Privacy Policy

1. Introduction

This Privacy Policy explains how Kitsunebi Miyabi SRL ("the Company", "we", "us", or "our"), the operator of the Vici Sensei website and mentorship program, collects, uses, stores, and protects your personal data. We process personal data in accordance with Regulation (EU) 2016/679 (the "GDPR") and applicable Romanian data protection law.

By visiting our website or enrolling in our services, you acknowledge that you have read and understood this Policy.

2. Who Is Responsible For Your Data

The data controller responsible for your personal data is:

Kitsunebi Miyabi SRL
Registered office: Str. Penes Curcanul, nr. 8, bl. 151C, sc. A, et. P, ap. 1, Ploiesti, Prahova, 100511, Romania
Company registration number: J29/63/2023
C.I.F.: 47442947
Email: vici.sensei@gmail.com
Phone: +40 745 984 726

3. What Data We Collect

• Contact and enrollment data — your name, email address, phone number, and Discord or WhatsApp handle, collected when you message us or enroll in the mentorship program.
• Billing information — details necessary to process payment for your subscription. We do not store full card numbers ourselves; bank transfers are reconciled using the payment reference you provide.
• Communications — records of messages exchanged with us through Discord, WhatsApp, or email for enrollment and support purposes.
• Learning data — study progress, saved vocabulary and kanji lists, and spaced-repetition review history if you use the companion vocab app.
• Technical and usage data — browser type, device type, and an approximate country location (via IP address), used mainly to display pricing in your local currency.

4. How We Use Your Data

• To respond to your enquiries and process your enrollment in the mentorship program;
• To schedule, deliver, and follow up on live sessions;
• To manage billing for the 4-week subscription cycle;
• To provide and maintain access to the custom kanji and vocabulary app;
• To display pricing relevant to your location;
• To maintain accounting records required by law;
• To improve our website and services.

5. Legal Basis For Processing

We rely on the following legal bases under Article 6 GDPR:

• Performance of a contract — to enroll you in the program and deliver the services you have purchased;
• Legitimate interest — to respond to enquiries and improve our services;
• Legal obligation — to keep accounting and tax records as required by Romanian law;
• Consent — for any optional communications you have opted into.

6. Sharing Your Data With Third Parties

We do not sell your personal data. We may share limited data with the following categories of third parties, solely to operate our services:

• Communication platforms you choose to contact us through — Discord, WhatsApp (Meta), and Gmail (Google);
• Our banking provider, to process and reconcile payments;
• A geolocation lookup service used only to detect your approximate country for currency display;
• Accountants or auditors, where required to meet our legal obligations.

Some of these providers may process data outside the European Economic Area. Where this occurs, they do so under their own data protection safeguards, which we encourage you to review on their respective websites.

7. Cookies and Similar Technologies

Our website uses only the minimal technical functionality necessary for it to work correctly. If we introduce analytics or marketing cookies in the future, we will update this Policy and request your consent where required by law.

8. Data Retention

We retain your personal data for as long as necessary to provide the services you have enrolled in, plus any additional period required by Romanian accounting and tax legislation (generally up to 10 years for financial records). Data that is no longer needed is deleted or anonymized.

9. Your Rights Under GDPR

Subject to applicable law, you have the right to:

• Access the personal data we hold about you;
• Request correction of inaccurate data;
• Request deletion of your data;
• Request restriction of processing;
• Request portability of your data;
• Object to processing based on legitimate interest;
• Withdraw consent at any time, where processing is based on consent.

To exercise any of these rights, contact us at vici.sensei@gmail.com. You also have the right to lodge a complaint with the Romanian National Supervisory Authority for Personal Data Processing (ANSPDCP), www.dataprotection.ro.

10. Children's Privacy

Our services are not directed at children under the age of 16. If you are under 16, you may only use our services with the involvement and consent of a parent or legal guardian.

11. Security

We apply reasonable technical and organizational measures to protect your personal data against unauthorized access, loss, or misuse. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

12. Changes To This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. The "Last updated" date at the top of this page indicates when it was last revised. Continued use of our services after an update constitutes acceptance of the revised Policy.

13. Contact Us

If you have any questions about this Privacy Policy or how we handle your data, please contact us at vici.sensei@gmail.com or +40 745 984 726.