Privacy & Cookies

Part 1: Orientation

About this document

This Privacy Notice sets out how Kabuni Sports Ltd processes and protects the data that it collects from you when you access our website or use our services. This Privacy Notice contains the following sections:

Orientation: Who we are, what we do, and some definitions.

How we process your data: What we collect, how we use it and for how long we keep it.

Your rights: Your rights in relation to your data.

Cookies: Cookies and tracking technologies we use.

Who we are

We are Kabuni Sports Ltd, a UK company number 16604952. Our registered office and principal place of business is 128 City Road, London, United Kingdom, EC1V 2NX.

We are registered with the UK Information Commissioner's Office under number C1840336. For any queries or requests relating to your data, contact us at privacy@kabuni.com.

What we do

Kabuni is a sports‑science platform powered by machine learning. We combine AI, biomechanics, and health data to help people play, learn, and live better. Our interactive AI coach watches your game, reads your technique, and gives clear, spoken feedback in real time. Putting the expertise of a professional coach into every player’s kitbag.

Additional notes for users in India:

Under Indian law, we act as a "Data Fiduciary" and you are referred to as a "Data Principal".

If you want to exercise any of your rights under this privacy notice or make a complaint, please contact our Grievance Officer for India-related queries Joanne Rothwell, at privacy@kabuni.com.

Part 2: How we process your data

What information we collect

When you use our website or contact us, we may collect the following categories of information:

Your name and email address, where you submit it through our waitlist sign-up form or contact us directly.

Information you share with us via enquiry forms, email, or other communications channels, including the content of those communications.

Details about your device (including IP address, browser type, and operating system) and how you interact with our website, including pages visited, links clicked, and session duration.

Records of your marketing preferences and any consents or opt-ins you have provided in relation to receiving communications from us.

If you are located in India and are applying for the Kabuni Scout Program, please see the Kabuni Scout Program section of this Privacy Notice below, which sets out the additional personal data we collect from you and how we use it.

Why we collect it

We use your information for the purposes set out below:

Enquiry management
To respond to enquiries submitted via our website or by email/phone. Legal basis: Consent, Legitimate interests (customer communication).

Service notifications
To send service notifications about changes (such as changes to our website, associated services and legal terms) that affect you. Legal basis: Legitimate interests.

Marketing communications
To provide you with information about goods or services we feel might interest you (where you have opted-in). Legal basis: Consent.

Website optimisation
To ensure content from our website is presented in the most effective manner for you and your device. Legal basis: Legitimate interests (service improvement)

Security
To keep our website safe and secure, and as part of our efforts to detect and prevent security incidents, fraud and unauthorised access. Legal basis: Legitimate interests (security).

Waitlist registration

To add you to our pre-launch waitlist and to contact you about the launch of our platform. Legal basis: Legitimate interests (managing pre-launch interest in our services and communicating with prospective users about the launch of our platform).

Kabuni Scout Program applications

Please see the Kabuni Scout Program section of this Privacy Notice below.

Legal basis for processing

The legal basis for processing your personal information will typically be one of the following:

Consent – You have given clear consent for us to process your personal data for a specific purpose. You can withdraw your consent at any time by contacting us at privacy@kabuni.com.

Contract – Processing your data is necessary for a contract you have with us, or because you have asked us to take specific steps before entering into a contract.

Legitimate interests – Processing your data is necessary for our legitimate interests or the legitimate interests of a third party, provided those interests are not outweighed by your rights and interests. Our legitimate interests include operating and improving our website and services, and ensuring the security of our systems.

Legal obligation – Processing your data is necessary for us to comply with the law.

Who we share it with

We don't sell your information or share it with any other third parties for marketing purposes.

We may share your information with:

technologies we use to help us run our business and services (see Part 4);

the government or regulators if the law says we have to; and

If we are involved in a merger, acquisition, restructuring, insolvency, or sale of some or all of our assets, your personal data may be transferred to the relevant acquiring entity, successor organisation, or insolvency practitioner as part of that transaction. We will take reasonable steps to ensure that any recipient of your personal data in connection with such a transaction is bound by appropriate data protection obligations. We will notify you of any such transfer where required by applicable law.

How long we keep it

We will retain some categories of personal data for legal, regulatory and tax reasons, after our interaction or relationship has ended. We only retain personal data to the extent reasonably necessary.

Enquiry data
Retention period: 12 months from last contact.
Reason: To respond to follow-up queries and maintain records.

Marketing opt-out / opt-in records
Retention period: Indefinitely.
Reason: To ensure we respect your request not to receive marketing in future.

Legal and contractual records
Retention period: 7 years.
Reason: To meet legal obligations and manage potential legal disputes.

Data security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include:

Secure access controls
Unique login credentials and strong password requirements to prevent unauthorised access to systems and data.

Access restrictions
Data access limited to authorised personnel on a need-to-know basis, with role-based permissions and access logging.

Sharing safeguards
Reasonable safeguards including appropriate data processing agreements with subprocessors and subprocessor due diligence.

Regular security assessments
Ongoing security monitoring, vulnerability assessments and system updates to identify and address potential threats.

Staff training
Regular training for all staff on data protection principles, security best practices and incident response procedures.

Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. While we do our best to protect your personal data, we cannot guarantee the absolute security of information transmitted to our website. Any transmission is at your own risk.

If you have reason to believe that your interaction with us is no longer secure, please contact us immediately at privacy@kabuni.com.

If you are under the age of 18

You need to be 18 years or over to register on our site. If you are under 18, please ask your parent or guardian to register for you.

Notice for parents: We do not knowingly collect personal data from children under the age of 18 without parental/guardian consent. If you have reason to believe that a child under the age of 18 has provided personal data to us without your consent, please contact us so that we can delete that data.

Additional notes for users in India:

For persons with disabilities who cannot consent independently, or if we enable registration by individuals in India under the age of 18, we may require verifiable parental or guardian consent before processing personal data. We may obtain such consent through appropriate technological means during the registration process.

We do not engage in tracking, behavioural monitoring, or targeted advertising directed at children in India.

Part 3: Your rights

Your rights

Under data protection law, you have the following rights regarding your personal data:

Access
Request a copy of the personal data we hold about you.

Correction
Ask us to correct inaccurate or incomplete data.

Erasure (right to be forgotten)
Request deletion of your data (subject to our legal obligations to retain data).

Restrict processing
Ask us to stop processing your data temporarily.

Object
Object to processing based on legitimate interests.

Data portability
Receive your data in a structured format to transfer to another provider.

Withdraw consent
Where processing is based on consent, you can withdraw at any time.

Exercising your rights

To exercise any of these rights, email us at privacy@kabuni.com.

We will acknowledge your request within 72 hours of receiving your request and provide a substantive response within one month of your request. We may extend this period by up to two months for complex requests.

Right to complain

We would appreciate the opportunity to resolve your concerns before you contact the supervisory authority, so please contact us first. We will acknowledge your request within 24 hours and provide a substantive response within one month (or a shorter period if required by law).

If you consider our use of your personal information to be unlawful, or we have not responded to a request to exercise your rights or to a complaint, you have the right to complain to the Information Commissioner's Office (ico.org.uk).

Additional notes for users in India:

Our Grievance Officer for India-related queries (complaints or requests to exercise your rights) is Joanne Rothwell, contactable at privacy@kabuni.com.

If you are located in India, you may file a complaint with the Data Protection Board of India. You can do this by writing to the DPBI, or via the DPBI website or mobile app when that becomes available.

Please note that under Indian law, there is no right to data portability. Accordingly we do not make any commitments regarding the portability of your data if you are a user in India.

We will report all personal data breaches affecting users in India to the Data Protection Board of India. We will also, if required by law, notify you without delay if you are impacted by a data breach (providing information of breach extent, timing, consequences, and mitigation steps).

Part 4: Services we use

Third party services

Just like any other business, we use third parties to host our website and manage some processes. This means sharing your data with them. We do it only when strictly necessary and make sure there are safeguards in place.

Amazon Web Services (AWS)
Cloud hosting infrastructure, data storage, database services, backup services.
Located: UK, EU
More details: aws.amazon.com/privacy/

Google Cloud Platform
Email delivery services, Maps API, backup storage.
Located: EU, USA
More details: cloud.google.com/privacy

Google Analytics
Data analytics to assist us in improving and optimising the website.
Located: EU, US
More details: safety.google/

Google Workspace
Manage and store all our internal and external communications and documents.
Located: EU
More details: workspace.google.com/security/

International transfers

Some of our third-party service providers are based outside the United Kingdom and the European Economic Area (EEA), which means their processing of your personal data may involve a transfer of data outside these regions.

Whenever we transfer your personal data outside the UK or EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Adequacy decisions – We transfer data to countries that have been deemed to provide an adequate level of protection for personal data by the UK Government or the European Commission.

Standard Contractual Clauses – We use specific contracts approved by the UK Information Commissioner's Office or the European Commission which give personal data the same protection it has in the UK and Europe.

Other safeguards – In limited circumstances, we may rely on other lawful transfer mechanisms such as binding corporate rules or your explicit consent.

Part 5: Cookies

What are cookies

Like many businesses, we collect information through cookies. A cookie is a small, often encrypted, piece of information that a website puts on your computer so it can remember something about you or your device at a later date. We use cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our services.

By using our website, you agree to our use of cookies. When you first visit our website, a cookie consent banner will appear allowing you to select which types of cookies you wish to accept or reject.

Types of cookies we use

Our website is built on Squarespace. The cookies used on Squarespace websites are described here: https://support.squarespace.com/hc/en-us/articles/360001264507-The-cookies-Squarespace-uses

The types of cookies used by us can be classified into the following categories:

Essential Website Cookies
These cookies are essential to provide you with our website and any services available through it, and to use some of its features, such as access to secure areas. Without these cookies, services you have asked for cannot be provided.
How to remove: These cookies are necessary for the website to function and cannot be switched off. You can set your browser to block these cookies, but some parts of the site will not work.

Functionality Cookies
Remember choices you make (such as your username, language or region) and provide enhanced, more personal features. These cookies allow us to save your preferences and settings.
How to remove: You can control these through your browser settings. Most browsers allow you to refuse functionality cookies.

Analytics/Performance Cookies
Collect information about how visitors use our website, such as which pages are visited most often, page response times, and if visitors get error messages. All information is aggregated and anonymous.
How to remove: You can opt out of Google Analytics by installing the Google Analytics opt-out browser add-on, or control through browser settings.

Managing cookies

You can control cookies through your browser settings, and through the pop-up cookie banner when you first visit our website. However, disabling essential cookies may prevent the website from functioning properly.

Most browsers allow you to:

View what cookies are stored and delete them individually

Block third-party cookies

Block all cookies from specific websites

Delete all cookies when you close your browser

For more information, visit www.allaboutcookies.org.

Part 6: Final words

Changes to this notice

We may update this Privacy Notice from time to time to reflect changes in the law, our data practices, or the services we provide. The updated version will be posted on our website and will carry a revised "Last updated" date at the top of this notice.

Where we make changes that are material to the way in which we process your personal data, we will take reasonable steps to bring those changes to your attention — for example, by sending an email notification to the address you have provided to us or by displaying a prominent notice on our website.

Your continued use of our website following publication of a revised notice will constitute your acknowledgement of those changes. If you do not agree to the revised notice, please cease using our website and contact us at privacy@kabuni.com.

Contact us

If you have questions about this Privacy Notice or our data practices, or wish to exercise your rights, please contact us at privacy@kabuni.com.

Kabuni Sports Ltd
128 City Road, London, United Kingdom, EC1V 2NX

Part 7: Kabuni Scout Program

About this Part

This Part applies exclusively to individuals located in India who interact with us through the Kabuni Scout Program.

What information we collect from Kabuni Scout Program applicants

When you apply through the Kabuni Scout Program sign-up form on our website, we collect the following personal data:

Your first name and last name;

Your date of birth;

Your country and city of residence (selected from the options provided on the form);

Your school email address; and

Your marketing preferences, including whether you have opted in to receiving communications from Kabuni.

We collect your date of birth in order to verify that you are within the eligible age range for the Kabuni Scout Program (16 to 20 years old) and, where you are under 18.

We collect your school email address as the primary means by which we will contact you regarding your application. Where you are under 18, your school email address will also be used to initiate the parental or guardian consent process described below.

Why we collect it and our legal basis under Indian law

We process the personal data of Kabuni Scout Program applicants for the following purposes:

Processing your application - To assess your eligibility for the Kabuni Scout Program, to contact you about the outcome of your application, and to administer your participation in the programme if your application is successful. We process your data for this purpose on the basis of your consent, given at the point of submitting your application.

Age verification and safeguarding - To verify your age, and where you are under 18, to implement the parental or guardian consent process required under the DPDPA before we process your personal data further. We process your data for this purpose on the basis of our obligation to comply with applicable law.

Marketing communications - If you have opted in to receiving marketing communications, to send you news, updates, and offers from Kabuni by email. We process your data for this purpose on the basis of your consent, given through the optional opt-in checkbox on the sign-up form. You may withdraw this consent at any time by contacting us at privacy@kabuni.com or by clicking the unsubscribe link in any marketing communication.

Service notifications - To notify you of material changes to these terms, our services, or your application. We process your data for this purpose on the basis of your consent and our legitimate interest in communicating with applicants.

Transfer of your personal data to the United Kingdom

Kabuni Sports Ltd is a UK company. Personal data submitted through the Kabuni Scout Program sign-up form will be transferred from India to the United Kingdom and processed by us and our third-party processors in the United Kingdom.

We carry out this cross-border transfer in accordance with the requirements of the DPDPA and applicable regulations. We ensure that appropriate safeguards are in place to protect your personal data during and following any such transfer.

‍