SENRI LIMITED is headquartered in Tokyo, Japan and its subsidiaries are part of a global group of affiliated companies with offices and operations around the world. When we say “SENRI LIMITED” (or similar things like “we” or “us”), we’re referring to the SENRI LIMITED entity or, where applicable, entities that control and are responsible for your info (see Contact Us to see who that is).
1.WHAT ARE THE SENRI LIMITED SERVICES?
Note that your use of the SENRI LIMITED Services may also be subject to additional terms and conditions.
2.WHAT INFORMATION DO WE COLLECT?
The types of information we collect depend on how you interact with us. Generally speaking, we collect information in three main ways: A) when you provide it to us, B) automatically when you use the SENRI LIMITED Services, and C) from service providers and third parties.
A.Information You Provide
You can provide us with different kinds of information depending on how you interact with the SENRI LIMITED Services. Sometimes we’ll ask you to provide specific pieces of information, such as when we require it to provide parts of the SENRI LIMITED Services to you. If we ask you to provide us with information in these cases and you choose not to, you may not be able to access the relevant SENRI LIMITED Services and/or some features may not operate as intended.
For instance, in order to use and access the SENRI LIMITED Application and to use our software, you’ll need an SENRI LIMITED account. To create one, you’ll need to provide us with registration information which contains your full names, password and user name/account name to complete the registration. Additional information you may be asked to give include your email address, your telephone number and profile photo.
We also collect the information you voluntarily provide to sign up for email alerts, use our developer tools, complete surveys, or contact us through Support requests or customer service. Furthermore in order to use our application we need to access GPS co-ordinates on your devices to enable the proper function of the application. The application may access your call logs to verify that commercial obligations have been met. The application may access to your Media Files to ensure photos taken can be uploaded to complete reports. The Application may also access your contact list and SMS. We collect whatever information you choose to provide to us in those or other similar cases.
B. Information We Collect Automatically
We collect some information automatically when you visit, access, or use the SENRI LIMITED Services. This includes information about your device or application usage, GPS Co-ordinates, entitlements, and other activity in the SENRI LIMITED Services, typically associated with your account (if you are logged into your SENRI LIMITED account) or with an identifier we have assigned to your device or profile. While the specific types of information that we automatically collect may vary, they generally include:
Usage information and statistics about how you interact with the SENRI LIMITED Services, including the application you used or the places your devices have visited, how long you have stayed in a particular location and when, call records to contacts saved specifically on the SENRI Application,, progression and results of reports, saved preferences, crash reports, the URLs of our websites that you have visited, tracking movement, contacts saved specifically to the SENRI Application;
Technical information about your application, device, hardware, or software you use to access our services, such as IP address, device identifiers, plugins, or other transactional or identifier information for your device (such as device make and model, information about device operating systems and browsers, or other device or system-related specifications); and current status
The general location of your device, which we typically derive from your device’s IP address and device’s GPS Location.
The SENRI LIMITED Services use technologies such as cookies, log files, and web beacons to automatically collect the types of information listed above. Some of these technologies may create small files or record-keeping tools that may be stored on your device. They help us, our service providers, and third parties recognize your device and provide information about how you use and interact with the SENRI LIMITED Services. For example, they support our ability to authenticate users, remember preferences, manage advertising, personalize experiences, and conduct data analytics.
Please note that if certain features on the SENRI LIMITED Services are provided by third parties, those third parties may also use automated means of data collection and may record information about your use of the SENRI LIMITED Services or others’ websites over time. These features are subject to those third parties’ privacy notices and policies.
C. Information We Collect from Other Sources
In some cases, we may also receive information about you from service providers and third parties in connection with your use of the SENRI LIMITED Services or your interactions with us on other platforms.
For example, some other developers allow you to use your SENRI LIMITED account to log in to their service. And if you choose to link your SENRI LIMITED account with your account on a third-party website or service, or if you interact with an ad for one of the SENRI LIMITED Services on an external website or service, the company that operates that website or service may share some information with SENRI LIMITED in accordance with their own privacy practices. Your privacy settings on the other company’s website or service typically control the specific types of information they can share with SENRI LIMITED, so please be sure to review and update them regularly. Common examples for linked accounts might include your third-party account display name and user ID, as well as associated device information, name, and email address.
You can also access some SENRI LIMITED Services on or through services operated by third parties. If you do, they may provide us with information to facilitate your access to and use of the SENRI LIMITED Services. This typically includes information like your display name, user ID, and device and region information. When you do, the company operating that platform or service may share some information with us, which helps us do things like facilitate and track your progression.
D. Fraud Prevention & Anti-Cheat
Providing users with a fair, balanced, and competitive experience on the SENRI LIMITED Services is extremely important to us. We strictly enforce prohibitions against cheating, hacking, and any other unauthorized or fraudulent activity on the SENRI LIMITED Services. We use a variety of anti-cheat and fraud prevention technologies to help us identify and prevent malicious activity. These services may collect and analyse data about your application and the software on your application to detect cheating and may be provided by SENRI LIMITED.
3.HOW DO WE USE INFORMATION?
As a general matter, we use the information we collect (either individually or in combination with other information collected as described in this policy) to help us provide, improve, customize, analyse, and promote the SENRI LIMITED Services.
This includes using it for purposes such as:
Developing, delivering, and improving the SENRI LIMITED Services and other offerings, some of which may be offered in partnership with other parties;
Personalizing your experience, including by presenting content or features better tailored to you or your interests, or our inferences about your interests (for instance, if you frequently play s in a certain genre, we may infer that you’d be interested in that genre and suggest similar s to you);
Promoting the SENRI LIMITED Services, including managing, customizing, and measuring the effectiveness of our advertisements, promotional offers, surveys, and events;
Managing alpha, beta, or early access tests (and collecting feedback);
Conducting data analytics (like analysing how the SENRI LIMITED Services are used so we can better understand, improve, and personalize them);
Complying with our legal or contractual obligations and enforcing our terms; and
Securing the SENRI LIMITED Services, such as by detecting fraud and otherwise protecting SENRI LIMITED and other users from illegal or harmful actions.
4.HOW DO WE SHARE INFORMATION?
We may share some of the information we collect to help operate and improve the SENRI LIMITED Services. Depending on how you interact with us, common examples might include sharing:
With partners (for example, to facilitate services when you access the SENRI LIMITED);
With other developers (such as to enable features for the software and application you use);
With other users (like if similar contacts have been saved on the SENRI Application);
Publicly (for example, if photos taken of products and locations for marketing purposes to others);
With service providers that operate on our behalf to help support the SENRI LIMITED Services in accordance with our instructions (for example, cloud storage providers, payment processors, or marketing and advertising partners);
When we believe we must in order to comply with the law or to protect you, SENRI LIMITED, or others (for example, in response to court order , as part of an investigation of fraud or other illegal activity, or violation of our terms or policies, or if necessary to protect others from death or serious harm to body or property);
With other SENRI LIMITED entities (including to help provide support for the SENRI LIMITED Services internationally);
In connection with certain types of corporate transactions (like in the event of a restructuring or the sale of all or a significant part of our business); and
With your permission (for example, if you link external accounts with your SENRI LIMITED account, or use your SENRI LIMITED account to sign in to third-party websites and services or participate in cross-promotional events).
We may also share information that does not identify you with third parties, including aggregate or de-identified information.
Third parties you interact with through SENRI LIMITED Services may have different privacy practices than SENRI LIMITED, so we encourage you to review their privacy policies before sharing your information with them.
SENRI LIMITED does not share information about data subjects or its partners without express consent from them and/or express legal authority.
The SENRI LIMITED Services are intended to be used for adults and are not directed to children (usually considered to be under 18,). SENRI LIMITED does not intentionally collect personal information from children without seeking any required parental approval in accordance with applicable legal and regulatory obligations.
6.YOUR CHOICES AND CONTROLS
We seek to provide you with meaningful choices about the personal information we collect. The specific choices available to you often vary depending on the exact nature of our relationship with you, such as the SENRI LIMITED Services you use. Common examples include:
You can request that we provide access to, or that we correct or delete, personal information we’ve collected from you. Please submit requests to access, update, or delete personal information associated with your SENRI LIMITED account by reaching out to us as described in “Contact Us” below. Note that we may ask you for additional information to help us verify who you are before completing your request. SENRI LIMITED
You can change your email marketing preferences at any time, such as by using the opt-out mechanism provided in our marketing emails, updating your SENRI LIMITED account settings, or contacting us with your request (see “Contact Us” below).
You can change your privacy settings on other parties’ websites or platforms to limit the information they may share with us.
You can change your browser or mobile device settings to block, manage, delete, or limit tracking technologies like cookies and GPS. In some cases, blocking or disabling cookies and GPS may cause the SENRI LIMITED Services not to work as intended and some features may not be available.
If you’re under the age of 18 and your details have been captured by SENRI LIMITED, you can ask that we remove or anonymise certain content that has been provided on the SENRI LIMITED Services. Please direct requests to help delete or edit content on the SENRI LIMITED Services to SENRI LIMITED as described in “Contact Us” below.
7.OUR GLOBAL OPERATIONS
SENRI LIMITED is based in the Japan, but we operate globally to help provide users all around the world with a better experience on services offered by SENRI LIMITED. We have subsidiaries, offices, service providers, and partners worldwide to support these operations in a number of different ways. This means that SENRI LIMITED may process the information we collect in connection with your use of the SENRI LIMITED in places outside the region where you reside.
A. Data Transfers
When you use the SENRI LIMITED Services, your information may be transferred to or stored in Germany or other countries where we or our service providers operate. The data protection laws and rules in these countries may be different than those where you live. We rely on various legal mechanisms to help lawfully support transfers of information outside the country of collection where appropriate. If permissible under local law, you’re authorizing SENRI LIMITED to process your information in any of the locations where we operate (including the Federal Republic of Germany) by using SENRI LIMITED Services.
To learn more about the SENRI LIMITED entity responsible for operating the SENRI LIMITED Services you use, see “Contact Us” below.
B. Information Collected
Some of the information we might obtain and collect include:
Identifiers (such as email addresses);
Demographic information (like ages);
Commercial information (including entitlements or purchase history);
Call Logs activity (for example, calls made to clients from mobile devices with the SENRI LIMITED Application Installed);
Audio, electronic, visual, or similar information (like voice chat);
Geolocation information (such as may be derived from your IP address or mobile devices);
Inferences drawn from any of these categories (for example, about the places that might need more.
For details about the precise data points we collect and the categories of sources where we got that information, please see “What Information Do We Collect?” above. We collect personal information for the business and commercial purposes described in “How Do We Use Information?” above.
SENRI LIMITED does not sell the personal information we collect. We do, however, disclose personal information as described in this policy (see “How Do We Share Information?” above). In the past 12 months, we have disclosed personal information to the following categories of recipients:
Business partners (for example, if you request that we share your email address with our third party systems including and not limited to Google, Safaricom, Microsoft, Sage, Africa’s Talking);
Other SENRI LIMITED entities (like to subsidiaries that may help support certain SENRI LIMITED Services);
Service providers (as described in “How Do We Share Information?” above);
Operating systems and platforms; and
Government entities or other third parties in response to a legal request.
C. DATA SUBJECTS
If you’re located in Kenya you have certain rights regarding how your personal data is processed.
Data Subject Rights
You may have the right to access, correct, or delete personal data we have collected about you through the SENRI LIMITED Services. You may also have the right to a portable copy of the personal data you have provided, and to object to or restrict processing of your personal data, such as for direct marketing. Where you have provided your consent to our data processing, you have the right to withdraw consent.
You also have the right to make a complaint against us. We would, however, appreciate the chance to address your concerns before you contact a data protection regulator, and ask that you direct your complaint to us first.
SENRI LIMITED only collects data when an end user is logged on to a device.
Please see the “Contact Us” section below to learn more about reaching out to SENRI LIMITED with any relevant concerns you may have.
Basis for Processing
The legal bases we rely on to process your personal data depend on the SENRI LIMITED Services you use and how you interact with them. They primarily include:
Contractual Necessity: we process personal data to perform the SENRI LIMITED Services you requested under our Terms of Service or other similar contractual agreements with you. For example, we process personal data to set up and maintain your account; process your purchases; authenticate users; provide user-experience features (like saving your preferences); monitor and analyse the SENRI LIMITED Services; detect and prevent fraud, cheating, or other similar misuse; facilitate features like cross-progression that allow you to use the platform on both the website and application while providing feedback and tracking your progress to the licensee, which may require us to share your information with third-party partners; and contact the licensee about your account, transactions, or other updates. The end user might be tracked as a result of this. We also rely on performance of a contract to manage our relationship with you, which includes responding to your support requests or general inquiries, and notifying you about changes to our applicable terms or policies.
Legitimate Interests: we process personal data as needed for SENRI LIMITED’s business purposes, as balanced against the potential impact on your privacy rights. This includes many common purposes that you’d reasonably expect, such as to: communicate with you, respond to your requests, or provide you with updates and information; better understand our users and their preferences; personalize your experience, save your preferences, authenticate our users, and provide similar user experience features; develop, deliver, and improve the SENRI LIMITED Services and other offerings (some of which may be offered in partnership with other parties); manage and customize advertisements or promotional offers; secure and protect the SENRI LIMITED Services; prevent fraud and illegal activity; and support internal purposes such as auditing and data analysis.
Legal Obligations: we process personal data when necessary to comply with legal obligations, such as responding to legitimate requests from law enforcement authorities or other government officials in accordance with relevant legal processes.
Consent: we process personal data when you provide us with your consent to do so. You aren’t required to provide consent if you do not want your personal data to be processed for the requested purposes, and you may withdraw your consent at any time.
Because the specific personal data we process and our reasons for doing so often vary depending on how you use the SENRI LIMITED Services, how long we retain it can also vary. We generally store personal data for as long as we reasonably need it for the purposes described in this policy (like complying with our legal obligations, contractual obligations, managing internal records, enforcing our terms, and resolving disputes), unless a long retention period is required or permitted by law.
The main criteria we consider in determining specific retention periods often include minimum requirements under applicable law, relevant industry standards, the types of data in question (such as its level of sensitivity), relevance to potential litigation or similar proceedings (like defending ourselves against legal claims), and whether the data is required to prevent fraud or similar abuse of the SENRI LIMITED Services (including to enforce prohibitions against cheating and other unauthorized behaviour). For example, if you use a SENRI LIMITED account, we will generally store the personal data associated with the SENRI LIMITED account for as long as needed to maintain the account, provide the SENRI LIMITED Services requested, enforce any terms that apply and govern the use of the SENRI LIMITED Services, and maintain appropriate records to reflect how we deliver the SENRI LIMITED Services.
To learn more about requesting that SENRI LIMITED delete your personal data, please see “Your Choices and Controls” and “Data Subject Rights” above.
THIRD PARTY WEBSITES AND SERVICES
The Companies listed below provide SENRI LIMITED with various services that enable the Software and Application to work as intended.
Alphabet Inc and its subsidiaries
Safaricom PLC (For Users residing in Kenya and using M-Pesa)
Microsoft Corporation (For users and companies that have integrated SENRI and Microsoft Products)
The Sage Group PLC (For users and companies that have integrated SENRI and SAGE Products)
Africa’s Talking Limited
Twilio Inc and Its subsidiary SendGrid
Amazon Web Services Inc
By using the application we believe that the respective privacy policies of those third parties have been accepted. SENRI LIMITED is not liable for any breach of Data Protection Laws and Regulations that might be as a result of the third-party websites and services not been compliant with the Law.
We maintain appropriate administrative, technical, and physical safeguards to protect your personal information from accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use and other unlawful forms of processing. In some cases, your information is accessible when you log into a feature we offer, and in those cases you need to keep your user credentials and password confidential and secure so that your information is protected.
We’ll update this policy from time to time to reflect changes in our practices or relevant laws. When we do, we’ll change the date noted at the top of the policy. In some cases we may also notify you of the relevant changes by email or within the SENRI LIMITED Services. Please review this policy regularly to make sure that you understand your relationship with SENRI LIMITED and the ways we may collect, use, and share information in connection with the SENRI LIMITED Services.
If you have questions or concerns about the SENRI LIMITED Services (such as application-related issues, trouble accessing your SENRI LIMITED account, bugs or other technical problems, payment matters, or content and entitlement issues), please contact our Support teams. You can learn more about submitting support requests for products and services from:
Effective July 10th, 2022