Kura Sushi USA, Inc. and its parents, subsidiaries, and affiliates, and their respective stockholders, directors, officers, employees, agents, successors and assigns (collectively, “Kura Sushi,” “Kura” or “Kura Revolving Sushi Bar”) is very sensitive to the privacy concerns of the visitors to and users of (collectively “Users”) its website, Kura Sushi Rewards mobile application (“App”), rewards programs, and other online programs (collectively the “Kura Online Service” or “Service”).
Under certain laws, the definition of personal information (which we use broadly to include similar terms such as “personal data”) is broader and also covers things like online identifiers (for example, IP address, cookie IDs, device IDs). Where information does not qualify as personal information, including information that has been deidentified, anonymized, or aggregated, we will not treat it as such. However, where we are required by law to treat certain information as personal information, or where we combine certain information with personal information, we will treat it as personal information.
We collect information in relation to the operation of our business and, most importantly, to run our restaurants, serve you sushi, and operate our Kura Sushi Rewards Program. Some of the data categories listed below may not apply to you, depending on how you interact with us.
Identifiers, including your name and account names, as well as date of birth, if you provide it to us on the App. It also includes online identifiers such as mobile advertising ID, IP address, and cookie ID that we may use in relation to our advertising activities.
Contact Information such as your email address, phone number, and address.
Personal Characteristics and Traits, such as where we provide you the option to submit information regarding whether you are visually impaired or have any reach limitations, in order to assist with fulfilling your order. In addition, we may collect certain demographic information, such as age and gender.
Account Details and Commercial Information such as your purchase history and amounts, favorite menu items and communications preferences.
Financial and Payment Information, such as your payment card information (we do not handle full payment card info directly, but rather rely on Vendors for doing so).
Service Usage Information. This includes information collected by Tracking Technologies (defined below), which includes information such as:
your device functionality (browser, operating system, hardware, mobile network information);
the URL that referred you to our Kura Online Service;
the areas within our Kura Online Service that you visit and your activities there (including emails we send, such as whether you open them or click on links within);
your device location (if you have enabled such features on your device);
your device characteristics; and
device data and the time of day.
Location Data such as where you enable features on your device to provide us with your location (which may include your precise location).
Audiovisual and Similar Information such as CCTV recordings in our retail locations and customer service call recordings.
Inferences including information derived from other information that we have collected. For example, we may make inferences about you based on your order history or other information about you in order to provide you with offers or advertisements that are most relevant to your interests.
User Content as described in our Terms & Conditions.
The definition of personal information under certain laws is limited to information that can be used to directly identify you, such as your name, email address, and similar information. Under other laws the definition of personal information is broader and also covers things like online identifiers (IP address, cookie IDs, device IDs). Where we are required by law to treat certain information as personal information, or where we combine certain information with personal information, we will treat it as such.
Directly From You on the Kura Online Service
E-mail addresses and other Personal information of visitors, such as a first and last name, home or other physical address, date of birth or telephone number, are known to Kura only when voluntarily submitted, for example, via purchases made through the Kura Online Service, registration for sweepstakes or contests, content submissions, suggestions or participation in online interactive activities. For example, you may submit your name, postal address, e-mail address, and/or other information in order to receive information about various subjects, register for programs, contact customer service, or respond to surveys.
Information from your Kura Revolving Sushi Bar Visits
We may collect information using technology in our stores and premises, such as cameras and CCTV. This technology is used for operational and security purposes, to protect the health and safety of our customers and associates and to prevent, investigate, and prosecute shoplifting, fraud, and other criminal activities. We may also collect information directly from you when you visit a store, such as when you interact with a team member or order sushi or drinks in person.
Automatically from You or Your Device When You Visit the Service
We may use a variety of technologies that store or collect certain information whenever you visit or interact with the Kura Online Service. This information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, browser, laptop, tablet, mobile phone or other device whenever you visit or interact with our Kura Online Service.
In addition, we may collect certain information by automated means. The information we collect may include your Internet Protocol (IP) address, computer/mobile device operating system and browser type, type of mobile device, the unique device identifier (UDID) or mobile equipment identifier (MEID) for your mobile device, and others (“Device Identifiers”). We may use such Device Identifiers to associate information you have provided on different devices, or during separate interactions with us on the Kura Online Service on the same device. For example, if you login to your account on your mobile phone, then later login to your account on your tablet or laptop, we may collect those Device Identifiers and associate those two devices and their Device Identifiers with other information we have on you. By way of another example, if you use the Kura Online Service (for example, to order sushi) while logged into your account during one interaction but later use the Kura Online Service on the same device, but not logged into your account, we may use Device Identifiers and other information to associate these separate interactions with the Kura Online Service with your single device. We may also collect the address of a referring web site (if any), the pages you visit on our Kura Online Service, and other information. We may use this information to operate, maintain, and manage our Kura Online Service and to provide services such as technical support.
We may use various tracking technologies such as those described below (“Tracking Technologies”) to collect information on the Kura Online Service, including the types of information described above in the Types of Information Collected section, above. Tracking Technologies include:
Cookies. A cookie is a data file placed on a device when it is used to visit the Kura Online Service.
Web Beacons. Small graphic images or other web programming code called web beacons (also known as “1x1 GIFs” or “clear GIFs”) may be included in our Kura Online Service’s pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon. Web beacons or similar technologies can be used to count visitors to the Kura Online Service, to monitor how users navigate the Kura Online Service, to count how many e-mails that were sent were actually opened or to count how many links were actually viewed.
Embedded Scripts. An embedded script is programming code that is designed to collect information about the links you click on and your interactions with the Kura Online Service. The code is temporarily downloaded onto your device from our web server or a third-party service provider, is active only while you are connected to the Kura Online Service, and is deactivated or deleted thereafter.
Location-Identifying Technologies. Our Kura Online Service may provide you the ability to enable location-identifying technologies, including “location services” on our App, to find the nearest Kura Revolving Sushi Bar. Some location-identifying technologies rely on Bluetooth technology, which you also have to enable with respect to the App in order for our App to interact with such technology. For example, some retail locations may install Bluetooth, Wi-Fi, radio transmitters, or other devices, which have the ability to communicate with your App or collect information about your device when you are in or near a retail location. In order to stop utilizing, or to change the settings with respect to, location-identifying technologies on our App, you can change your device settings.
There may be other Tracking Technologies now and later devised and used by us in connection with the Kura Online Service.
From Our Affiliates and Related Entities
We may receive information from our affiliates and related entities that are part of the Kura Sushi, Inc. family.
We may receive information about you from third parties, including your friends and others (when they submit content to us or post or interact with the Kura Online Service) and Third-Party Services. Additionally, we may, from time to time, supplement the information we collect with information from third parties.
Information You Provide about Others
The Kura Online Service may allow you to submit the personal information of someone else, such as if you are ordering sushi to a friend’s house and provide their address. In addition, the Kura Online Service (or a Third-Party Service) may offer functionality to send someone else an invitation or other communication. If so, the information you provide is used to facilitate the communication or transaction and is not used by us for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise. Please see our Terms & Conditions for our expectations and your obligations as to information that you submit. Please be aware that when you use any send-to-a-friend functionality, your information, including contact information, name or username and message, may be included in the communication sent to your addressee(s), and the communication will indicate it was sent at your request and/or on your behalf.
Generally, we use and otherwise process personal information to provide you with sushi and other products and services you purchase or request, personalize our offerings, services, and marketing, and to otherwise support our business. Below are more specific examples of various purposes for which we use personal information:
Providing our products and services, including to provide you with information, goods, or services, or process transactions that you have requested or agreed to receive, to enable you to participate in a variety of the Kura Online Service’s features, including ordering sushi and finding a nearby Kura Revolving Sushi Bar; to process your registration with the Kura Online Service, verify your personal information is active and valid; to facilitate a purchase, including facilitating payment for your purchase.
Operating our business.
Customer service and communications, including responding to any questions, comments, or requests that you have for us or for other customer service purposes; sending you communications and notifications about your use of the Kura Online Services or your other interactions with us, and changes to the Kura Online Service and/or Service’s policies or other aspects of our business operations.
Administering accounts and loyalty programs, such as the Kura Sushi Rewards Program.
Research, development, and analytics, including to better understand how users access and use our websites, Apps, and other Kura Online Services, both on an aggregated and individualized basis, in order to improve our Kura Online Service and respond to user desires and preferences, and for other research, development, and analytical purposes relating to the Kura Online Service, our retail locations, and the operation of our business.
Promotions and marketing, including sweepstakes, contests, and other promotions that you sign up for (which may include co-promotions with third parties), and to provide you with special offers or promotional materials on behalf of us or third parties.
Customizing your experience, offers, and content, including to customize your experience on the Kura Online Service, or to serve you specific content and offers that are relevant to or customized for you (including, without limitation, pricing and discounts based on your profile, location, or history).
Targeting advertisements to you or your device to assist us in determining relevant advertising.
Ad measurement, attribution, and other ad administration, including to determine the success of our advertising campaigns and to help us determine where to place our ads, including ads placed on other websites and services.
Market research and customer satisfaction, including administering surveys and questionnaires, such as for market research or customer satisfaction purposes.
For security and safety purposes, including to detect and respond to threats, to both our in-store and online operations, protect the health and safety of our customers, team members, and the public, and to prevent, investigate and prosecute criminal activities.
To comply with legal obligations, including as part of our general business operations, for other business administration purposes, or as otherwise required or compelled.
For purposes disclosed at the time you provide your personal information.
For our legitimate business purposes that are compatible with the purpose of collecting your personal information and that are not prohibited by law.
We operate a loyalty program, the Kura Sushi Rewards Program, to thank you for visiting our restaurants and eating our sushi. The personal information collected from the Kura Sushi Rewards Program is used to administer the loyalty program. We do not give you rewards or a discount in exchange for your personal information.
Third-Party Services. Third-Party Services may collect your personal information independently on the Kura Online Service, or we may directly provide them with personal information that we have collected on the Kura Online Service, including in relation to Interest-Based Advertising and other purposes.
Third-Party Promotional Partners. Where we have the legal right, we may disclose or otherwise make your personal information available to promotional partners or other third parties for a business purpose that we have approved. When we disclose personal information in these contexts, we make sure that we comply with applicable legal requirements, which may include providing opt-out or other rights with respect to the shared data. This may also include sponsors, co-promotional partners and other third parties on co-branded areas of the Kura Online Service. The data practices of these third parties are subject to their own privacy policies and terms.
With notice or your consent. We may disclose your personal information to third parties with notice to you, as directed by you, or, where legally required, upon your consent or authorization.
Corporate Transactions. We may disclose and transfer your personal information: (i) to a subsequent owner, co-owner, or operator of the Kura Online Service or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, or a financing, and during the course of any due diligence process.
Your personal information may be stored and processed by Vendors and other third parties implicated above in the United States or other locations where they maintain facilities.
If the Kura Online Service permits you to submit content (“User Content”), we or others may store, display, reproduce, publish, distribute, or otherwise use User Content online or offline in any media or format (currently existing or hereafter developed) and may or may not attribute it to you. You choose what User Content you submit. You may be able to submit User Content including ideas, photographs, user profiles, writings, music, video, audio recordings, computer graphics, pictures, data, questions, comments, suggestions, and Personal Information, to private areas of the Service, or to public areas of the Kura Online Service such as blogs and message boards. Others may have access to this User Content and may have the ability to share it with third parties. Please think carefully before deciding what information you share, in connection with your User Content. Please note that Kura does not control who will have access to the information that you choose to make public and cannot ensure that parties who have access to such publicly available information will respect your privacy or keep it secure. We are not responsible for the accuracy, use or misuse of any User Content that you disclose or receive from third parties through the Kura Online Service.
The Service has functionality that allows certain kinds of interactions between the Service and third-party content, web sites, applications, platform, code ((e.g., plug-ins, application programming interfaces (“API”), and software development kits (“SDKs”)), and Tracking Technologies (collectively, “Third-Party Services”).
We are not responsible for the policies or business practices of Third-Party Services, including how they collect, use, or share your information, including through Tracking Technologies that collect information regarding your visit to the Kura Online Service as well as after your visit is over. These Third-Party Services may have their own terms of service, privacy policies or other policies and ask you to agree to the same. Be sure to review any available policies before submitting any personally identifiable information to or otherwise interacting with any Third-Party Services.
You may unsubscribe from our email and other electronic marketing communications you receive from us as follows: (i) for promotional emails, following the instructions provided in emails to click on the unsubscribe link, or if available by changing your communication preferences by logging onto your account; (ii) for text messages, following the instructions provided in text messages from us to text the word, “STOP” (or as otherwise instructed); and (iii) for app push notifications, turn off push notifications on the settings of your mobile device.
Opting out of certain communications will not affect subsequent subscriptions and, if your opt-out is limited to certain types of electronic communications, the opt-out will be so limited. Subsequent or different subscriptions will be unaffected. Please note that we reserve the right to send you certain communications relating to your account or use of our Service and administrative and service announcements. These transactional messages will be unaffected if you choose to opt-out of marketing communications.
All of the App’s features and functionality, and its related data collection, can be terminated by uninstalling the App. You can use the App’s or your device’s settings to set and change some settings and control some functions, such as enabling or disabling certain features (e.g., “tracking”, Bluetooth, location-based services, push notifications, etc.).
Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options, so you may need to set them separately. Also, tools from commercial browsers may not be effective with regard to certain Tracking Technologies.
Some App-related Tracking Technologies in connection with non-browser usage (e.g., most functionality of a mobile app) can only be disabled by uninstalling the app. To uninstall an app, follow the instructions from your operating system or device manufacturer. Apple and Google mobile device settings have settings to limit ad tracking, and other tracking, but these may not be completely effective.
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you can visit http://www.allaboutdnt.com, but we are not responsible for the completeness or accuracy of this third-party information.
Some third parties, however, may offer you choices regarding their Tracking Technologies.
Interest-Based Advertising Industry Opt-Out Programs
There are two advertising industry organizations – the Network Advertising Alliance (NAI) and Digital Advertising Alliance (DAA) that offer opt-out programs. You can visit the following links to submit opt-out requests to companies participating in each program. The NAI’s opt-out page provides detailed information regarding the opt out of Interest-based Advertising and its limitations. For similar information from the DAA regarding its opt-out program, click here (web-based program) and here (app-based program).
Please be aware that, even if you are able to opt out of certain kinds of Interest-based Ads, you will continue to receive non-targeted ads. Further, if you selectively opt out of one or more of the above opt-out programs, you may receive Interest-based Advertising from other participants. You may also receive Interest-based Advertising from parties that do not participate in the NAI or DAA’s programs. However, Kura supports the ad industry’s Self-regulatory Principles for Online Behavioral Advertising and expect that ad networks Kura directly engages to serve you Interest-based Ads will do so as well, though Kura cannot guaranty their compliance.
We may also use Microsoft Advertising Services. To learn about the data Microsoft collects and how your data is used by it and to opt-out of certain Microsoft browser Interest-based Advertising, please visit here.
We may also use Google Ad Services. To learn more about the data Google collects and how your data is used by it and to optout of certain Google browser Interest-Based Advertising, please visit here.
Important Notice Regarding Opt-Outs
We are not responsible for effectiveness of, or compliance with, any third parties’ opt-out options or programs or the accuracy of their statements regarding their programs. You will need to exercise the above choices on each browser or device that you use. Please be aware that if you disable or remove certain Tracking Technologies, some parts of the Service may not work or will function with more limited capabilities. In addition, please note that your choices sometimes rely on Tracking Technologies, such that when you clear or disable them, your choices are reset.
You may also proactively limit the amount and type of actively-transmitted personal information that Kura receives about you by choosing not to enter any personal information into forms or data fields on the Kura Online Service. However, some services can only be provided to you if you provide appropriate personal information. Other parts of the Kura Online Service may ask whether you wish to opt out or opt in to contact lists for offers, promotions and additional services that may be of interest to you.
You may also be provided with preference questions or preference boxes allowing you to indicate that you do not want the Kura Online Service to use tracking technologies, such as cookies, to “remember” your Personal information, such as user IDs or mailing addresses, on return visits. However, if the Kura Online Service uses tracking technologies to collect unidentifiable information, it will not generally provide you with the ability to opt out of the tracking technologies. Some internet browsers allow you to limit or disable the use of tracking technologies that collect passively-transmitted information. More detailed information about cookie management or other passive transmissions by specific web browsers can be found at the browser's respective websites.
Residents of California (“Consumers”) have certain privacy rights, including those provided by the California Consumer Privacy Act, including as amended by the California Privacy Rights Act (“CCPA”). These rights include, the Right to limit the processing of sensitive personal information, the right to know categories of personal information, the right to know specific pieces of personal information, the right to delete personal information, the right to correct inaccuracies in your personal information, and your right to opt-out of certain processing activities (those activities which may be deemed “selling” or “sharing” under the CCPA). Contact us at firstname.lastname@example.org , by phone at 855-387-5872, or by mail at 17461 Derian Ave, #200, Irvine, CA 92614 (Attn: CCPA Rights Request”) to exercise your rights.
We disclose our tracking and “do not track” practices in the Tracking Technologies and Interest-based Advertising section above. Any California residents under the age of eighteen (18) who have registered to use the Service, and who have posted content or information on the Service, can request that such information be removed from the Service by contacting us at the email or address set forth in the Children’s Privacy Notice making such a request, stating that they personally posted such content or information and detailing where the content or information is posted. We will make reasonable good faith efforts to remove the post from prospective public view or anonymize it so the minor cannot be individually identified. This removal process cannot ensure complete or comprehensive removal. For instance, third-parties may have republished the post and archived copies of it may be stored by search engines and others that we do not control. We comply with California Civil Code Section 1798.83 (the “Shine the Light” law) by not sharing your personal information with third parties for their direct marketing purposes (as those terms are defined by that law) without your consent. If you are a California resident, you may request information about our compliance with the Shine the Light law by contacting us in the following ways: Postal Mail: 17461 Derian Ave, #200, Irvine, CA 92614, Attn: STL Request; by e-mail at email@example.com . Please note that the CCPA and Shine the Light are different laws offering different rights and requests must be made separately.
We do not believe we “sell” “covered information” of Nevada “consumers” as those terms are defined by Chapter 603A of the Nevada Revised Statutes. Though we do not believe we sell covered information, Nevada’s law requires us to provide a method for Nevada consumers to make requests to opt out of sale, which you can do by e-mail at firstname.lastname@example.org.
Kura endeavor to incorporate commercially reasonable safeguards to help protect and secure your personal information on the Kura Online Service. However, the confidentiality and security of personal information transmitted over the Internet cannot be guaranteed. We urge you to exercise caution when transmitting personal information over the Internet, Please note that we cannot ensure the security of any personal information you transmit to us, and you use our Kura Online Service and otherwise provide us with your information at your own risk.
We do not use the Kura Online Service to knowingly collect Personal information online from children under the age of 13 without the appropriate parental or guardian consent.
In the event that we become aware that we have collected personal information from any child, we will dispose of that information in accordance with the Children’s Online Privacy Protection Act (“COPPA”) and other applicable laws and regulations. If you are a parent or guardian and believe we may have collected such information without parental or guardian consent or other than in a manner authorized by law, please contact us at email@example.com.
All notices to Kura Sushi can be sent via email to firstname.lastname@example.org or mailed to Kura Sushi USA, Inc., ATTN: Rewards Department, 17461 Derian Ave, Suite 200, Irvine, CA 92614.