Last updated on 23 November 2020
Kaeru Team (also referred to in this document as “we”, “our”, “us”) isn’t currently an incorporated organisation. As such, ‘Kaeru Team’ refers to the current development team, led as of the time of writing by Ms Lauren Kelly (a British citizen), considered collectively.
For the purposes of data protection law (e.g., the GDPR in the European Economic Area, and the Data Protection Act 2018 in the United Kingdom), Ms Kelly acts as the data controller. We’re registered with the ICO in the UK - our registration number is ZA813282.
Throughout this document, where we refer to our ‘services’ in general, this should be read to include the services which we provide (including, but not limited to, for example, Kaeru Gallery on the 3DS, Kaerutomo, the Kaeru Accounts system, and Kaeru Duel) as well as any associated websites (such as the Kaeru Team website and the web version of Kaeru Gallery).
We’re committed to protecting and respecting your privacy; if you have any questions about how we handle your personal information please send an email to [email protected].
Information we hold about you
We aim to collect the minimum amount of information necessary to provide high quality services. The exact data we hold varies depending on which of our services you use, but includes:
- Information you submit through our websites or services, for example:
- When you sign up for a Kaeru Account, we collect your email address, birthday, and your chosen display name.
- Any content you post to our Services (including our websites) such as Kaeru Gallery (e.g., Flipnotes, comments, any profile info you choose to enter) and Kaerutomo (e.g., answers to questions or messages you send).
- The IP address you use to access our services.
- Statistics and analytical information about how you use our services.
- Information from any social networks or other accounts that you connect to our services, where needed to provide our service, or where you ask us to display this on a profile page for you.
- Cookie information.
- In some cases, we also collect unique IDs assigned to the device that you use to access our services, for example:
- Kaeru Gallery stores the ‘Flipnote Studio ID’ from your Flipnote Studio 3D save data (which is used to attribute your Flipnotes back to you), and the MAC address from your console (which is used as part of our account login and security processes).
How we use your information
We use your information to provide our services to you and our other users. In particular, we use it to:
- Enable you to use our services.
- Help us manage your account, and to fix problems you’re having.
- Detect and fix bugs in our services.
- Display content you choose to share to other users.
- Analyse and improve the services we give you and other users.
We may also use your information to exercise what’s known as our legitimate interests. This is when we use data for a reason which is in your and/or our interest, and which doesn’t involve overriding your privacy rights.
Finally, with your permission, in future we may use information you provide to:
- Market and communicate our services, where we think these will be of interest to you, by email.
Who we share your information with
We may share your information with:
- Anyone who works on our behalf, when they need it to do their job.
- Other users of our services, where this use is a key part of our service and/or when you give permission for this to happen.
- For example, we may show Flipnotes you upload to Kaeru Gallery to other Kaeru Gallery users and on the Kaeru Gallery website, or display profile information that you provide on your profile page.
- Any organisation which supports any of our services you use, when they need it to offer those services, for example:
- Analytics and cyber security service providers.
- Anyone who you give us explicit permission to share it with.
We’ll also share your information where this is necessary to comply with the law, including reasonable requests from the authorities; or to protect the rights, property, or safety of us, our users, or others.
How long we keep your information
Generally, we will hold your data for as long as you’re using our services. However, we may store some of your data for longer if we need to in order to exercise our legitimate interests, as explained above, such as protecting our services and users from abuse, spam and security threats, and/or if the law says we have to.
How we keep your information secure
We are committed to ensuring that your information stays secure. In order to prevent anyone from gaining unauthorised access, we’ve put in place suitable procedures and policies to keep your data safe.
In particular, when creating a Kaeru Account (and whenever you might reset the password for your existing Kaeru Account), we will always ensure that any password you enter is securely hashed, salted, and stored in accordance with industry-standard security guidelines and best practices. This means that even if someone were able to bypass our robust security measures to steal information from our databases, it would be virtually impossible for them to work out your original password from the data that we store.
Where we store your data
We use various external service providers to help provide our own services.
The majority of our services are hosted by DigitalOcean, LLC, on servers located in the United Kingdom. We also use content delivery network (CDN) services provided by Cloudflare, Inc., to keep everything running quickly and smoothly.
We might transfer and store the data we collect from you somewhere outside the European Economic Area (‘EEA’), and people who work with us or our suppliers outside the EEA might also process your data, but this will only happen if:
- We’ve agreed standard data protection clauses with the company; and/or,
- The European Commission says that the country in question offers adequate data protection.
We don’t knowingly collect or ask for any information from anyone under the age of 13 without the consent of their parent or guardian, nor do we knowingly allow them to register, as our services and content aren’t aimed at children under the age of 13.
If we learn that we have collected data from someone under the age of 13 without the consent of their parent or legal guardian, we’ll delete that information as soon as possible. If you believe we might have received any data from or about a child under 13, please contact us by emailing [email protected].
You have a right to:
- Access the personal data we hold about you, or to get a copy of it.
- Ask us to correct inaccurate data.
- Ask us to delete, ‘block’ or suppress your data, though for legal reasons we might not always be able to do this completely.
- Object to us using your data for direct marketing, and in certain circumstances for our legitimate interests, for research, and for statistical reasons.
- Withdraw any consent you’ve previously given us to use your data.
If you’d like to exercise (make use of) any of these rights, please contact us by emailing [email protected].
How to complain
If you have a complaint, or you otherwise have any concerns or queries about our use of your personal information, please contact us by emailing [email protected] and we’ll do our best to help.
If you’re still unhappy with how we have handled your data, you can also complain to a supervisory authority.
As Kaeru Team is based in the UK, you can make a complaint to the ICO:
- ICO website: https://www.ico.org.uk
- Helpline number: 0303 123 1113
(International format: +44 303 123 1113)
- The ICO’s address:
Information Commissioner’s Office
Alternatively, you have the right to raise a complaint with the relevant authorities where you live; if you live in the EU, you can find a list of supervisory authorities here: https://ec.europa.eu/digital-single-market/en/news/list-personal-data-protection-competent-authorities