Kaeru Privacy Policy - Previous versions

This is an old version of our privacy policy, from 23 November 2020. Click here to read the current version.

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].

For detailed information about the cookies we use, please see our Cookie Policy.

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:

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:

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:

Who we share your information with

We may share your information 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.

In the event that our services are sold or transferred to another person or organisation (a ‘third party’), your data will be transferred to that third party as part of the transfer and will fall under their privacy policy.

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:

Children’s privacy

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].

Your rights

You have a right to:

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:

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