Privacy Policy

Article 1 (Purpose and Scope)

1. SEARED BONITO (hereinafter the "Studio") publishes the iOS and iPadOS application Golf Swing Partner (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 18.
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 16 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 17 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. "Camera Video" means the images captured through a device's camera while the App is in use.
5. "Two-Device Mode" means the feature of the App in which one device films (the "Camera") and another device plays the video back with a delay (the "Monitor").
6. "Recording" means Camera Video that the User chooses to save by using the App's record button.

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, Camera Video, Recordings, 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, and the Studio operates no server for the App. 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.
5. Accordingly, the App's privacy information on the App Store states "Data Not Collected".

Article 5 (Camera Video)

1. Camera Video is processed on the User's device. To play it back with a delay, the App keeps it only temporarily in the device's memory.
2. When Swing Replay is on, the App detects swings on the device and keeps short clips of the User's three most recent swings, taken from the Camera Video, as temporary files in the App's own storage on the device, so that they can be replayed. When a new clip is kept, the oldest one beyond three is deleted, and any clips left over are deleted at the latest the next time the App is opened. These clips are not sent off the device, and the Studio has no access to them.
3. Camera Video is saved only when the User makes a Recording or saves a swing from Swing Replay, and only to the Photos library on the User's own device. For this purpose, the App asks only for permission to add items to the Photos library (add-only access); it does not read the photos or videos in that library.
4. While a Recording is being made, its video is written to a temporary area of the App’s own storage on the device, and is moved from there into the Photos library when it is saved; the App keeps no copy. If the App closes during a Recording, the video recorded up to that point is, where it can be recovered and add-only access to the Photos library has already been granted, saved to the Photos library the next time the App is opened; otherwise it is deleted. In either case, it is not sent off the device.
5. Recordings contain video only. The App does not use the device's microphone and records no sound.
6. Once saved, a Recording is kept and managed in the User's Photos library under the User's control, including any syncing the User has turned on for that library. The Studio has no access to Recordings.

Article 6 (Two-Device Mode)

1. In Two-Device Mode, Camera Video is sent directly from the Camera to the Monitor over the local network between the User's two devices, encrypted with a key derived from the 4-digit pairing code. It is not sent over the internet, and it is not sent to the Studio or to any third party.
2. The App uses the Local Network permission only to find and connect the User's two devices for this purpose.
3. So that the Monitor can find it, the Camera announces to nearby devices a name made up of the device type and a random code (for example, "iPhone FC43"). The name the User has given the device is not used.
4. Besides Camera Video, the two devices exchange only what the feature needs in order to work: the Camera's settings and zoom as changed from the Monitor, the state of the connection, and whether either device has purchased Pro (so that the link can be used without a time limit).

Article 7 (Information Stored on Your Device)

1. The App stores the data described in the table below on the User's device. This data is never transmitted to the Studio or to any third party.

2. App settings are erased when the App is deleted from the device. Pairing memory is kept in the device's Keychain, which the operating system may retain after the App is deleted and may carry over to a new device through an encrypted backup made by the User. Pairing memory contains no Personal Information.
3. Whether Pro has been purchased is provided to the App by the App Store Operator through StoreKit (Article 8); the App keeps no separate record of it.

Article 8 (Payments and In-App Purchases)

The App offers one optional in-app purchase, "Pro", processed entirely by the App Store Operator using StoreKit: from version 2.0 as an auto-renewable annual subscription, and in version 1.0 as a one-time purchase, which remains valid for those who bought it. Payment credentials, including card numbers, are entered outside the App, and the Studio neither receives nor stores them. The Studio receives no personal information or payment information about purchasers. The App learns from StoreKit only whether Pro is active and, for the subscription, the date it renews or ends, whether it renews automatically and whether the free trial is available; it uses this on the device only, to unlock the corresponding features and to show the state of Pro in the App. The Studio operates no server of its own and cannot identify who has made a purchase.

Article 9 (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 10 (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 11 (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 7 is kept on the User's device as set out in paragraph 2 of that Article. Recordings remain in the User's Photos library until the User deletes them there.

Article 12 (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. In Two-Device Mode, Camera Video is encrypted in transit as described in Article 6. Data described in Article 7 is protected by the security features of the operating system on the User's device.

Article 13 (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 18 at any time, free of charge.

Article 14 (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 15 (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 18.

Article 16 (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 17 (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 18 (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 19 (Amendment of this Policy)

The Studio may amend this Policy, in particular before introducing a feature that would change the information described in Articles 4 to 7. 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 24 September 2026