Introduction and Scope

At Kizuna Senior Tech ("we," "our," or "us"), we are deeply committed to protecting your privacy and ensuring the security of your personal information. This comprehensive Privacy Policy explains in detail how we collect, use, store, share, and safeguard your data when you use our services, visit our website, participate in our programs, or interact with our platform in any capacity.

This policy applies to all users of our services, including students, caregivers, family members, workshop participants, and website visitors. By using our services, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy.

Information We Collect

Personal Information

We collect various types of personal information to provide you with our services effectively:

• Identity Information: Full name, age, date of birth, gender, and preferred language
• Contact Information: Phone numbers (mobile and landline), email addresses, mailing addresses, and emergency contact details
• Educational Information: Learning preferences, technology skill level assessments, progress tracking data, and lesson completion records
• Financial Information: Payment card details, billing addresses, subscription information, and transaction history
• Health and Accessibility Information: Vision, hearing, or mobility considerations relevant to our services (collected only with explicit consent)
• Family and Caregiver Information: Details about authorized family members or caregivers who may access your account or progress information
• Device Information: Information about the devices you use for learning, including make, model, operating system, and technical specifications
• Communication Records: Records of your interactions with our support team, including phone calls, emails, and chat conversations

Automatically Collected Information

When you use our website and services, we automatically collect certain technical information:

• Usage Data: Pages visited, time spent on our website, click patterns, and navigation paths
• Technical Data: IP address, browser type and version, device identifiers, screen resolution, and operating system
• Performance Data: Website loading times, error reports, and system performance metrics
• Location Data: General geographic location based on IP address (not precise location tracking)
• Cookie Data: Information collected through cookies and similar tracking technologies as detailed in our Cookie Policy

Information from Third Parties

We may receive information about you from third parties, including:

• Family members or caregivers who register on your behalf (with proper authorization)
• Community partners and healthcare providers who refer you to our services
• Payment processors and financial institutions for transaction verification
• Technology partners who help us deliver our services

How We Use Your Information

We use your personal information for the following legitimate business purposes:

• Service Delivery: Providing our educational services, customizing lessons to your skill level, and tracking your learning progress
• Account Management: Creating and maintaining your account, processing registrations, and managing subscriptions
• Communication: Sending you important service updates, lesson reminders, progress reports, and responding to your inquiries
• Payment Processing: Processing payments, managing billing, handling refunds, and preventing fraudulent transactions
• Scheduling and Coordination: Booking workshops, arranging in-home visits, and coordinating with community partners
• Family and Caregiver Support: Providing authorized family members and caregivers with progress updates and account access
• Service Improvement: Analyzing usage patterns to improve our platform, develop new features, and enhance user experience
• Safety and Security: Protecting against fraud, ensuring platform security, and maintaining the safety of our community
• Legal Compliance: Fulfilling our legal obligations, responding to legal requests, and protecting our rights and interests
• Marketing and Outreach: Sending you information about new services, educational content, and community events (with your consent)
• Research and Development: Conducting research to better understand the needs of older adults and improve our educational methods

Legal Basis for Processing

We process your personal information based on the following legal grounds:

• Contractual Necessity: Processing necessary to perform our contract with you and provide our services
• Legitimate Interests: Processing necessary for our legitimate business interests, such as improving our services and ensuring security
• Consent: Processing based on your explicit consent, which you can withdraw at any time
• Legal Obligation: Processing required to comply with applicable laws and regulations
• Vital Interests: Processing necessary to protect your vital interests or those of another person

Information Sharing and Disclosure

We do not sell, trade, or rent your personal information to third parties. We may share your information only in the following carefully controlled circumstances:

• With Your Consent: When you explicitly authorize us to share your information with specific third parties
• Authorized Representatives: With family members, caregivers, or legal representatives you have designated to access your account
• Service Providers: With trusted third-party vendors who assist us in operating our business, such as payment processors, hosting providers, and communication platforms
• Community Partners: With community centers, libraries, or healthcare providers where you participate in our programs (limited to necessary information only)
• Legal Requirements: When required by law, court order, or government regulation, or to protect our legal rights and interests
• Business Transfers: In connection with a merger, acquisition, or sale of assets, subject to confidentiality agreements
• Emergency Situations: When necessary to protect the safety and well-being of you or others

Data Security Measures

We implement comprehensive technical, administrative, and physical security measures to protect your personal information:

• Encryption: All sensitive data is encrypted both in transit and at rest using industry-standard encryption protocols
• Access Controls: Strict access controls ensure that only authorized personnel can access your information on a need-to-know basis
• Secure Infrastructure: Our systems are hosted on secure servers with regular security updates and monitoring
• Regular Audits: We conduct regular security assessments and vulnerability testing to identify and address potential risks
• Staff Training: All employees receive comprehensive training on data protection and privacy best practices
• Incident Response: We have established procedures for detecting, responding to, and reporting security incidents
• Data Minimization: We collect and retain only the information necessary to provide our services effectively
• Backup and Recovery: Regular data backups ensure business continuity while maintaining security standards

Your Privacy Rights

You have the following rights regarding your personal information, which you can exercise by contacting us:

• Right of Access: Request a copy of the personal information we hold about you, including details about how it's being used
• Right to Rectification: Request correction of inaccurate, incomplete, or outdated information
• Right to Erasure: Request deletion of your personal information, subject to certain legal limitations
• Right to Data Portability: Request transfer of your data to another service provider in a structured, machine-readable format
• Right to Object: Object to certain uses of your personal information, particularly for marketing purposes
• Right to Restrict Processing: Request limitation of how we process your information in certain circumstances
• Right to Withdraw Consent: Withdraw your consent for data processing at any time (where consent is the legal basis)
• Right to Lodge a Complaint: File a complaint with relevant data protection authorities if you believe your rights have been violated

International Data Transfers

As a Japan-based company, we primarily process data within Japan. However, some of our service providers may be located in other countries. When we transfer personal information internationally, we ensure appropriate safeguards are in place, including:

• Adequacy decisions by relevant authorities
• Standard contractual clauses approved by data protection authorities
• Binding corporate rules for intra-group transfers
• Certification schemes and codes of conduct

Data Retention

We retain your personal information only as long as necessary to fulfill the purposes outlined in this Privacy Policy and comply with legal obligations. Our retention periods are based on:

• Account Information: Retained while your account is active and for 7 years after closure for legal and tax purposes
• Learning Progress Data: Retained for the duration of your subscription and 3 years thereafter for continuity of service
• Communication Records: Retained for 5 years for quality assurance and dispute resolution purposes
• Financial Information: Retained as required by applicable financial regulations, typically 7-10 years
• Marketing Data: Retained until you withdraw consent or for 2 years of inactivity

When information is no longer needed, we securely delete or anonymize it using industry-standard data destruction methods.

Children's Privacy

Our services are designed for adults aged 50 and older. We do not knowingly collect personal information from individuals under 18 years of age. If we become aware that we have collected information from a minor, we will take immediate steps to delete such information from our systems.

Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will:

• Notify you by email (if you have provided an email address)
• Post a prominent notice on our website
• Update the "Last updated" date at the top of this policy
• Provide you with a reasonable opportunity to review the changes before they take effect

Your continued use of our services after the effective date of any changes constitutes acceptance of the updated Privacy Policy.

Contact Information

If you have questions about this Privacy Policy, wish to exercise your rights, or need to report a privacy concern, please contact us using the following methods:

We are committed to responding to your privacy inquiries promptly and will acknowledge receipt of your request within 48 hours and provide a substantive response within 30 days.