--- title: "Privacy Policy" date: 2026-05-07 author: "流庵殿 認定教師" categories: - name: "Legal Framework" url: "https://shibari-dojo.online/legal-en.md" --- # Privacy Policy **Version 2.1 · Effective Date: May 1, 2026 · Operator: Web3Hispano LLC, New Mexico, USA** (hereinafter, "SHIBARI-DOJO"). --- > **Notice** > > By accessing and using the Site, you accept the terms of this Privacy Policy. If you do not accept this Policy, you must leave the Site immediately. --- 1. **Data Controller** The data controller for personal data collected through the Site is: **Web3Hispano LLC** 500 4th St NW, Suite 102, PMB 1612 Albuquerque, NM 87102 — United States of America Contact: contact form available on the Site Web3Hispano LLC is an entity organized and domiciled in the United States of America. The processing of personal data described in this Policy is governed by the laws of the State of New Mexico and applicable federal laws of the United States of America. 1. **Principles Governing Data Processing** SHIBARI-DOJO’s privacy policy is not merely a legal requirement: it is a principled decision consistent with the nature of the services it provides. The Site deals with personal and sensitive matters —shibari, sexology, applied psychology SHIBARI-DOJO applies the following principles to the processing of all personal information: - **Minimization:** only data strictly necessary to provide the service is collected. - **Purpose limitation:** data is used exclusively for the purposes for which it was collected. - **No commercialization:** user data is not sold, rented, or transferred for third-party advertising or commercial purposes. - **Privacy by design:** the Site is designed to operate with the least possible amount of personal data. No real name is required. No tracking cookies or behavioral analysis tools are used. 1. **Information Collected and Legal Basis for Processing** 3.1 Data collected directly from the user **(a) During registration and account creation:** email address, username or alias freely chosen by the user, and password in encrypted form. No real name is required. **(b) When contracting services:** data that the user voluntarily provides in the registration or subscription forms. If the user requests tax documentation, the corresponding tax data will be collected solely at the user’s request. **(c) During use of the Site:** inquiries sent through the contact form and communications arising from the contractual relationship. 3.2 Data collected automatically While browsing the Site, technical data necessary for its operation is automatically collected, including IP address, browser type, operating system, pages visited, and session duration. This collection is carried out exclusively using necessary technical cookies, as detailed in Section 7. 3.3 Payment data Banking or payment method data provided in connection with contracting services is managed exclusively by SHIBARI-DOJO’s administrative area for legal, tax, and accounting compliance purposes, in accordance with obligations applicable to the Operator in the United States of America. Such data is processed separately and independently from the Site’s platform and is not integrated into the user account management systems. Its processing is restricted to administrative personnel with specific authority, and its retention complies with the periods established by applicable tax law, as set forth in Section 6 of this Policy. SHIBARI-DOJO does not use this data for any purpose other than strictly legal, tax, or administrative purposes arising from the contractual relationship. 3.4 Legal basis for processing | Processing | Legal basis | | --- | --- | | User account management | Performance of the use contract | | Provision of contracted services | Performance of the services contract | | Service-related communications | Performance of the contract and legitimate interest | | Site security and fraud prevention | Legitimate interest of the controller | | Compliance with legal obligations | Applicable legal obligation | | Own commercial communications (if applicable) | User’s express consent | 1. **Use of Information** Personal data collected is used exclusively for the following purposes: (a) To create, manage, and maintain the user’s account on the Site. (b) To provide the services contracted by the user, including access to educational content and coordination of sessions. (c) To communicate with the user regarding their account, subscriptions, or inquiries. (d) To ensure the security of the Site and user accounts, including detecting and preventing unauthorized or fraudulent access. (e) To comply with legal obligations applicable to the Operator in the United States of America. (f) To improve the technical operation of the Site based on aggregated and anonymized data. SHIBARI-DOJO will not use the user’s personal data for third-party marketing purposes, nor will it transfer such data for advertising purposes. 1. **Disclosure of Information to Third Parties** SHIBARI-DOJO does not sell, rent, or trade its users’ personal data. Data may be shared with third parties only in the following circumstances: **(a) Service providers:** SHIBARI-DOJO may share data with external providers that perform services necessary for the operation of the Site, such as cloud hosting services, payment processors, and communication tools. Such providers act as data processors and are contractually obligated to process data solely in accordance with SHIBARI-DOJO’s instructions and to maintain adequate security measures. **(b) Legal obligations:** SHIBARI-DOJO may disclose personal data when required by a court order, request from a competent authority, government regulation, or applicable legal process in the United States of America, or when necessary to protect the rights, property, or safety of the Operator, its users, or third parties. **(c) Corporate transfer:** In the event of a merger, acquisition, reorganization, or sale of assets of Web3Hispano LLC, user data may be transferred as part of such transaction. In that case, the acquirer will be bound by the terms of this Policy, or the user will be notified sufficiently in advance to exercise their rights. 1. **Data Retention** Personal data will be retained for the following periods: | Category of data | Retention period | | --- | --- | | Active user account data | For the duration of the account | | Inactive account data | Up to 6 months after deactivation due to inactivity, unless prior deletion is requested | | Contracting and billing data | 7 years from the date of the transaction, due to applicable tax obligations in the U.S. | | Support communications and inquiries | 2 years from the last communication | | Technical browsing data (logs) | 90 days from generation | After the indicated periods, the data will be deleted or irreversibly anonymized, unless retention is necessary for compliance with legal obligations or the defense of claims. 1. **User Rights** 7.1 General rights applicable to all users Regardless of their jurisdiction of residence, any user may exercise the following rights with respect to their personal data: **(a) Access:** obtain confirmation as to whether SHIBARI-DOJO processes the user’s personal data and, if so, access such data. **(b) Rectification:** request correction of inaccurate or incomplete data. **(c) Deletion:** request the erasure of their personal data when it is no longer necessary for the purposes for which it was collected, without prejudice to legally required retention obligations. **(d) Objection to commercial communications:** object at any time to the use of their data for sending own commercial communications. **(e) Portability:** receive the data they have provided in a structured, commonly used format, when processing is based on consent or on the performance of a contract. To exercise any of these rights, the user must contact SHIBARI-DOJO through the **contact form available on the Site**. SHIBARI-DOJO will respond within a maximum period of **30 business days** from receipt of the request. 7.2 Users residing in California (CCPA/CPRA) If you are a resident of the State of California, you additionally have the following rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA): (a) The right to know what categories of personal data have been collected about you and for what purpose. (b) The right to know whether your personal data has been sold or disclosed to third parties and, if so, to which categories of third parties. In this regard, SHIBARI-DOJO expressly states that it **does not sell personal data** within the meaning of the CCPA/CPRA. (c) The right to request deletion of your personal data, subject to exceptions provided by law. (d) The right not to be discriminated against for exercising your privacy rights. (e) The right to correct inaccurate personal information. To exercise these rights, contact the Site’s contact form and indicate your California residency. 7.3 Users residing in other U.S. states Several U.S. states have enacted privacy laws that recognize rights similar to those described above, including Colorado (CPA), Virginia (VCDPA), Connecticut (CTDPA), Utah (UCPA), and others. SHIBARI-DOJO honors rights requests made by residents of those states on the same terms set forth in this Policy, to the extent applicable. 7.4 Users located in the European Economic Area and the United Kingdom Web3Hispano LLC is a U.S. entity and its operations are conducted from the United States of America. User personal data is processed on cloud infrastructure servers whose physical location may vary among the Americas, Europe, and Asia depending on the automatic allocation made by the cloud service provider, without direct intervention by SHIBARI-DOJO over such allocation. SHIBARI-DOJO has no permanent establishment in the European Economic Area or the United Kingdom and does not formally represent that it is subject to the General Data Protection Regulation (GDPR) or equivalent UK legislation. Nevertheless, consistent with its privacy policy and out of respect for the rights of all its users, SHIBARI-DOJO grants users located in the EEA and the UK the same substantive rights set forth in Section 7.1 of this Policy, exercisable through the Site’s contact form. In the event that, for any reason, the GDPR or other European data protection law becomes applicable, the user may exercise their rights under such law through the same channel. 1. **Cookies and Similar Technologies** The Site uses strictly necessary technical cookies and proprietary analytical measurement cookies managed through Matomo, a self-hosted platform whose data is not shared with third parties. No advertising, retargeting, third-party analytics cookies, or any other external tracking technology are used. The technical cookies used serve the following purposes: (a) To maintain the user’s authenticated session while browsing the Site. (b) To remember the user’s technical preferences necessary for the proper functioning of the Site. (c) To ensure session security and prevent unauthorized access. Because these cookies are strictly necessary for the operation of the Site, they cannot be rejected without affecting the Site’s functionality, including access to areas restricted to registered users. Users who do not wish these cookies to be used must refrain from creating an account or logging in. 1. **Data Security** SHIBARI-DOJO implements reasonable technical and organizational measures to protect user personal data against unauthorized access, loss, alteration, or accidental disclosure, including password encryption, the use of secure connections (HTTPS), and access control to systems. No data transmission or storage system is completely secure. In the event of a security breach affecting personal data, SHIBARI-DOJO will take the necessary technical and legal measures to mitigate its effects and comply with any notification obligations required under the laws of the State of New Mexico and applicable federal law of the United States of America. Affected users will be notified via the email address registered in their account. 1. **Policy Changes** SHIBARI-DOJO reserves the right to amend this Policy at any time. Amendments will take effect upon posting on the Site. Material changes will be notified by a prominent notice on the Site. Continued use of the Site after amendments are posted constitutes acceptance of the updated Policy. 1. **Contact** For any inquiries, rights requests, or complaints related to the processing of personal data, users may contact SHIBARI-DOJO through the **contact form available on the Site**, which is the preferred communication channel, or in writing to the following postal address: **Web3Hispano LLC** 500 4th St NW, Suite 102, PMB 1612 Albuquerque, NM 87102 United States of America SHIBARI-DOJO will respond within a maximum period of 30 business days from receipt of the request through any of the indicated channels. --- *By using the Site, the user acknowledges that they have read and accepted the terms of this Privacy Policy.*