Japan privacy notice (APPI)

This page publishes the matters about retained personal data required by Art. 32 APPI. The full picture of what we collect is in the privacy policy.

• Parents: name, email, password hash or Sign in with Apple / Google sign-in identifier, language, time zone, sign-in and security logs (IP address, device). Collected at sign-up and sign-in.
• Children and family members: the name and birth year a parent enters (for the age band). Children have no email or password.
• Device: model, iOS and app version, device identifier, push token, earbud model and battery levels. Collected by the app.
• Measurements: volume, estimated or measured dB, weekly sound dose, Apple Health headphone and environmental audio levels (only with permission), posture state and durations, earbud connection and drop events.
• Location: where an earbud dropped or was left behind (only with permission); low-accuracy updates only if background monitoring is on.
• Goals, stars, streaks, rewards, cheers and hearing-game results.
• Subscription: plan, transaction ID, expiry (card details stay with Apple).
• Parental consent records: who consented, when and from which device.
• Website: name, email and message from the contact form; technical logs.

We use personal information only within these purposes (Art. 17 and 21 APPI):

• creating accounts, sign-in and pairing a parent with a child's phone;
• measuring headphone level, sound dose, posture and earbud events and showing them to the person and their linked parents;
• sending alerts, weekly reports (including PDF) and notifications;
• helping find an earbud that dropped or was left behind;
• providing goals, stars, rewards, the wardrobe, friends and the league;
• managing subscriptions (payment goes through the App Store);
• answering contact and support requests;
• preventing misuse, keeping the service secure, investigating and fixing faults;
• complying with the law;
• producing anonymous class averages for a school programme a parent chose to join (only with at least 10 reporting students).

We never use personal information for advertising, marketing profiles or sale.

Listening records, sound dose and posture state can relate to health. We treat them with the care the APPI requires for special care-required personal information and, under Art. 20(2), obtain them only with the prior consent of the person (for a child, the parent).

• Consent is asked on its own screen, separate from the terms, with a box that is not pre-ticked.
• Apple Health access is read-only and covers only headphone and environmental audio levels. We write nothing to Health.
• If you say no, only the measurement features stay off.
• You can withdraw consent at any time in the app or in iOS Settings.

Earbunny is not a medical device and does not diagnose or treat.

Only a parent can create a child's profile, and the parent gives consent before pairing; we keep a record of it. The Personal Information Protection Commission's guidelines generally require a legal representative's consent for children up to between 12 and 15. For children under 13, no pairing code can be created without consent. Children always see that monitoring is on and who can see their data. See the children's privacy notice.

We do not provide personal data to third parties without consent, except where the law allows it (Art. 27(1)). Only the person and the parents linked to them can see their data.

We entrust hosting, notifications, sign-in, App Store billing, email delivery and crash and log monitoring to service providers acting on our instructions. This is entrustment under Art. 27(5)(i), not provision to a third party. We supervise them by contract and list them in the subprocessor list.

Some of our service providers are abroad (Art. 28 APPI):

Our US providers are bound by contract to take measures equivalent to those a Japanese business must take (Art. 16 of the Enforcement Rules). We check periodically how they apply them and whether local law could affect them. On request we tell you without delay what these measures are and how we check them (Art. 28(3)).

Our own country: disclosed without delay on request

We protect personal data against leaks, loss and damage (Art. 23 APPI):

More on our security page.

Raw measurements are deleted after 30 days, minute summaries and events after 90 days and event location after 7 days. Daily summaries and reports are kept until the account is deleted. The full table is in the privacy policy.

For retained personal data, you can ask us for:

• notification of the purposes of use and disclosure (Art. 33), including as electronic data (JSON);
• correction, addition or deletion (Art. 34);
• suspension of use, erasure or stopping provision to third parties (Art. 35);
• disclosure of third-party provision records (Art. 33(5)) — we make no such provision.

Send complaints and questions to privacy [at] earbunny.app or the contact form. We are not a member of an accredited personal information protection organisation. If you are not satisfied with our answer, you can contact the Personal Information Protection Commission's consultation line.

We announce changes in the app and by email before they take effect, and ask for consent again where a new purpose needs it.