1. What’s in this Privacy Policy?

In this Privacy Policy, you’ll find:

• What information we collect about you
• How we might use that information
• What information we might share with others
• Your rights and choices about that information

2. What does this Privacy Policy cover?

We are Kuruma NFT Inc.,  In this document we’ll refer to ourselves as “Kuruma,” “we,” or “us.” 

In this Privacy Policy, we will describe how the Kuruma website, located at www.kurumanft.com, collects and processes your personal data. We’ll refer to this as the “Service.” 

3. What types of personal data do we collect?

Below you’ll find details about the types of personal data we collect from you and how we use it. We call this “processing” your data. 

We’ll also tell you the reason for processing that data, which is known as our “legal basis.” 

First, the personal data we collect from you:

• Contact Information – we will collect your name and email address when you contact us for technical or customer support, sign up for our newsletter or other communications, or otherwise provide us with this information for contact purposes. Our legal basis for collecting this information is with your explicit consent, under GDPR Art. 6 (1) (a).
• Wallet Information – we will collect your crypto wallet information that you input on the Service for the purposes of conducting transactions on the Service, including the purchase of NFTs, and we may also collect any public blockchain data related to those transactions. Our legal basis for collecting this information is to fulfill a contract with you, under GDPR Art. 6 (1) (a).
• Analytic Information – we will collect certain analytic information when you use the Service, including your IP address, usage information, basic device and operating system information, and other analytic information provided by our analytics partners (as described below). Our legal basis for collecting this information is for our legitimate interest, under GDPR Art. 6 (1) (f).
• Posts – if you post publicly on the Service, including our Service-operated Discord and other communications channels, we will collect and display these posts to other users on those channels. Our legal basis for collecting this information is to fulfill a contract with you, under GDPR Art. 6 (1) (a).

Next, the personal data that third parties share with us:

• Analytics – we use Google Analytics, who shares various anonymous analytic data and analysis with us for the purposes of improving the Service.

Finally, the personal data that we share with others:

• Your public posts – when you post publicly on the Service, including on the Service-operated Discord and other channels, your posts will be publicly shared with other users.
• Newsletters and other communications – when you sign up to receive marketing communications from us, we will share your Contact Information with our third-party mailing list providers.
• Marketplace Backend – we currently use CreatorMachine for primary mints, ThirdLife for KurumaCards™ and Holaplex to operate our NFT marketplace backend, which may receive your Wallet Information, certain Analytic Information, and other information necessary to process marketplace transactions and operate the Service.

We may also need to share your personal data in a few other situations:

• To comply with the law, a court order, or orders from government agencies
• To detect and combat fraud or security issues
• To protect the Service, our employees, and our business’s rights or safety

Other than that, we will not share your personal data with anyone else.

4. How long do we keep your personal data?

We only keep your personal data as long as it’s required to provide you with the Service. Sometimes a longer period might be required by law. 

After that, we will delete your personal data within a reasonable time.

Please note that we may retain some data if necessary to: 

• resolve disputes, 
• enforce our user agreements, 
• follow any technical and legal requirements related to the Service.

5. Cookies, Do Not Track signals, and sharing to Social Media

Certain parts of the Service may feature cookies and social media sharing.

Cookies: A cookie is a small amount of data that is sent to your browser from a web server and is stored on your computer’s hard drive. Cookies are not spyware or adware and can’t deliver viruses or run programs on your computer. Other similar methods include tracking pixels and web beacons.

Please see our Cookie Policy here for more information.

Google Analytics: We use Google Analytics, which gathers information about the Service’s users by means of cookies. The information gathered is used to create reports about Service usage. You can find out more about Google’s use of this information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google’s privacy policy at https://policies.google.com/privacy.

“Do Not Track” Signals: We do not comply with web browser-based and other “do not track” mechanisms.

Social Media Sharing: The Service may allow you to share certain information from the Service or your Account to various third-party social media sites and networks. When you do this, any information you share outside of the Service will be subject to that third party site or network’s privacy policy. We encourage you to review their privacy document before sharing any personal data.

6. Children’s privacy rights

We don’t knowingly collect any personal data from children under the age of 13. We also don’t knowingly allow them to create accounts, sign up for newsletters, make purchases, or use the Service. 

We may also limit our personal data processing for EU users between 13 and 16.

We take children’s privacy seriously and encourage parents to play an active role in their children’s online experience. If you have any concerns about your child’s personal data, please contact us at contact@kurumanft.com.

7. Transfers of your personal data

We are based in the United States. 

No matter where you live, by using the Service you consent to the processing and transfer of your personal data in and to the United States. This processing will be under our privacy policy and the privacy policies of third parties that we share personal data with. 

The laws of the United States governing data collection and use may not be as comprehensive or protective as the laws of your country. 

If you would like more information, please contact us (see “How to contact us” below).

8. EU residents’ rights

We are regulated under the General Data Protection Regulation (GDPR), which applies across the European Union (including in the United Kingdom). We are responsible as a controller of personal data for GDPR purposes.

Under the GDPR, EU residents have several important rights: 

• The right to access – You have the right to request copies of your personal data that we have on file. 
• The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.
• The right to erasure – You have the right to request that we erase your personal data, under certain conditions.
• The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.
• The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.
• The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
• Rights in relation to automated decision making and profiling – You have the right to request that we do not use your personal data in automated individual decision-making and profiling.

If you would like to exercise any of those rights, please email us at contact@kurumanft.com. We may ask for additional info to verify that you’re the owner of that data. 

Also, in some cases where the law requires it, we may not be able to help with the above requests. 

9. California residents’ rights

We are regulated under the California Consumer Privacy Act (CCPA), which applies to California residents. 

Under the CCPA, California residents have several important rights: 

Right to Know: You can ask us what personal data we hold about you and request a copy. This includes:

• The type and specific pieces of personal data we have collected
• The types of sources we collect the data from
• The purpose for collecting your personal data
• The third parties we share that data with

Right to Delete: You can request that we erase your personal data. There are some exceptions to this right, if we:

• Need to complete the transaction for which the personal data was collected or if there is an ongoing business relationship or contract with you 
• Detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity
• Need to identify and repair errors affecting Service functionality
• Exercise free speech or ensure another consumer can exercise (or other lawful right)
• Need to comply with the California Electronic Communications Privacy Act
• Engage in research in the public interest
• Enable solely internal uses that are in line with your expectations for using your personal data
• Need to comply with a legal obligation
• Otherwise use your personal data internally, in a way that’s compatible with the reason we collected it in the first place

Sale of your personal data: We don’t sell any of your personal data for any purposes. 

Other Rights: California residents also have the right to request information about our disclosure of personal data to third parties for direct marketing purposes during the calendar year before your request. This request is free and may be made only once a year. 

We also won’t discriminate against you for exercising any of the rights listed above.

If you would like to exercise any of those rights, please email us at contact@kurumanft.com. We may ask for additional info to verify that you’re the owner of that data. 

Also, in some cases where the law requires it, we may not be able to help with the above requests. 

10. Brazilian residents’ rights

We are regulated under the Lei Geral de Proteção de Dados (“LGPD”), which applies to Brazilian residents. 

Under the LGPD, Brazilian residents have several important rights: 

• Know when we use your personal data
• Access your personal data, correct any errors, or delete your personal data
• Anonymize, block, or delete data that we don’t need or are not processing in compliance with the LGPD
• Request we transfer your data to another provider
• Be informed about who we share your data with
• Be informed about your ability to deny consent and any consequences 
• To revoke your consent

These rights apply to any personal data collected or processed in Brazil, as well as any personal data processed for the purpose of providing goods or services in Brazil.

If you would like to exercise any of those rights, please email us at contact@kurumanft.com. We may ask for additional info to verify that you’re the owner of that data. 

11. How do we protect personal data?

We have taken steps and put security measures in place to prevent the accidental loss or misuse of personal data. 

For example, we limit access to those who have a genuine business need and protect all personal data using firewalls and other data security measures. Those processing your information will do so only in an authorized manner and under the terms of strict confidentiality agreements.

We also have procedures in place to deal with any suspected data security breach. We’ll notify you and any applicable regulator of a suspected data security breach when legally required.

12. Resolving Disputes

We hope that we can resolve any questions or concerns you raise about our use of your personal data. 

Please contact us at contact@kurumanft.com to let us know if you have questions or concerns. We will do our best to resolve the issue.

For EU residents, the GDPR also gives you the right to lodge a complaint with a supervisory authority. You may do this in the EEA state where you live, work, or where any alleged infringement occurred. 

13. How will we notify you of changes?

We last updated this Privacy Policy on September 14, 2022.

We may make further updates from time to time. When we do so, we will post a message on the Service about the change.

14. How to contact us

Please contact us if you have any questions about this Privacy Policy or your personal data.

You can contact us regarding any privacy concerns at contact@kurumanft.com or by physical mail at:

Kuruma NFT Inc.1730 East Holly AveSuite 757El Segundo, CA 90245