and operated by Robert Sherling having an address at Minato-ku Aoyama 2-2-15, Win Aoyama 942, Tokyo-to 107-0062, Japan.  (“we”, “us”, or “our”).

1.4 Minors. KICHI is not intended for use by persons under the age of 14. Only persons who are at the age of majority (18) can register their user accounts and make payments. Thus, if you would like to allow your child under 18 to use KICHI, you must register your user account by using your personal data and payment details. We do not knowingly collect personal data belonging to persons younger than 14. If you become aware that such a person has provided us with his or her personal data and you are a parent or a legal guardian of that person, please contact us immediately and we will remove that person’s personal data from our systems.

1.5 Term and termination. This Privacy Policy enters into force on the effective date indicated at the top of the Privacy Policy and remains valid until terminated or updated by us.

1.6 Amendments. We can change the Privacy Policy from time to time to address the changes in KICHI, laws, regulations, and industry standards. The amended version of the Privacy Policy will be posted on this page and, if we have your email address, we will send you a notice about all the changes implemented by us. We encourage you to review our Privacy Policy to stay informed. For significant material changes in the Privacy Policy or, where required by the applicable law, we may seek your consent. If you disagree with the changes to the Privacy Policy, you should cease using KICHI.

2. WHAT DATA DO WE COLLECT?

Here we explain in detail what personal data we collect from you, for what purposes we use it, what technical data is collected automatically when you use KICHI, and what messages you may receive from us.

2.1 Collection of personal data. We comply with data minimisation principles. Thus, we collect only a minimal amount of personal data that is necessary for your use of KICHI. We use your personal data for limited, specified and legitimate purposes explicitly mentioned in this Privacy Policy. In short, we use it only for the purposes of providing you with access to KICHI, registering your account, processing your payments, maintaining and improving KICHI, conducting research about KICHI and our business activities, replying to your enquiries, and pursuing our legitimate business interests. We do not repurpose your personal data. It means that we do not use it for any purposes that are different from the purposes for which your personal data was provided. Below, you can find an overbid of the types of personal data that we collect, the purposes for which we use it, and the legal bases on which we rely when processing it.

  • User account. When you register your user account, we collect your email address and password. We use the said information to register and maintain your user account, enable your access to KICHI, provide you with the requested services, contact you, if necessary, and maintain our business records. The legal bases on which we rely are ‘performing a contract with you’ and ’pursuing our legitimate business interests’ (i.e. operate, analyse, grow, and administer KICHI). We will store this data until you delete your user account.  
  • Payments. When you make a payment for KICHI, we collect your email address, credit card details, name on card, and billing address. We use such information to process your payments and maintain our business records. The legal bases on which we rely are ‘performing a contract with you’ and ’pursuing our legitimate business interests’ (i.e. administer KICHI). We will store this data until the time period for which we have to keep our accountancy records expires.
  • Enquiries. When you contact us by email or using the contact form, we collect your name, email address, and any information that you decide to include in your message. We use such data to respond to your enquiries and provide you with the requested information. The legal bases on which we rely are ‘pursuing our legitimate business interests’ (i.e. to grow and promote our business) and ‘your consent’ (for optional personal data). We will store this data until you stop communicating with us.
  • IP address. When you browse KICHI, we or our third-party analytics service providers (as explained in below) collect your IP address. We use your IP address to analyse the technical aspects of your use of KICHI, prevent fraud and abuse, and ensure the security of KICHI. The legal basis on which we rely is ‘pursuing our legitimate business interests’ (i.e. to analyse and protect KICHI). We will store this data as long as analytics records are necessary for our business.
  • Data that you upload. If, while using KICHI, you upload any images or text that contain personal data, we will process that data in order to provide you with the requested translation services. The legal basis on which we rely is ‘performing a contract with you’. We will store this data until you delete it.

2.2 Sensitive data. We do not collect or use any special categories of personal data (“sensitive data”) from you, unless you decide, at your own discretion, to provide such data to us. Sensitive data refers to your health, religious and political beliefs, racial origins, membership of a professional or trade association, or sexual orientation.    

2.3 Refusal to provide personal data. If you refuse to provide us with your personal data when we ask to, we may not be able to perform the requested operation and you may not be able to use the full functionality of KICHI, receive our services, or get our response. Please contact us immediately if you think that any personal data that we collect is excessive or not necessary for the intended purpose.  

2.4 Collection of non-personal data. When you browse KICHI, we automatically collect certain technical non-personal data related to your use of KICHI. Such data does not allow us us to identify you in any manner. The non-personal data includes the following information:

  • Your activity on KICHI;
  • Your browser type and version;
  • Your operating system;
  • Your device ID and status;
  • URL addresses from which you access KICHI;
  • The date and time when you access KICHI;
  • Your internet service provider; and
  • Your other online behaviour.

2.5 Purposes of non-personal data. We will use non-personal data for the following purposes:

  • To perform our contractual obligations;
  • To maintain our business records;
  • To analyse what kind of users use KICHI;
  • To examine the relevance, popularity, and engagement rate of the content available on KICHI;
  • To investigate and help prevent security issues and abuse; and
  • To develop and provide additional features to KICHI.

2.6 Your feedback. If you contact us, we may keep records of any questions, complaints, recommendations, or compliments made by you and the response. Where possible, we will de-identify your personal data (i.e., we will remove all personal data that is not necessary for keeping such records).

2.7 Aggregated and de-identified data. In case your non-personal data is combined with certain elements of your personal data in a way that allows us to identify you, we will handle such aggregated data as personal data. If your personal data is aggregated or de-identified in a way that it can no longer be associated with an identified or identifiable natural person, it will not be considered personal data and we may use it for any business purpose.

2.8 Service-related notices. If necessary, we will send you important informational messages, such as confirmation receipts, payment information, technical or administrative emails, and other administrative updates. Please note that such messages are sent on an “if-needed” basis and they do not fall within the scope of commercial communication that may require your prior consent. You cannot opt-out from service-related notices.

3. COOKIES

We use cookies for analytics purposes. Here, we give you information on cookies in general, the cookies that we use and for what purposes we do so, as well as how to decline cookies.

3.1 What should you know about cookies? A cookie is a small piece of data typically consisting of letters and numbers. When you visit a website, that website may send a cookie to your browser. Subsequently, the browser may store the cookie on your computer or mobile device for some time (cookie expiration date depends on its type). Cookies are used to recognise your device and collect certain information about your use of websites. Thus, over time, cookies allow websites to “remember” your actions and preferences. There are several types of cookies, namely, (i) persistent cookies, which remain valid until deleted by you, (ii) cookies that remain valid until their expiration date, and (iii) session cookies that are stored on a web browser and remain valid until the moment the browser is closed. Cookies may also be (i) first-party cookies (set by the original website itself) and (ii) third-party cookies (placed by third-party websites).

3.2 We may different types of cookies on KICHI, including:

  • Essential technical cookies that are strictly necessary to ensure the correct functioning of KICHI and provide the services requested by you;
  • Preference cookies that record information about the choices that you make on KICHI;
  • Marketing cookies that allow us to create, implement, and examine our marketing campaigns. Such cookies allow us to reach the right customers, analyse the productivity of our marketing campaigns, and offer you personalised advertisement; and
  • Statistics cookies that allow us to generate statistical reports about how you use KICHI.

Below, you can find a list of cookies that we use on KICHI, including their purpose and expiration time:

Essential technical cookies

Name

Type

Provider

(location)

Expiration

Purpose

__stripe_mid, __stripe_orig_props,
__private_machine_identifier,
scfc

First-Party HTTP cookie

US

One year

Used by Stripe (payment provider) to facilitate online payment

Locale, country,

First-Party HTTP cookie

US

2 years

Used by Stripe (payment provider) to facilitate online payment

machine_identifier

First-Party HTTP cookie

US

18 years

Used by Stripe (payment provider) to facilitate online payment

Cid, site-auth, stripe.csrf

First-Party HTTP cookie

US

Session

Used by Stripe (payment provider) to facilitate online payment

Cookie-perms

First-Party HTTP cookie

US

3 months

Used by Stripe (payment provider) to facilitate online payment

Statistics cookies

Name

Type

Provider

(location)

Expiration

Purpose

_ga

First-party HTTP cookie

learnkichi.com 

(Japan)

2 years

The cookie is used to set a unique ID that is used to generate statistical data on how you use KICHI.

_gat

First-party HTTP cookie

learnkichi.com 

(Japan)

1 day

The cookie is used by Google Analytics to throttle request rate.

_gid

First-party HTTP cookie

learnkichi.com 

(Japan)

1 day

The cookie is used to set a unique ID that is used to generate statistical data on how you use KICHI.

3.3 Cookie consent. When you visit KICHI, we may ask you to provide us with your consent to our use of all cookies via a cookie consent banner (for example, if you come from the EU). If you do not provide your opt-in consent, we will not serve you our non-essential cookies. Please note that we may not be able to provide you with the best possible user experience on KICHI if not all cookies are enabled.

3.4 Disabling cookies. If we ask you to provide your consent to our use of non-essential cookies, you have the freedom not to provide such consent. If you would like to refuse our use of non-essential cookies later, you can do it at any time by declining cookies in your browser or device. For more information, you can consult the cookie management instructions of your browser.

3.5 Google Analytics. To analyse your use of KICHI, we use Google Analytics, the business analytics service provided by Google LLC located in the United States (“Google”). Google generates statistical information by means of cookies and creates reports about your use of KICHI. The cookies served by Google Analytics are anonymous first-party cookies that do not allow us to identify you in any manner. The information generated by cookies will be transmitted to and stored by Google on servers in the United States. To ensure your privacy, your IP address will be anonymised and Google will not combine your IP address with other information Google holds about you. Thus, Google will not be able to identify you. In certain cases (e.g., when required by law or when third parties conduct services on behalf of Google), Google may transfer the information to third parties. For more information about Google Analytics’ privacy practices, please visit https://support.google.com/analytics/answer/6004245. If you would like to opt out from Google Analytics, you can do so by installing a Google Analytics opt-out browser add-on available at https://tools.google.com/dlpage/gaoptout?hl=en.

4. HOW LONG DO WE STORE YOUR DATA?

Here we explain for how long we keep your data in our systems and how we delete it.

4.1 Storage of personal data. We store your personal data in our systems only for as long as such personal data is required for the purposes described in this Privacy Policy or until you request us to update or delete your personal data, whichever comes first. For more details, please refer to section 2.1. After your personal data is no longer necessary for its purposes and there is no other legal basis for storing it, we will immediately securely delete your personal data from our systems. We do not store any personal data longer than necessary.

4.2 Storage of non-personal data. We retain non-personal data pertaining to you for as long as necessary for the purposes described in this Privacy Policy. This may include storing non-personal data for the period of time needed for us to examine our business activities, fulfill our contractual obligations, pursue our legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.

4.3 Storage as required by law. In instances when we are obliged by law to store your personal data for a certain period of time (e.g., for accountancy purposes), we will store your personal data for the time period stipulated by the applicable law and delete the personal data as soon as the required retention period expires.

5. HOW DO WE DISCLOSE YOUR DATA?

Here you can find information about third parties that may have access to your personal data.

5.1 Disclosure to data processors. We keep your personal data in strict confidentiality. However, if necessary for the intended purpose of your personal data (for example, for payment processing or service provision purposes), we will disclose your personal data to the service providers with whom we cooperate (our data processors). Your personal data may be shared with entities that provide technical support services to us, such as hosting and email distribution services. We do not sell your personal data to third parties and do not intend to do so in the future. The disclosure of your personal data is limited to the situations when it is required for the following purposes:

  • Ensuring the proper operation of KICHI;
  • Ensuring the delivery of services requested by you;
  • Responding to your enquiries;
  • Pursuing our legitimate business interests;
  • Enforcing our rights, preventing fraud, and security purposes;
  • Carrying out our contractual obligations;
  • Law enforcement purposes; or
  • If you provide your prior consent to such a disclosure.

5.2 List of data processors. We choose our data processors carefully and make sure that they ensure an adequate level of protection of personal data that is consistent with this Privacy Policy and the applicable data protection laws. The data processors that will have access to your personal data are:

  • Our hosting service providers Google Cloud Platform, Amazon Web Services, and Google Firebase located in the United States;
  • Our analytics service providers Google Analytics, Sentry, and Firebase Analytics located in the United States;
  • Our payment service provider Stripe located in the United States;
  • Our developing service providers Google and Amazon located in the United States; and
  • Our independent contractors and consultants.

5.3 International transfers. Some of our data processors are likely to be based outside the country where you reside. For example, if you reside in a country belonging to the European Economic Area (EEA), we may need to transfer your personal data outside the EEA. In case it is necessary to make such a transfer, we will make sure that the country in which our data processor is located guarantees an adequate level of protection for your personal data or we conclude an agreement with it that ensures such protection (e.g., a data processing agreement based pre-approved standard contractual clauses).

5.4 Disclosure of non-personal data. Your non-personal data may be disclosed to third parties for any purpose as it does not identify you as a natural person. For example, we may share it with prospects or partners for business or research purposes, for improving KICHI, responding to lawful requests from public authorities or developing new products and services.

5.5 Legal requests. If requested by a public authority, we will disclose information about the users of KICHI to the extent necessary for pursuing a public interest objective, such as national security or law enforcement.

5.6 Successors. In case our business is sold partly or fully, we will provide your personal data to a purchaser or successor entity and request the successor to handle your personal data in line with this Privacy Policy.

6. HOW DO WE PROTECT YOUR DATA?

Here you can find information on how we protect your data against breaches.

6.1 Security measures. We implement technical and organisational information security measures   that protect your personal data from loss, misuse, unauthorised access and disclosure. The security measures taken by us include secured networks, strong passwords, limited access to your personal data by our staff, and anonymisation of personal data (when possible).

6.2 Security breaches. Although we put our best efforts to protect your personal data, given the nature of communication and information processing technology and the Internet, we cannot be liable for any unlawful destruction, loss, use, copying, modification, leakage, and falsification of your personal data caused by circumstances that are beyond our reasonable control. In case a serious breach occurs, we will take reasonable measures to mitigate the breach, as required by the applicable law. Our liability for any security breach will be limited to the highest extent permitted by the applicable law.

7. HOW CAN YOU MANAGE YOUR PERSONAL DATA?

Here you can find detailed information about the rights that you have with regard to your personal data and how to exercise those rights.

7.1 The list of your rights. You have the right to control how we process your personal data. Subject to any exemptions provided by law, you have the following rights:

  • Right of access: you can get a copy of your personal data that we store in our systems and a list of purposes for which your personal data is processed;
  • Right to rectification: you can rectify inaccurate personal data that we hold about you;
  • Right to erasure (right to be forgotten): you can ask us to erase your personal data from our systems;
  • Right to restriction: you can ask us to restrict the processing of your personal data;
  • Right to data portability: you can ask us to provide you with a copy of your personal data in a structured, commonly used and machine-readable format and move that personal data to another processor;
  • Right to object: you can ask us to stop processing your personal data;
  • Right to withdraw consent: you have the right to withdraw your consent, if you have provided one; or
  • Right to complaint: you can submit your complaint regarding our processing of your personal data.

7.2 How to exercise your rights? If you would like to exercise any of your legitimate rights, please contact us by email at contact@kichi.io and explain in detail your request. In order to verify the legitimacy of your request, we may ask you to provide us with an identifying piece of information, so that we can identify you in our system. We will answer your request within a reasonable time frame but no later than 30 days.

7.3 Complaints. If you would like to launch a complaint about the way in which we handle your personal data, we kindly ask you to contact us first and express your concerns. After you contact us, we will investigate your complaint and provide you with our response as soon as possible (no later than 2 weeks). If you are not satisfied with the outcome of your complaint, you have the right to lodge a complaint with your local data protection authority.

8. CONTACT

If you have any questions about this Privacy Policy our our data protection practices, please contact us by using the following contact details:

Email: contact@kichi.io

Postal address: KICHI, Robert Sherling, Minato-ku Aoyama 2-2-15, Win Aoyama 942, Tokyo-to 107-0062, Japan

[END]

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