Privacy Policy

Article 1 (Purpose and Scope)

1. SEARED BONITO (hereinafter the "Studio") publishes the iOS and iPadOS application Golf Rhythm Coach (hereinafter the "App"). This Privacy Policy (hereinafter this "Policy") describes how the Studio handles personal information in connection with the App, in accordance with the Act on the Protection of Personal Information of Japan (Act No. 57 of 2003, as amended; hereinafter the "APPI") and other applicable laws and regulations.
2. This Policy applies to the App and to no other product of the Studio. The website at searedbonito.com is governed by a separate, studio-wide privacy policy, referenced in Article 16.
3. Where the General Data Protection Regulation (Regulation (EU) 2016/679; hereinafter the "GDPR") or the United Kingdom General Data Protection Regulation (hereinafter the "UK GDPR") applies, the provisions of Article 14 shall apply in addition to this Policy. Where the California Consumer Privacy Act (Cal. Civ. Code §1798.100 et seq., as amended; hereinafter the "CCPA") applies, the provisions of Article 15 shall apply in addition to this Policy.

Article 2 (Definitions)

For the purposes of this Policy, the following terms shall have the meanings set out below:

1. "Personal Information" means personal information as defined in Article 2, paragraph 1 of the APPI, and, where the GDPR or UK GDPR applies, personal data as defined in Article 4(1) thereof.
2. "User" means any person who uses the App.
3. "App Store Operator" means Apple Inc., which distributes the App and processes purchases made within it.
4. "Practice Settings" means the club, tempo, count sound, template and related options a User selects while using the App.

Article 3 (Identity of the Controller)

1. The entity responsible for the App and for the handling of Personal Information under this Policy is as follows:
   1. Trade name: SEARED BONITO
   2. Representative: Toshiyuki Maeda
   3. Location: 503, 5-8-4 Daizawa, Setagaya-ku, Tokyo 155-0032, Japan
   4. Contact for privacy matters: support@searedbonito.com
2. Where the GDPR or UK GDPR applies, the Studio acts as the controller within the meaning of Article 4(7) thereof in respect of any Personal Information described in this Policy.

Article 4 (No Collection of Personal Information)

1. The App does not collect Personal Information of any kind. In particular, the Studio does not collect, and the App does not transmit to the Studio or to any third party, a User's name, email address, precise or approximate location, contacts, health data, device identifiers, or any record of how the App is used.
2. The App does not require, and does not offer, the creation of an account.
3. The App does not incorporate advertising or analytics software of any kind. No usage data leaves a User's device.
4. The App does not use cookies or comparable tracking technologies, being a native application rather than a website.

Article 5 (Information Stored on Your Device)

1. The App stores the data described in the table below using the operating system's standard local storage. This data remains on the User's device at all times and is never transmitted to the Studio, to the App Store Operator, or to any other party.

2. This data is erased automatically when the App is deleted from the device. A User may also reset Practice Settings to their standard values from within the App at any time, free of charge.

Article 6 (Payments and In-App Purchases)

The App offers a single optional, non-consumable in-app purchase ("Pro"), processed entirely by the App Store Operator using StoreKit. Payment credentials, including card numbers, are entered outside the App, and the Studio neither receives nor stores them. The Studio receives only confirmation, from the App Store Operator, that the purchase has been made and remains valid, which the App uses to unlock the corresponding features. The Studio operates no server of its own and cannot identify who has made a purchase.

Article 7 (No Provision to Third Parties)

Because the App collects no Personal Information, the Studio has none to provide, sell, or disclose to any third party in connection with the App, and does not do so.

Article 8 (Entrustment)

The Studio entrusts the distribution of the App and the processing of its in-app purchase to the App Store Operator. The Studio does not entrust any handling of Personal Information to any other party in connection with the App, as none is collected.

Article 9 (Retention and Deletion)

The Studio retains no Personal Information in connection with the App, and accordingly no retention period applies. The data described in Article 5 is retained locally on the User's device until the User resets it or deletes the App, at which point it is erased.

Article 10 (Security)

The App is designed so that no Personal Information is created or handled by the Studio in the first place, which the Studio considers the most effective safeguard available. Data described in Article 5 is protected by the security features of the operating system on the User's device.

Article 11 (Rights of Users)

Because the Studio holds no Personal Information in connection with the App, there is no Retained Personal Data, within the meaning of Article 16, paragraph 4 of the APPI, in respect of which to exercise a right of disclosure, correction, or deletion under Articles 33 to 35 of the APPI. A User who nonetheless has a question about this Policy, or believes the App has behaved otherwise than as described here, may contact the address in Article 16 at any time, free of charge.

Article 12 (Children's Privacy)

The App is not directed at children and, as described in Article 4, collects no Personal Information from a User of any age.

Article 13 (Special Provisions for Residents of Japan)

A User resident in Japan may lodge a complaint with the Personal Information Protection Commission (ppc.go.jp), in addition to contacting the Studio under Article 16.

Article 14 (Special Provisions for Residents of the EEA and the United Kingdom)

1. Because the App collects no Personal Information, the Studio processes none on which the rights of access, rectification, erasure, restriction, objection, or data portability under Articles 15 to 21 of the GDPR or UK GDPR could operate.
2. A User nonetheless has the right to lodge a complaint with the supervisory authority of the User's habitual residence, place of work, or place of the alleged infringement, including the Commission nationale de l'informatique et des libertés in France (cnil.fr) and the Information Commissioner's Office in the United Kingdom (ico.org.uk).

Article 15 (Special Provisions for Residents of California)

Because the App collects no personal information within the meaning of the CCPA, the Studio has none in respect of which the rights to know, delete, or correct under the CCPA could be exercised. The Studio does not sell or share personal information within the meaning of the CCPA, and has not done so in the preceding twelve (12) months.

Article 16 (Contact)

Enquiries and complaints concerning the App or this Policy shall be addressed to:

For matters concerning searedbonito.com itself, rather than the App, see the studio-wide privacy policy.

Article 17 (Amendment of this Policy)

The Studio may amend this Policy, in particular before introducing a feature that would change the information described in Article 4 or 5. Where an amendment is made, the Studio shall update the date of last amendment stated above and, where the amendment materially affects the handling of Personal Information, shall give notice within the App or on this page prior to the amendment taking effect.

Established 17 August 2026